COMMISSION STAFF WORKING DOCUMENT EVALUATION acompanying the Impact assessment report of the Proposal for a Directive of the European Parliament and of the Council amending Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers, Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union, and Directive 1999/37/EC on the registration documents for vehicles
Date: 2025-04-24
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: data recording, exchange of information, information system, road safety, road transport, roadworthiness tests, technical regulations, vehicle, vehicle documents, vehicle registration

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 24.4.2025  SWD(2025) 98 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  acompanying the Impact assessment report of the Proposal for a Directive of the European Parliament and of the Council  amending Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers, Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union, and Directive 1999/37/EC on the registration documents for vehicles {COM(2025) 179 final} - {SEC(2025) 119 final} - {SWD(2025) 96 final} - {SWD(2025) 97 final} - {SWD(2025) 99 final}  
 
 
Table of contents 

Contents 

1 

INTRODUCTION .................................................................................................................. 1 

1.1  Context ................................................................................................................ 2 

1.2  Purpose and scope of the evaluation ................................................................ 4 

1.3  Evaluation methodology .................................................................................... 5 

2  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ......................... 5 

2.1  Description of the intervention and its objectives ........................................... 5 

2.2  Points of comparison ....................................................................................... 10 

2.2.1 

2.2.2 

2.2.3 

Road safety points of comparison .............................................................. 11 

Emissions and air pollutant points of comparison ...................................... 12 

Other expected impacts .............................................................................. 14 

3 

HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ......... 14 

3.1  State  of  play  –  transposition  and  implementation  of  the  Roadworthiness 
Package ...................................................................................................................... 14 

3.2  Market developments ...................................................................................... 18 

4 

EVALUATION FINDINGS (ANALYTICAL PART) ......................................................... 21 

4.1  To what extent was the intervention successful and why? ........................... 21 

4.1.1 

4.1.2 

4.1.3 

Effectiveness............................................................................................... 21 

Efficiency ................................................................................................... 32 

Coherence ................................................................................................... 35 

4.2  How did the EU intervention make a difference and to whom? ................. 36 

4.3  Is the intervention still relevant? .................................................................... 37 

5  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ................................... 41 

5.1  Conclusions ....................................................................................................... 41 

5.1.1 

5.1.2 

5.1.3 

5.1.4 

5.1.5 

Effectiveness............................................................................................... 41 

Efficiency ................................................................................................... 42 

Coherence ................................................................................................... 42 

EU added value........................................................................................... 43 

Relevance ................................................................................................... 44 

5.2  Lessons learned ................................................................................................ 44 

5.3  Robustness of the conclusions ......................................................................... 45 

ANNEX I: PROCEDURAL INFORMATION............................................................................... 46 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ..................................... 48 
ANNEX III. OVERVIEW OF BENEFITS AND COSTS .............................................................. 51 

 
 
 
ANNEX IV. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT .............................. 53 
ANNEX V. INTERVENTION LOGIC .......................................................................................... 75 
ANNEX VI. SUMMARY OF CURRENT LEGISLATIVE FRAMEWORK ................................ 77 

ANNEX  VII.  THE  MINIMUM  REQUIREMENTS  SET  OUT  IN  THE  DIRECTIVES  AS 
EXCEEDED BY SOME MEMBER STATES ..................................................................... 81 
ANNEX VIII. EVALUATION MATRIX AND THE EVALUATION QUESTIONS .................. 82 

 
 
 
 
 
GlossaryTerm 
or acronym  

Meaning or definition  

ABS  

ACEA  

ADAS  

BC  

CARE  

CITA  

CNG  

CO 

COC  

DPF  

EEA 

EGR 

EPRS  

ESC  

EUCARIS 

Anti-lock Braking System. This is an electronic system used which operates by 
preventing  the  wheels  from  locking  up  during  braking,  thereby  maintaining 
contact with the road surface and allowing the driver to maintain more control 
over the vehicle. 
Association des Constructeurs Européens d'Automobiles (European 
Automobile Manufacturers' Association)  
Advanced Driver Assistance Systems refer to systems that support the driver in 
their primary driving task. These systems can inform or warn the driver, but also 
take over (part of) vehicle control. 
Black carbon: a component of fine particulate air pollution (PM2.5). It is formed 
by the incomplete combustion of wood and fossil fuels, a process which also 
creates  carbon  dioxide  (CO2),  carbon  monoxide  (CO),  and  volatile  organic 
compounds. It  lasts  only  days  to  weeks  in  the  atmosphere  but  has  significant 
direct and indirect impacts on the climate and human health. 
CARE is an EU database on road crashes resulting in death or injury. Council 
Decision  93/704/EC  (on  the  creation  of  a  Community  Database  on  road 
accidents) obliges Member States to provide annual data on road accidents but 
does  not  specify  the  content.  The  CARE  expert  group  composed  of  national 
representatives meets 1-2 times per year to discuss issues related to the database 
and the variables, as well as the collection, processing and dissemination of data. 
International Motor Vehicle Inspection Committee - an international non-profit 
association of authorities and companies involved in vehicle compliance. 
Compressed Natural Gas  
CO (carbon monoxide): colourless odourless very toxic gas that is formed as a 
product  of  the  incomplete  combustion  of  carbon  or  a  carbon  compound.  The 
greatest sources of CO to outdoor air are vehicles or machinery that burn fossil 
fuels. 
A Certificate of Conformity is a statement by a vehicle manufacturer that the 
vehicle conforms to EU type-approval requirements. 
Diesel Particulate Filter is a device designed to remove diesel particulate matter 
or soot from the exhaust gas of a diesel engine.  
European Environmental Agency  
Exhaust Gas Recirculation (EGR) is a system for reducing automotive nitrogen 
oxide (NOx) emissions in petrol, diesel and some hydrogen engines. The high-
pressure EGR loop collects part of the exhaust gases at the cylinder head outlet 
and re-injects them into the engine air intake. 
European Parliamentary Research Service  
Electronic Stability Control is an extension of anti-lock braking technology, 
which has speed sensors and independent braking for each wheel. It addresses 
the problem of skidding and crashes due to loss of control of vehicles, 
especially on wet or icy roads or in rollovers. 
European  car  and  driving  licence  information  system.  This  is  an  initiative  of 
several European countries, formalised in a multilateral treaty, and focused on 
the data-exchange regarding vehicle registration, driving licences etc.  

 
 
 
GHG  

HMI  

ISO  
NOx 

OBD  

OBFCM  

OBM  

OPC  

PN and PM 

PTI  

RDE  

RSI  
RWP  

SCR  

TWC  

UNECE  

VRD  

Greenhouse gases  
Human Machine Interface is a user interface or dashboard that connects a 
person to a machine, system, or device. It includes the hardware and software 
that is used to translate user input into commands, and to present results to the 
user.  
International Organization for Standardization  
Nitrogen Oxides 
On-board  Diagnostics is  a  computer  system  in  a  vehicle  that  monitors  its 
performance.  It  collects  information  from  the  network  of  sensors  inside  the 
vehicle, which the system can use to  regulate car systems or alert the user to 
problems. A technician can read relevant data through the OBD port to diagnose 
problems. 
An on-board Fuel Consumption Monitoring Device uses vehicle, engine, fuel 
and/or electric energy parameters to determine and make available information 
(such as fuel consumption, distance travelled, and speed) and stores the 
lifetime values on board the vehicle. 
On-Board  Monitoring means  a  system  on  board  a  vehicle  that  is  capable  of 
detecting and communicating either emission exceedances or when a vehicle is 
in zero emission mode. 
Open Public Consultation  
Particle Number measurement, a measure of air pollution, is a method of 
measuring particulate emissions, typically expressed as the number of particles 
per cm3. Particulates (or particulate matter – often abbreviated to PM) 
are microscopic particles of solid or liquid matter suspended in the air. 
Periodical technical inspection  
The Real-Driving Emissions test is part of the type-approval procedure for all 
new passenger cars and vans. The RDE test is an on-road emissions test meant 
to complement laboratory tests to ensure vehicle  emissions are similar during 
normal, real-world operating conditions as they are during laboratory testing. 
Roadside Inspection  
Roadworthiness Package  
Selective  Catalytic  Reduction is  a  technology  that  reduces  nitrogen  oxides 
(NOx) from exhaust gases of diesel engines. It converts NOx into nitrogen and 
water  vapour,  and  also  improves  fuel  economy  and  performance  of  diesel 
engines. 
Three-Way Catalytic converter is a device used in the exhaust system to 
convert harmful gases in the engine exhaust to relatively harmless gases. It is 
called a three- way catalytic converter because it can convert three types of 
pollutants simultaneously. 
United  Nations  Economic  Commission  for  Europe.  One  of  5  regional 
Commissions of the United Nations, its remit includes transport (including road 
safety) and vehicle regulations. 
Vehicle Registration Document  

 
 
 
1 

INTRODUCTION 

This  report  presents  the  findings  of  the  evaluation  of  the  three  Directives  that  together 
comprise the Roadworthiness Package (hereinafter the “RWP”). These Directives are: (i) 
Directive  2014/45/EU  on  periodic  roadworthiness  tests  for  motor  vehicles  and  their 
trailers, (ii) Directive 2014/47 EU on roadside inspections of commercial vehicles, and (iii) 
Directive 2014/46 EU on registration documents for vehicles.  

The evaluation is performed “back-to-back” with an Impact Assessment for the possible 
review of the RWP. This exercise is in line with the Commission’s Sustainable and Smart 
Mobility Strategy1 adopted in 2020 which reconfirmed the Union’s commitment to pursue 
improving road safety and the objective of zero road fatalities by 2050. In this context, the 
Strategy  stated  that  “Our  roadworthiness  legislative  framework  should  be  adjusted  to 
ensure the lifetime compliance of vehicles with emission and safety standards.” 

Improving road safety is a prime objective of the EU's transport policy. The EU is pursuing 
a  policy  to  improve  road  safety  with  the  objective  of  reducing  fatalities,  injuries  and 
material  damage.  The  EU’s  regulatory  framework  for  road  safety  addresses  the  core 
elements of the Safe System Approach (road use, infrastructure, vehicles and post-crash 
care) and combines binding legal acts and recommendations to Member States. The EU 
road safety policy also builds on national initiatives, setting targets and addressing the key 
factors  that  play  a  role  in  road  crashes,  supporting  public  awareness  and  education 
campaigns, helping Member States and other road safety actors share relevant experience. 

Over  the  last  20  years,  EU  roads  have  become  significantly  safer.  The  number  of  road 
fatalities has gone down by 60% from around 51,400 in 2001 to around 20,600 in 2022. 
The 2022 figure represents 2,100 fewer fatalities (-9%) compared with the pre-COVID-19 
pandemic year 2019.  Nevertheless, the improvement in  road safety  has not  been strong 
enough to meet the EU’s political ambition to decrease the number of road deaths by 50% 
between  2001  and  2010,  and  by  additional  50%  between  2011  and  2020  (i.e.  by  75% 
between  2001  and  2020).  This  political  ambition  stems  from  a  number  of  strategic 
documents issued by the Commission over the last two decades, such as the White Paper 
on  European  Transport  Policy  for  20102,  the  2011  White  Paper  on  a  Single  European 
Transport Area3 or the Communication from the Commission on Towards a European road 
safety area: policy orientations on road safety 2011-20204.  In its Sustainable and Smart 
Mobility Strategy of 2020, the Commission committed to target zero fatalities in all modes 
of transport by 2050. 

In the years before 2020, there was hardly any drop in the number of road fatalities. This 
slowdown, that already appeared around 2014, prompted the Transport Ministers to issue 
a  ministerial  declaration  on  road  safety  at  the  informal  transport  Council  in  Valletta  in 
March  20175,  whereby  the  Member  States  called  upon  the  Commission  to  explore  the 
strengthening of the Union’s road safety legal framework to reverse that stagnating trend. 
Against this background, and in the context of the Safe System Approach that focuses on 
safe infrastructure, safe  vehicles, safe road use and better post-crash  care, an important 

1 COM(2020) 789 final, 9.12.2020 
2 COM(2001) 370 final, 12.9.2001 
3 EUR-Lex - 52011DC0144 - EN - EUR-Lex (europa.eu) 
4 COM/2010/0389 final, 20.7.2010 
5 Valletta Declaration on Road Safety (europa.eu) 

1 

 
 
element of the Union’s efforts to improve road safety is to improve the safety of the vehicle 
fleet. 

1.1  Context  

Various measures  have  been  introduced  at  EU  level  since 1977, as Member States had 
begun developing their own national regulations regarding vehicle roadworthiness testing, 
leading to a lack of harmonisation.  

Directive  77/143/EEC  on  the  approximation  of  the  laws  of  the  Member  States  relating  to 
roadworthiness tests for motor vehicles and their trailers introduced the requirement that motor 
vehicles should undergo periodic roadworthiness tests, identifying the categories of vehicles to 
be  tested,  frequencies,  and  the  items  to  be  tested.  This  Directive  was  replaced  by  Directive 
96/96/EC  which  established  common  requirements  for  periodic  technical  inspections  (PTIs), 
including testing frequencies, inspection methods, and standards for various vehicle categories. 
Directive 2009/40/EC on roadworthiness tests for motor vehicles and their trailers was a recast 
of  the  1996  Directive  and  it  allowed  Member  States  to  apply  higher  requirements  for  PTI 
concerning, notably, the frequency of testing, the items to be inspected, the vehicles covered or 
the minimum standards for braking efficiency.  

Directive 2000/30/EC on the technical roadside inspection of the roadworthiness of commercial 
vehicles complemented Directive 96/96/EC by providing the requirement to control the technical 
state of commercial vehicles in between periodic inspections (roadside inspections).  

Finally, Directive 1999/37/EC on the registration documents for vehicles aimed to harmonise 
the  form  and  content  of  the  registration  certificates  issued  by  Member  States  and  included 
provisions concerning the information to be provided in the registration certificates, the process 
of re-registration of a vehicle previously registered in another Member State and for exchange of 
information and cooperation.  

The 2014 Roadworthiness Package 

The Roadworthiness Package was presented by the Commission in 2012 as a set of three 
legislative proposals.  Given their strong thematic interdependence and the  alignment of 
their specific objectives in the field of road safety, the package approach was considered 
to be more effective than dealing and updating each legislation separately.  

•  Directive  2014/45/EU6  on  periodic  roadworthiness  tests  (hereinafter  the 
"Periodic  Technical  Inspection  or  PTI  Directive")  requires  that  road  transport 
vehicles  are  periodically  tested  to  ensure  compliance  with  a  set  of  minimum 
requirements and it applies to all cars, vans, trucks and buses, heavy trailers, faster 
tractors as well as, since January 2022, to larger two- and three-wheel vehicles and 
quadricycles.  

•  Directive  2014/47/EU7  on  technical  roadside  inspections  (hereinafter  the 
“Technical  Roadside  Inspection  or  RSI  Directive)  has  a  similar  aim  to  PTI 
Directive,  although  in  relation  to  roadside  inspections  of  heavy  passenger  and 
freight vehicles and their trailers.  

•  Directive 2014/46/EU8 on the registration documents for vehicles (hereinafter 
the  "Vehicle  Registration  Documents  or  VRD  Directive")  provides  for  the 

6 It repeals Directive 2009/40/EC; EUR-Lex - 32014L0045 - EN - EUR-Lex (europa.eu) 
7 It repeals Directive 2000/30/EC; EUR-Lex - 32014L0047 - EN - EUR-Lex (europa.eu) 
8 It amends Directive 1999/37/EC; EUR-Lex - 32014L0046 - EN - EUR-Lex (europa.eu) 

2 

 
 
 
 
electronic recording of data on all vehicles registered on a Member State’s territory, 
and harmonised procedures in relation to the suspension of a vehicle’s registration. 

A more detailed explanation of the provisions of the RWP Directives is provided in Annex 
VI. 

The  Roadworthiness  Package  was  intended  to  act  complementarily  to  the  safety  and 
environmental requirements that vehicles must meet to be able to circulate on the EU roads 
i.e., the respective EU type approval Regulations9 for motor vehicles. These Regulations 
also set out the market surveillance requirements for motor vehicles. The focus of the RWP 
is,  however,  different.  EU  market  surveillance  rules  for  motor  vehicles  establish 
procedures  to  test  vehicles  against  type-approval  requirements  with  the  aim  to  identify 
vehicles  (and  vehicles  components)  systematic  deficiencies  through  random  checks, 
creating in this way a feed-back loop for improving type-approval legislation. The RWP 
legislation  in  force  rely  instead  on  regular  vehicles  checks  that  focus  on  ensuring  that 
minimum standards are maintained by owners throughout the lifetime of the vehicle.  

The  Commission  Implementing  Regulation  (EU)  2019/62110,  adopted  as  part  of  the 
roadworthiness acquis, concerns the technical information necessary for roadworthiness 
testing  of  the  items  to  be  tested,  on  the  use  of  the  recommended  test  methods,  and 
establishing detailed rules concerning the data format and the procedures for accessing the 
relevant technical information. Its main objective is to facilitate roadworthiness testing by 
requiring  manufacturers  to  make  the  relevant  technical  information  available  to  testing 
centres and competent authorities. Although this Implementing Regulation applies since 
May 2020, it appears to have only been used to a limited extent. In fact, Member States 
and  vehicle  inspection  bodies  have  reported  difficulties  in  collecting  the  necessary 
information from each manufacturer due to cumbersome registration processes as well as 
costs. As a result, some checks have not been performed as legally required. 

While  this  Implementing  Regulation  does  not  contain  any  reporting  obligations  for 
Member  States,  the  latter  have  repeatedly  indicated  difficulties  to  the  Commission  in 
effectively enforcing road safety measures in EU cross-border traffic and vehicle trade. 
These mostly have their origin in difficulties for competent authorities in accessing vehicle 
register  data  and  other  safety-relevant  information  of  vehicles,  notably  if  these  are 
registered in another Member State. These difficulties also, for instance, may negatively 
impact upon attempts to combat odometer tampering which negatively affects road safety 
and consumer welfare in the EU.  

The  introduction  of  advanced  vehicle  safety  features  (mandated  by  the  General  Safety 
Regulation11,  from  July  2022  onwards)  and  of  significantly  strengthened  emission 
legislation is challenging the methods of inspecting vehicles Therefore, changes to current 
practices will be needed in future to cope with vehicles becoming technically ever more 

9  https://eur-lex.europa.eu/EN/legal-content/summary/eu-approval-and-market-surveillance-measures-for-
motor-vehicles-and-their-trailers.html 
10 EUR-Lex - 32019R0621 - EN - EUR-Lex (europa.eu) 
11 Regulation (EU) 2019/2144 of the European Parliament and of the Council of 27 November 2019 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; EUR-Lex - 32019R2144 - EN - EUR-Lex (europa.eu) 

3 

 
  
 
complex and emissions standards requiring lifelong monitoring. In that context, accessing 
vehicle data will become even more critical to perform roadworthiness checks.  

Laboratory tests indicated that even vehicles with defective or tampered diesel particulate 
filters  (‘DPF’)  can  pass  the  opacity  test,  without  the  malfunctioning  being  noticed.  An 
alternative to the opacity test would be to count the particles that are emitted using optical 
methods. Such an approach would be able to reliably detect a defective or tampered DPF, 
but a harmonised EU measurement method was lacking. A first step towards harmonised 
particle number (PN) measurement during roadworthiness testing within the EU was made 
with  the  adoption  of  a  specific  Commission  Recommendation12.  These  guidelines  were 
adopted in March 2023 following the introduction of PN measurement by three Member 
States and to achieve a minimum degree of harmonisation in PN measurement methods in 
the 
the  EU.  Member  States  can 
Recommendation into their PTI regimes. The test methods required by the PTI Directive 
as regards exhaust emissions of motor vehicles, notably the opacity testing applicable to 
compression ignition engines, were found not anymore adapted to more recent vehicles 
equipped with particle filters.  

the  requirements  set 

therefore 

integrate 

in 

1.2  Purpose and scope of the evaluation  

The  evaluation  of  the  Roadworthiness  Package aims  to  assess  the  performance  of  the 
substantive provisions of the three Directives, to  analyse if the framework is  consistent 
with relevant safety, environmental and internal market objectives and to determine if it is 
still fit for purpose.  

Both the PTI and the RSI Directives contain a reporting requirement for the Commission 
on the implementation and effects of the Directives. Member States reporting obligations 
are only foreseen in the RSI Directive. However, these Directives have only applied since 
2018,  and  in  order  to  generate  data  to  draw  meaningful  conclusions,  in  particular  their 
effect in terms of improvement of road safety, it was considered that a reasonable period 
of time should have elapsed. The Commission has therefore prepared reports providing an 
overview of the implementation actions of the Member States based on the preliminary 
findings of the transposition control13  

This evaluation covers all EU Member States and is based on evidence available for the 
period  between  2018  and  202114.  The  evaluation  addresses  the  five  evaluation  criteria: 
effectiveness,  efficiency,  coherence,  relevance,  and  EU  added  value,  for  each  of  which 
dedicated evaluation questions were defined. The evaluation systematically reviews and 
analyses all available evidence, from a variety of sources. The evaluation was developed 
with  the  support  of  an  external  support  study15  and  in  line  with  the  Better  Regulation 
Guidelines  and  Toolbox.  The  methodology  is  detailed  in  Annex  II,  while  Annex  III 
presents the evaluation matrix which was elaborated to answer the evaluation questions. 

12 Commission Recommendation (EU) 2023/688 of 20 March 2023 on particle number measurement for the 
periodic technical inspection of vehicles equipped with compression ignition engines 
13 COM (2020) 699 final and COM (2020) 107 final 
14 Data on implementation for 2022 are not complete yet. 
15 The evaluation support study was prepared in 2022-2023 by a consortium led by VVA and including TML, 
TNO, VUFO and the University of Leeds. The study will be published alongside this evaluation. 

4 

 
 
1.3  Evaluation methodology 

Against  this  background,  the  Commission  has  carried  out  the  evaluation  of  the  three 
Directives. In line with the Better Regulation Guidelines, this evaluation analyses: 

-  Effectiveness: assesses the extent to which the three Directives triggered the actual 
changes,  in  particular  in  view  of  original  objectives  of  improving  road  safety, 
contributing to the reduction of the emissions of GHG and air pollutants from road 
transport,  and  facilitating  free  movement  for  EU  citizens  and  the  smooth 
functioning of the Internal Market.  

-  Efficiency:  assesses  the  actual  costs  relative  to  the  actual  benefits  of  the 
implementation of the three Directives, whether there is potential for simplification 
and increasing cost-efficiency.  

-  Coherence of the regulatory framework of the three Directives, regarding both the 
internal coherence and the external coherence with other relevant EU legislation 
and policies. 

-  Relevance: assesses whether the overall problem analysis and related objectives 
are  still  adequate  and  how  the  policy  context  has  evolved.  It  also  analyses  the 
relevance  of  the  Directives  for  current  and  future  needs,  in  light  of  the 
technological, environmental, and scientific advances.  

-  EU  added  value:  assesses  the  value  of  the  three  Directives,  for  citizens  and 
businesses,  compared  to  what  could  have  been  achieved  by  Member  States  at 
national and/or regional and international level without these Directives.  

The following sources of information were used for this evaluation:  

• 

Information  from  stakeholder  consultation  activities  which  included  an  online 
public consultation, targeted surveys, and interviews;  

•  A  review  of  existing  literature  on  the  effects  of  technical  inspections  and  their 
correlation with the evolution of the number of road crashes, as well as on emission 
control technologies and tampering practices; and  

•  European Commission’s CARE Database, Member States’ reports from roadside 

inspections. 

2  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1  Description of the intervention and its objectives 

In 2010 the European Commission adopted policy orientations on road safety16, where it 
proposed  amongst  other 
for  safer  vehicles: 
harmonisation/strengthening  of EU legislation on  roadworthiness  tests  and on technical 
roadside inspections to help reaching the announced road safety target (i.e. reducing the 
number of road fatalities by 50% between 2010 and 2020). The 2012 Commission proposal 
built  on  requirements  included  in  the  previous  Directives  related  to  the  roadworthiness 

two-pronged  strategy 

things  a 

16 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. 

5 

 
  
 
tests,  roadside  inspections,  and  rules  on  the  registration  documents  of  vehicles  (briefly 
introduced in section 1.1).  

The EU regime in place before the adoption in 2014 of the RWP set minimum standards 
for roadworthiness testing across the EU. Before a vehicle was allowed to be put on the 
market,  it  had  to  fulfil  all  the  relevant  type  or  individual  approval  requirements 
guaranteeing an optimal level of safety and environmental standards. Every Member State 
had the obligation to register for the first time any vehicle that had EU type-approval on 
the basis of a “Certificate of Conformity” issued by the vehicle manufacturer. Registration 
of a vehicle provided administrative authorisation for a vehicle's’ entry into road traffic. 
Registered vehicles had to be regularly submitted to periodic roadworthiness tests, aiming 
to ensure that they remain roadworthy. 

According to the impact assessment17, the Commission's 2012 legislative proposals aimed 
to tackle the problem of too many vehicles with technical defects still present on EU roads, 
despite the existing legal framework. The immediate consequences of this problem were 
accidents, injuries, fatalities, as well as environmental damage, in particular air pollution. 
Two main underlying problem drivers were identified: (i) the scope of EU legislation was 
too  narrow  and  the  level  of  requirements  it  sets  were  too  low;  and  (ii)  the  relevant 
information and data were not exchanged between the concerned actors.  

In this context, the RWP aimed to contribute: (1) to increased road safety (halving fatalities 
by  2030  and  moving  to  zero  fatalities  by  2050)  by  increasing  the  quality  and  better 
coordinating  national  PTI  and  roadside  inspection  systems  and  (2)  to  the  reduction  of 
greenhouse  gas  and  air  pollutant  emissions  from  road  transport  by  detecting  more 
effectively  and removing from  circulation  vehicles which are over-polluting because of 
technical defects.  

The impact assessment identified the following two specific objectives: 

(1) 

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

(2)  Create the appropriate framework for a seamless flow of information between 

actors and Member States involved in the enforcement of PTI results. 

While not specifically stated in the impact assessment, the revision also had the objective 
of facilitating the free movement of EU citizens and the smooth functioning of the internal 
market, by including explicit references to free movement in recitals 1, 3, and 8 of VRD 
Directive, and in recital 24 and Article 10 of PTI Directive. With the increase in cross-
border  vehicle  movements  within  the  EU,  there  was  a  need  for  more  harmonised  and 
rigorous roadworthiness standards to ensure that vehicles moving across borders met the 
same safety criteria. The RWP intended to create a common and harmonised framework 
for  roadworthiness  control,  including  common  requirements  for  technical  checks, 
equipment, knowledge and training of inspectors and cooperation between Member States. 
It also aimed at reducing the administrative burden through general data exchange (based 
on  collaboration  among  national  contact  points  (NCP)  and  mutual  recognition  of 
roadworthiness certificates (RWCs).  

To  meet  the  objective  to  enhance  the  safety  of  vehicles  on  the  road,  the  minimum  EU 
standards  for  periodic  roadworthiness  tests  (PTI)  were  strengthened  and  mandatory 
standards were introduced, together with the introduction of random roadside inspections 

17 Register of Commission Documents - SWD(2012)206 (europa.eu) 

6 

 
 
(RSI). This  was  seen  as  essential to  avoid  reducing  the effectiveness  of roadworthiness 
enforcement.  To  meet  the  objective  of  making  the  necessary  data  for  and  from 
roadworthiness  testing  available,  the  PTI  Directive  also  encourages  cooperation  and 
information exchange among Member States including records of roadworthiness tests.  

In several Member states a high number of private authorised test centres were carrying 
out  roadworthiness  tests (and still do). To ensure a coherent  approach, certain  common 
procedures such as frequency of testing were specified in the legislation. 

In contrast to the PTI and RSI Directives, there was a limited number of changes made to 
the  1999  Vehicle  Registration  Documents  Directive  in  Directive  2014/46/EU,  perhaps 
reflecting  the  fact  that  this  Directive  has  a  relatively  limited  scope,  given  that  vehicle 
registration itself is a responsibility of Member States. The main changes introduced in 
Directive 2014/46/EU were (i) providing for electronic recording of data on all vehicles 
registered on a Member State’s territory, and (ii) harmonised procedures in relation to the 
suspension of a vehicle’s registration. 

The expected result from the revision of the three Directives was more detection of defects 
and  reduction  of  the  number  of  “gross  emitting”  vehicles  and  vehicles  with  dangerous 
defects  in  circulation.  Also,  overall  consistency,  objectivity,  and  quality  of  the  testing 
throughout the EU was expected to be improved, as well as the framework for exchange 
of information between actors and Member States involved in the enforcement of testing 
results. 

A  figure  representing  the  intervention  logic  of  the  RWP  is  presented  in  Annex  VI.  It 
summarises the links and causal relationships between the problems and needs. It takes 
into  consideration  the  general  and  specific  operational  objectives  that  the  legislative 
framework was designed to address and presents the expected outputs, results, and impacts. 

Directive 2014/45/EU on the periodic roadworthiness tests compared to its predecessor, 
Directive 2009/40/EC:  

•  Addressed the quality of vehicle tests by setting common minimum standards for 

equipment, training of inspectors and assessment of deficiencies. 

•  Made  electronic  safety  components  (such  as  anti-lock  braking  system  (ABS), 

electronic stability control (ESC) and airbag) subject to mandatory testing. 
Introduced measures to combat odometer fraud. 

• 
•  Made  compulsory  EU  wide  testing  for  heavy  motorbikes,  with  a  possibility  for 
Member States to introduce effective alternative road safety measures instead.  
•  Foresaw compulsory EU wide testing of high-speed tractors used for commercial 

road haulage purposes;  

•  Provided  for  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. 

Directive  2014/47/EU  on  the  technical  roadside  inspection  of  commercial  vehicles 
compared to its predecessor, Directive 2000/30/EC:  

•  Addressed the quality of vehicle tests by setting common minimum standards for 
equipment,  training  of  inspectors  carrying  out  more  detailed  inspections,  the 
assessment and follow-up of deficiencies; 

•  Extended the risk rating system of road transport undertakings, with information 

based on the technical roadside inspection;  

7 

 
•  Relied on a two-step approach for the roadside inspections by introducing the initial 

and more detailed inspection;  
Introduced measures for the inspection of cargo securing;  

• 
•  Added  compulsory  EU  wide  testing  of  high-speed  tractors  used  for  commercial 

road haulage purposes. 

Directive  2014/46/EU  on  vehicle  registration  documents  introduced  the  following  new 
requirements compared to its predecessor, Council Directive 1999/37/EC: 

•  An  obligation  for  Member  States  to  record  electronically  data  on  all  vehicles 

registered on their territory; 

•  An  obligation  for  Member  States  to  record  electronically  the  suspension  of  a 
vehicle’s authorisation after a failed PTI, and to notify it to the vehicle registration 
authority.  This  suspension  is  effective  until  the  vehicle  has  passed  a  new 
roadworthiness  test.  Upon  successful  completion  of  the  roadworthiness  test,  the 
competent authority has to re-authorise the use of the vehicle in road traffic without 
delay, and with no need of new registration; 

•  An obligation for Member States to assist each other in the implementation of the 
Directive,  in  particular  to  check,  before  any  re-registration  of  a  vehicle,  the 
vehicle's legal status in the Member State in which it was previously registered. 
Such checking may involve the use of data from national databases to facilitate the 
exchange of information.  

There are some significant differences between what the Commission originally proposed 
in  2012,  and  the  measures  included  in  the  legal  text  of  2014  Directives.  Some  of  the 
measures originally proposed in the Commission’s 2012 proposals were not included in 
the final legal texts (see Tables 1 to 3 below). It should also be noted that the Commission 
originally  proposed  Regulations  for PTI and RSI, whereas the final legal texts  took the 
form  of  Directives.  In  addition,  the  Commission’s  proposals  would  have  applied  from 
2015, whereas the final agreed texts applied from 2018. 

8 

 
 
Table 1. PTI: Comparison between COM’s proposal in 2012 and adopted directive of 2014 

Table 2. RSI: Comparison between proposal of 2012 and adopted directive of 2014 

9 

Topic  Vehicle Category  Commission Proposal of 2012 for a Regulation  Adopted Directive of 2014  Test intervals  M1 (passenger car) and N1 (light truck)  Initial test after 4 years, next after a further 2 years, then annually  Initial test after 4 years, then every 2 years  O2 (trailer 0.75 to 3.5 tonnes)  Initial test after 4 years, next after a further 2 years, then annually  Omitted  L1e, L2e, L3e, L4e, L5e (two- and three-wheeled vehicles, i.e. motorcycles), L6e and L7e (quadricycles)  Initial test after 4 years, next after a further 2 years, then annually  L1e and L2e omitted  L6e (light quadricycles) omitted  L3e, L4e, L5e and L7e (motorcycles above 125cc and heavy quadricycles) to be included from 1 Jan 2022 with the Member States deciding the test frequency and with the possibility of exemption for Member States adopting effective alternative measures  M2 (minibus), M3 (bus), N2 (medium truck), N3 (heavy truck), T5 (agricultural vehicle with a maximum design speed of  more than 40 km/h), O2 and O3 (trailers over 3.5 tonnes)  Initial test after 1 year, then annually  As proposed, except that first test for T5 category to be after 4 years with subsequent tests every 2 years  Major deficiencies    Retest within no more than 6 weeks  Retest within no more than 2 months  Dangerous deficiencies    Requirement of withdrawal of vehicle registration until rectification  The Member State or the competent authority may decide that the vehicle in question is not to be used on public roads and that the authorisation for its use in road traffic is to be suspended for a limited period of time, without requiring a new process of registration   Topic Commission Proposal of 2012 for a Regulation  Adopted Directive of 2014 Vehicle categories included Light commercial vehicles (category N1) and their trailers (categories O1 and O2) to be included No requirement to include light vehicles and their trailers. Only buses and coaches (categories M2 and M3), trucks (N2 and N3) and trailers of over 3.5 tonnes (O3 and O4), as well as tractors used for commercial road haulage and capable of over 40 km/h (T5) are included. High-risk profile Inspectors shall select as a priority vehicles operated by undertakings with a high-risk profile optional   
 
 
Table 3. VRD: Differences between proposal of 2012 and adopted directive of 2014 

It is reasonable to assume that if all of the Commission’s proposals had been included in 
the  final  texts,  then  this  would  have  led  to  fewer  dangerous/defective  vehicles  in 
circulation, and hence fewer accidents and fatalities. This can be assumed particularly in 
relation to the Commission’s proposals for (i) the earlier proposed date of application of 
the measures, (ii) the wider scope of vehicles to be tested at PTI and RSI, (iii) more frequent 
PTI testing of older vehicles, and (iv) the greater repercussions for a vehicle failing at PTI 
or RSI. 

2.2  Points of comparison  

Before  the  adoption  of  the  Roadworthiness  Package  in  2014,  the  requirements  of  EU 
legislation in this area were set below what was perceived as an adequate scope; moreover, 
most  Member  States  have  had  set  national  requirements  for  several  elements  of  the 
roadworthiness system at a level, which was higher than required by EU legislation. This 
led  to  a  heterogenous  transposition  of  the  PTI  Directive  2009/40/EC  (predecessor  of 
Directive  2014/45/EU) into national  legislations. For example,  because of this  situation 
Member States often refused to recognise the certificates for roadworthiness tests issued 
by  other  Member  States  for  re-registration  purposes  and  required  a  new  test  to  be 
performed according to national rules.  

Also, information and data vital for the effectiveness of testing and enforcement of test 
results  was  not  exchanged  between  concerned  actors  even  if,  during  PTI  and  roadside 
inspections, an important amount of data on the vehicle and its performance was collected. 
This data could be used by the different authorities to ensure the follow up of the detection 
of  defects,  to  organise  targeted  checks,  but  also  to  improve  the  policy  measures  in  this 
domain. For PTI and roadside inspections, enforcement authorities did not have access to 
information on the history of the vehicle and its technical characteristics, even if data was 
available in the national registers. Lack of provisions in EU legislation about the exchange 
of PTI-relevant data did not allow the effective flow of data to and from PTI centres and 
enforcement authorities. 

Without  further  intervention  at  EU  level,  the  implementation  of  the  policy  measures  in 
Member  States  would  have  continued  to  diverge  with  a  possible  negative  impact  on 
roadworthiness, and consequently road safety and environment. Overall, it was expected 
that the downwards trend in fatalities would be maintained, while the share of accidents 
caused by technical defects would likely rise. On the environment side, GHG emissions 
were expected to reduce due to the gradual withdrawal of older vehicles. But this has been 

10 

Topic  Commission Proposal of 2012 for a Regulation  Adopted Directive of 2014  Registration withdrawal in case of dangereous deficiencies   The original proposal stated that: “In cases where dangerous deficiencies have been found during a roadworthiness test, the registration should be withdrawn by the competent authorities until the vehicle has passed a new roadworthiness test.” “In cases where dangerous deficiencies have been found during a roadworthiness test and the authorisation of a vehicle for use on public roads has been suspended, that suspension should be recorded until the vehicle has passed a new roadworthiness test.” Therefore according to the final version, full re-registration would not be required   
 
more than compensated by increasing  transport activity  (and an  increase in  the average 
mass of vehicles). However, the impact on air pollution would have become proportionally 
higher. It was also expected that the number of cross-border re-registrations of vehicles in 
the EU would increase up to 2050, which would increase the magnitude of the problems 
related to the absence of exchange of data between the authorities and the testing centres 
in different Member States. 

2.2.1  Road safety points of comparison  

In 2011, at the beginning of the period over which the EU aimed to halve road deaths, there 
were  28,750  fatalities  on  the  roads  of  the  EU27.  By  2022,  that  number  was  20,640, 
equivalent of a 28.2% reduction on the 2011 figure (and a 14.8% reduction on the 2013 
figure of 24,230). The 2014 Roadworthiness Package was one of a series of actions at EU 
level intended to help deliver the targeted reduction. The Impact Assessment for the RWP 
estimated that it would lead to a yearly reduction of 38,447 in the number of accidents and 
allow avoiding 1,282 fatalities per year. The measure with the greatest expected effect was 
more  frequent  testing  of  older  vehicles  (not  included  in  the  final  agreed  text  of  the 
Directive).  Performance  testing  of  electronic  safety  systems  was  expected  to  have  the 
potential to  save an important  number of additional lives.  The monetised  social benefit 
arising from the reduction in accidents, saving of lives and avoided injuries was estimated 
at  EUR 5,122  million  per year. The reduction in  congestion resulting  from  the reduced 
number of accidents translated into an additional saving of EUR 192.5 million per year.  

Additional road safety benefits but which could not be quantified were identified, such as 
the requirement to make targeted roadside inspections for commercial vehicles, with the 
obviously badly maintained vehicles being inspected in priority. This was expected to have 
a positive impact on the effectiveness of RSI in taking off the roads vehicles with defects. 
Furthermore, positive impact on road safety was also expected by extending RSI to other 
categories  of  vehicles  than  commercial  vehicles  and  setting  a  minimum  target  of  10% 
commercial vehicles undergoing RSI in any given year. Higher training requirements for 
the  inspectors  involved  in  roadworthiness  testing  and  additional  requirements  on  the 
supervision of PTI centres were also expected to bring positive and significant impacts in 
terms of an increased rate of detection of defects during tests. 

The establishment of a data exchange system was expected to bring better enforcement of 
roadworthiness  test  results  by  the  national  authorities.  For  example,  police  forces  and 
roadside  inspectors  would  have  easier  access  to  roadworthiness  related  data  which  are 
needed to detect and fine non-compliant drivers. Finally, the availability of data from the 
Certificate  of  Conformity  and  the  PTI  should  have  improved  the  functioning  of  the  re-
registration process for vehicles originating from another Member State. 

There  is  ample  literature  to  support  the  argument  that  roadworthiness  measures  have  a 
positive  safety  impact.  For  example,  the  cost-benefit  analysis  conducted  in  the 
AUTOFORE project18 calculated that defects in passenger cars would be responsible for 
43,536 injury crashes across 10 Member States in 2010 and that older vehicles would be 
over-represented  in  this  problem.  A  recent  US  study19  concluded  that  states  that  have 
periodic safety inspection regimes had 5.5% fewer traffic fatalities per 100,000 registered 
passenger vehicles over the period from 1980 to 2015 than the US States that did not have 

18 Study part-funded by the European Commission, conducted by a CITA-led consortium, to examine options 
for roadworthiness enforcement, 2007, available at: https://citainsp.org/studies/autofore-2007/ 
19 https://ascelibrary.org/doi/10.1061/JTEPBS.TEENG-7320   

11 

 
 
such regimes. The study also concluded that the relationship was causal – i.e. inspection 
was responsible for those reduced fatalities. It can be observed that this estimated reduction 
of 5.5% is similar in size to the 4.4% reduction expected in the 2012 Impact Assessment, 
even though the former is an estimation for a change from no PTI at all to PTI, whereas 
the latter is a prediction for the outcome of an improvement in the operation of PTI and 
RSI.  

The Impact Assessment observed that those Member States with a poorer performance on 
road  safety  also  tended  to  be  the  ones  with  a  lower  level  of  stringency  in  PTI,  while 
Member  States  with  a  better  performance  in  road  safety  tended  to  exceed  the  then 
minimum standards for PTI. Thus, it concluded that a higher minimum standard would 
improve overall performance in EU road safety.  

Since periodic technical inspections have been in place in the EU for decades for the most 
important vehicle categories, the number of recent studies comparing the before and after 
(or with PTI and without PTI) situation within the EU is limited. What is available relates: 
(a) to the vehicle categories that are only inspected by some of the Member States or for 
which PTI has only been introduced recently (such as mopeds and trailers) (20), or (b) to 
non-EU countries, e.g. differences between US States (21) and the evolution of the situation 
in Costa Rica or Turkey (22).  

2.2.2  Emissions and air pollutant points of comparison 

The positive environmental impact of the 2014 RWP was primarily expected from more 
frequent  testing  of  vehicles  and  extended  scope  of  tested  vehicles,  which  should  have 
allowed a higher detection level of big polluters. It was estimated that this would lead to a 
decrease in the overall yearly CO2 and NOx equivalent emissions of road vehicles in the 
EU by 2%. In absolute terms, this would correspond to approximately 18.2 million tons 
CO2  and  6,979  tons  of  NOx  equivalent  per  year.  These  were  translated  into  annual 
monetary savings of EUR 545 million and EUR 30.7 million respectively. However, these 
estimated emission reductions did not materialise because the measures upon which these 
estimates were based, principally more frequent testing of passenger cars (annually after 6 
years) were not included in the final agreed text of the Directives.  

In  addition,  the testing  of emissions  using on-board diagnostics (OBD)  should ease the 
process and therefore reduce the costs of testing for PTI centres and for the drivers, but 
available evidence did not suggest that it would increase the rate of detection of defects. 
There was also positive environmental impact expected in terms of reduced noise, thanks 
to  removing  vehicles  with  technical  defects  from  circulation,  however  this  was  not 
quantified in the 2012 Impact Assessment. 

(20)  Study on the inclusion of light trailers and two- or three-wheel vehicles in the scope  of the  periodic 

roadworthiness testing, https://citainsp.org/wp-content/uploads/2019/02/LO.pdf  

(21)  https://ascelibrary.org/doi/10.1061/JTEPBS.TEENG-7320 
(22)  Schulz W.H. and Scheler S. (2019), Reducing the Death Toll of Road Accidents in Costa Rica through 
the  Introduction  of  Roadworthiness  Inspections  by 
the  Government,  available  at  SSRN: 
https://ssrn.com/abstract=3420341; Schulz W.H. and Scheler S. (2020), Getting Ready for Europe: An 
Empirical  Assessment  for  the  Introduction  of  Periodical  Technical  Inspections  of  Road  Vehicles  in 
Turkey, available at SSRN: https://ssrn.com/abstract=3523602 

12 

 
 
 
Despite the increase in car transport by 18% and freight transport by 22% from 2000 to 
2019  the  emissions  of  road  transport  have  decreased  substantially23.  Emission  control 
technology  and  type-approval  have  been  effective  in  reducing  the  overall  emissions. 
Hence,  ensuring  that  emission  control  systems  remain  in  a  proper  state  has  become 
increasingly important. Road transport was, and is, a major contributor of nitrogen oxides 
(NOx)  in  the  air,  but  the  continuing  decrease  is  the  result  of  successive  and  effective 
European vehicle emission legislation (see Figure 1 below).  

Figure 1. The continuing reduction of emissions from road transport. 

*Legend: NOx =Nitrogen Oxides ; BC=Black Carbon : CO=Carbon Monoxide  

Source: EEA 

Therefore, as noted in the Commission’s 2012 Impact Assessment, the effect of defects 
will increase in the overall context of decreasing carbon dioxide (CO2) emissions and air 
pollution.  However,  the  1.2%  to  5.7%  increases  in  emissions  estimated  by  the  impact 
assessment in  the  absence of the RWP, due to  lower detection of  technical defects,  are 
conservative  estimates.,  The  common  understanding  of  acceptable  deterioration  of 
emission control technologies, as estimated in type-approval legislation, is much larger. 
Typical increases are 10% to 30% in emissions due to gradual deterioration, notably  of 
catalysts, over the useful life. This is the order of magnitude expected as well for the effect 
of roadworthiness testing on emissions.  

At the time, in 2012, it was highlighted that an unnoticed defect could lead to a twentyfold 
increase in emissions on vehicles. However, the impact on the overall emissions – i.e. 1% 
vehicles  with  a  defect  would  increase  emissions  by  20%  –  could  not  be  factored  in 
properly, as older, less clean vehicles still dominated the total emissions (although not the 
fleet composition). 

The new emission control technologies in vehicles developed since 2010 all have their own 
strengths and weaknesses. In 2008, the first SCR (selective catalytic reduction) systems 
were  used  on  heavy-duty  vehicles,  and  on  light-duty  diesel  vehicles  a  string  of  after-
treatment  technologies  was  introduced,  with  Euro-6  from  2014  onwards.  The  technical 

23 https://www.eea.europa.eu/ims/emissions-of-air-pollutants-from 

13 

 
 
 
 
requirements for inspection, specifically relating to the functioning of the after-treatment 
technologies, did not anticipate the technological advancements. Therefore, the defects of 
these  advanced  technologies  likely  remained  undetected  during  periodical  technical 
inspections and roadside inspection, as neither the technology, nor the possible testing was 
addressed beyond the most generic formulation. In that respect, the RWP relied on the fact 
that  appropriate  servicing  of  a  vehicle  would  find  defects  and  enforce  their  repair.  In 
practice,  without  incentives,  vehicle  owners  would  not  consider  repairs,  which  will  not 
affect  the normal  vehicle usage and  are not legally required. The  increasingly stringent 
type-approval emission requirements on vehicles, both in terms of emission limits and test 
protocols,  had  not  been  integrated  into  the  roadworthiness  requirements.  Without 
addressing  the  specific  problems  with  modern  technologies  in  the  roadworthiness 
legislation, there is no basis to check its functioning. The undetected defects can lead to 
substantial increases in emissions, with a possibly significant impact, even with a small 
fraction of undetected defects.  

The  2014  RWP  did  not  take  into  account  the  rapidly  changing  target,  with  each  next 
generation  of  vehicles  achieving  lower  emissions.  This  has  led  to  a  situation  where 
emission tests became outdated, and the effectiveness of onboard diagnostics (OBD) is not 
currently tested in PTI. The moving target has become more apparent with the scrappage 
of most polluting pre-Euro-1 vehicles, for which the PTI was suitable, which have almost 
completely  been  removed  from  the  road  since  2020,  as  even  the  most  robust  pre-Euro 
vehicles do not last more than 30 years in normal use. Hence, although the 2012 Impact 
Assessment  noted  the  changing  landscape  with  more  complex  and  effective  emission 
control technologies,  it did  not  identify the risk of undetected defects  specific for these 
technologies, and the consequent gap between type approval and roadworthiness emission 
levels.  

2.2.3  Other expected impacts  

In  addition  to  positive  impacts  on  road  safety  and  environment,  the  revised  RWP  also 
introduced  the  requirement  for  PTI  centres  to  report  the  odometer  readings  of  tested 
vehicles.  These  readings  should  be  collected  at  Member  State  level,  thereby  helping  to 
combat  more  effectively  the  mileage  fraud,  which  was  distorting  the  second-hand  car 
market.  The  effects  were  expected  to  be  positive  and  significant,  but  not  assessed  in 
quantitative  terms.  Furthermore,  the  establishment  of  a  system  for  data  exchange  was 
expected  to  reduce  the  administrative  costs  of  complying  with  the  PTI  requirement  for 
vehicle  owners  and  reduce  the  administrative  procedures  for  authorities  and  PTI  test 
stations. This was expected to be achieved through a replacement of manual procedures 
with electronic data input and exchange.  

3  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

This section explains the state of play in implementing the Directive and presents what has 
happened over the evaluation period in relation to the objectives of the 2014 RWP.  

3.1  State  of  play  –  transposition  and  implementation  of  the  Roadworthiness 

Package 

All three RWP Directives stipulated that Member States must transpose the measures by 
20 May 2017, and that the Directives apply from 20 May 2018, though some provisions 
envisaged phased application.  

14 

 
The Commission has concluded its compliance assessment of the three Directives, based 
on  information  submitted  by  Member  States.  This  compliance  check  indicates  that  no 
Member State has correctly and completely transposed and communicated every provision 
of  all  three  Directives.  Given  that  Member  States  had  until  2017  to  notify  their 
transpositions,  it  is  likely  that  in  some  instances,  Member  States  have  modified  their 
legislation  since  2017  to  comply  more  fully  with  the  Directives.  Therefore,  the 
Commission  is  currently liaising with  the Member States to seek clarification on every 
item that does not appear to have been correctly transposed or communicated. 

However, it should be noted that the Commission has not been made aware of any systemic 
failure of any Member State to transpose the provisions of the RWP.  

In relation to the PTI Directive, the information gathered during the evaluation indicated 
that  most  Member  States  have  adopted  at  least  the  minimum  requirements  for  vehicle 
testing  frequency,  with  some  even  introducing  more  frequent  checks,  particularly  for 
passenger cars and light commercial vehicles. For example, the PTI Directive requires that 
passenger cars are subject to a PTI test at the latest 4 years after the first year of registration, 
and  thereafter  at  least  every  two  years  (i.e.,  a  regime  of  4-2-2-2-  etc.).  About  half  the 
Member  States  apply  such  a  regime,  while  the  other  half  have  a  stricter  regime.  For 
example, Croatia and Latvia require that a PTI be conducted for passenger cars after two 
years  and  annually  thereafter;  Germany  and  Lithuania  require  a  PTI  to  be  conducted  3 
years  after first  registration  and every two  years  thereafter, while Austria, Bulgaria and 
Poland require the first  PTI to be conducted after 3 years after, then after a further two 
years, and annually thereafter. Table 4 presents an overview of the frequency of PTI in EU 
Member States. 

Table  4.  Frequency  of  PTIs  by  Member  State,  for  passenger  cars  (unless  otherwise 
indicated) 
Country 
Austria 

Conducted by 
A 

Conducted by 
B 

Frequency 
4-2-2-2-1-1 

Frequency 
3-2-1-1- 

Country 
Ireland 

Belgium 

4-1-1-1- 

Bulgaria 

3-2-1-1- 

Cyprus 

4-2-2-2- 

Czechia 

4-2-2-2- 

Germany 

3-2-2-2- 

Denmark 

4-2-2-2- 

B 

B 

B 

B 

Italy 

4-2-2-2- 

Lithuania 

3-2-2-2 

Luxembourg 

4-2-1-1- 

D 

B 

B 

Latvia 

2-2-1-1- 
or 
motorcycles: 2-2-
2-2- 

B & C & D 

Malta 

4-2-2-2- 

The 
Netherlands 

Petrol/electric  4-
2-2-1-1 
diesel/other  3-1-
1-1 

B 

A 

B 

B 

Estonia 

4-2-2-2-1 

B 

Poland 

3-2-1-1- 

Greece 

4-2-2-2- 

B & D 

Portugal 

4-2-2-1- 

Spain 

4-2-2-2-1- 

B & D 

Romania 

3-2-2-2-2-1- 

B & D 

Finland 

4-2-2-2-1- 

B 

Sweden 

3 years – 2 years 
– 14 months – 14 

B 

15 

 
 
 
months 
months 

– 

14 

France 

4-2-2-2- 

Croatia 

2-1-1-1- 

B 

B 

Slovenia 

4-2-2-1- 

Slovakia 

4-2-2-2- 

B 

B 

Hungary 

4-2-2-2- 

B & D 

A: Commercial garages: commercial garages that are also allowed to carry out repairs 
B: Private inspection centres: privately owned vehicle inspection centres 
C: Central Licencing Authority: the central licencing authority in the country 
D: Public inspection centres: governmental owned vehicle inspection centres 

The content and method of these tests  are generally harmonised across  Member States, 
adhering to a minimum list of required items. In cases where major deficiencies are found 
during roadworthiness tests, most Member States stipulate a one to two-month period for 
a follow-up test. All Member States have instituted minimum competence requirements 
for PTI inspectors, including routine training and sometimes requalification exams with a 
given frequency.  

Regarding the extension of the scope by the 2014  revision, the inclusion of  high-speed 
tractors (with  design  speed over 40 km/h)  and two- and  three-wheel vehicles appear to 
have  posed  a  problem  for  some  Member  States.  I  In  relation  to  the  vehicle  categories 
already covered by the PTI Directive, only minor discrepancies have been found.  

It seems that agricultural vehicles are in general not registered in some Member States24, 
which  made  the  introduction  of  periodic  testing  for  these  vehicles  challenging.  The 
periodic testing of two- and three- wheeled vehicles was due from 1 January 2022, though 
many  Member  States  were  late  with  the  adoption  and  notification  of  the  transposing 
national measures. The broad and imprecise definition of “alternative measures” in Article 
2(2) of the PTI Directive, which is open to interpretation by Member States25, was also an 
issue.  

Concerning the measures related to the mutual recognition of roadworthiness certificates 
in the case of re-registration of a vehicle already registered in another Member State, in 
the majority of the Member States the transposition has been satisfactory. Most Member 
States made use of the optional measure to verify, in cases of doubt, the validity of the 
roadworthiness certificate.  

Regarding odometer fraud, the 2020 report on the implementation of the PTI Directive26 
showed  that  the  measures  requiring  Member  States  to  ensure  that  the  odometer  data 
recorded at the previous roadworthiness test was made available during the next inspection, 
have  been  transposed  without  major  problems.  However  as  regards  the  obligation  to 
introduce  effective  and  dissuasive  penalties  when  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.  

24 Note: In the absence of EU legislation, it is a national competence to decide which vehicles are registered 
and consequently issued a vehicle registration document and licence plate(s).  
25  Some  Member  States  take  it  to  mean  improved  road  infrastructure,  others  take  it  to  mean  roadside 
inspections for motorcycles.   
26 COM (2020) 699 final 

16 

 
 
 
 
 
In relation to the VRD Directive, the evaluation found that national legislation in most 
Member States mandates the electronic record-keeping of all registered vehicles, including 
the results of periodic roadworthiness tests and their validity periods. In all Member States, 
a  vehicle's  suspension  is  automatically  lifted  once  the  identified  deficiencies  have  been 
rectified and the vehicle successfully passes a new test.  

In  relation  to  the  RSI  Directive,  the  information  gathered  indicates  that  roadside 
inspections for commercial vehicles are carried out in varying numbers by Member States, 
. The selection of vehicles for initial roadside inspections can be based on the risk profile 
of  the  transport  undertaking,  although  random  selection  is  implemented  in  several 
countries.  The  method  of  selection  i.e.,  random  versus  targeted,  naturally  has  a  very 
significant effect on RSI failure rates. In all Member States, if a vehicle is found with major 
or dangerous deficiencies during an inspection, its use is restricted. In the case of dangerous 
deficiencies, which require immediate rectification, the vehicle may only be driven to the 
nearest workshop for repair, provided that immediate risks to the vehicle's occupants or 
other road users have been mitigated. According to the 2020 report on the implementation 
of  the  RSI  Directive27,  the  inclusion  of  high-speed  tractors  was  challenging  for  some 
Member  States.  The  report  also  indicated  possible  problems  in  several  Member  States 
concerning the extension of the risk rating system with the information stemming from the 
technical roadside inspections. On the other hand, the majority of the Member States have 
introduced the optional measures of the Directive concerning the selection of vehicles. The 
two-stage  approach  to  inspecting,  i.e.,  the  introduction  of  the  separate  initial  and  more 
detailed technical  roadside inspections proved challenging  in  practice.  It  seems  that the 
clear separation of the two stages has not been introduced in some Member States, which 
may raise further questions such as regarding the data collection, the reports of the more 
detailed roadside inspections, or the training of inspectors. Also, the new obligation on the 
collection of different sets of information after initial and more detailed inspections seems 
to have been challenging for some Member States. Only a few Member States appear to 
have introduced the optional measures to require the payment of a fee linked to carrying 
out the inspection where defects have been found during the more detailed inspection.  

During this evaluation, the Commission contacted Member States to assess the extent to 
which  Member  States  had  exceeded  the  minimum  requirements  in  the  Directives.  The 
responses indicated that some Member States have exceeded the minimum requirements 
set out in the Directives, including, but not limited to, the scope of vehicles to be subject 
to PTI and RSI, and the frequency of PTIs (please see Annex VIII for more details).  

In addition, Commission Delegated Directive 2021/171628 amended the RSI Directive as 
regards modifications to the vehicle category designations stemming from amendments to 
the type-approval legislation. Commission Delegated Directive 2021/171729 amended PTI 
Directive as regards the updating of certain vehicle category designations and the addition 
of  eCall  to  the  list  of  test  items.  For  both  Delegated  Directives,  the  most  common 
transposition issues have been the non-communication of the transposition measures, and 
the absence of a reference to the Directives in the national measures. 

27 COM (2020) 676 final 
28 EUR-Lex - 32021L1716 - EN - EUR-Lex (europa.eu) 
29 EUR-Lex - 32021L1717 - EN - EUR-Lex (europa.eu) 

17 

 
 
The  European  implementation  assessment  of  the  European  Parliamentary  Research 
Service (EPRS), from 202030 indicated that the transposition of the RWP at national level 
has led to improved harmonisation of procedures, such as the frequency and content of 
vehicle testing, and the provisions of the RWP Directives have enhanced the quality of 
periodical technical inspections and roadside inspections, as well as road safety standards. 
The  report  indicates  that  it  is  too  early  to  analyse  the  effectiveness,  the  efficiency,  the 
relevance, and the EU added value of the package, but the coherence has been analysed. 
The  report  found  that  the  RWP  measures  are  coherent  with  the  general  objective  of 
contributing to the achievement of the road safety targets in the 2011 White Paper. The 
report points to a number of measures in this is regard, in particular the introduction of 
common standards for testing centres, training of inspectors, as well as the provisions on 
scope,  frequency  and  the  methods  for  vehicle  testing.  The  report  also  notes  that  some 
Member  States  have  gone  beyond  the  minimum  requirements  in  relation  to  scope  and 
frequency  of  testing,  and  that  this  helps  to  reduce  the  number  of  unsafe  vehicles  in 
circulation. 

On the information exchange between Member States, the EPRS report found that 7 of the 
21 Member States consulted, had issues in contacting National Contact Points to verify the 
roadworthiness  certificate,  and  6  Member  States  on  the  time  required  to  obtain  the 
document. 12 authorities reported that there is no fixed time limit to keep information in 
the database. Furthermore, all the Member States notify the competent authority of the data 
collected during vehicle testing, including the odometer readings. 

On coherence, the Parliament report only pointed at one potential issue between Directive 
2014/45  and  Directive  2014/46,  referring  to  the  notification  and  registration  of  the 
roadworthiness  certificate.  Directive 2014/45  requires  the competent authority  to  notify 
the  content  of  the  roadworthiness  certificate,  but  Directive  2014/46  only  refers  to  the 
outcome  of  the  test,  and  the  validity  of  the  roadworthiness  certificate.  The  report  also 
pointed that no stakeholders interviewed have raised any internal coherence issue.  

3.2  Market developments 

Regarding the objective of improving road safety, one of the measures which was expected 
to have the greatest effect was more frequent testing of older vehicles, which tend to have 
more defects. A study from Spain31 showed that both passenger cars and light commercial 
vehicles have increasing failure rates in PTI as they age, with vehicles over 10 years old 
experiencing  particularly  high  rates.  This  was  reflected  in  the  crash  data,  where  older 
vehicles  were  more  prevalent,  often  due  to  issues  such  as  defective  tyres,  steering,  and 
brakes. Consequently, addressing this group of vehicles with targeted measures under the 
RWP was expected to bring greater benefits in terms of lives saved and injuries avoided. 
This  is  relevant  since  the  vehicle  fleet  in  the  EU  has  been  progressively  aging.  The 
proportion of passenger cars aged over ten years increased by 13% from 2016 to 202132. 

30  Implementation  of  the  roadworthiness  package:  European  implementation  assessment  |  Think  Tank  | 
European Parliament (europa.eu) 
31  Diaz  Lopez  et  al.,  2018,  https://www.aeca-itv.com/wp-content/contribucion-itv-seguridad-vial-medio-
ambiente/eng/files/assets/common/downloads/ROADWORTHINESS%20TESTING%20CONTRIBUTIO
N%20TO%20VEHICLE%20SAFETY%20AND%20ENVIRONMENT.pdf?uni=8643c3a2724634911b854
c6080952f96. 
32 ACEA Annual report; Evaluation support study (VVA) 

18 

 
 
Increases  also  occurred  for  light  commercial  vehicles  (7%)  and  for  medium  and  heavy 
commercial vehicles (11.8%). See Figure 2. 

Figure 2. Proportion of registered vehicles in the EU27 aged over 10 years. 

* Legend: LCV = light commercial vehicles; MHCV = medium and heavy commercial vehicles 
** Note: buses were nor included as a separate category before 2018 
Source: ACEA, 2023 

In parallel, the average age of the vehicle fleet increased: the average age of passenger cars 
in the EU was 10.7 years in 2016, and by the beginning of 2022 it had risen to 12.0 years.33 
It could be expected that the problem of vehicle defects — minor, major and dangerous — 
would worsen over time, since it has been established that the incidence of such defects 
increases with vehicle age.34  

The  introduction  of  advanced  vehicle  safety  features  mandated  by  the  General  Safety 
Regulation, (EU) 2019/2144 from July 202235 onwards and of significantly strengthened 
emission legislation has led to vehicles in the EU becoming technically ever more complex. 
The  Regulation  mandates  the  inclusion  of  safety  features  such  as  intelligent  speed 
assistance, driver drowsiness and attention warning systems, amongst others, in new motor 
vehicles. Advanced Driver Assistance Systems (ADAS) will gradually become standard 
in  all  vehicles  and  road  safety  will  be  increasingly  dependent  on  ensuring  the  correct 
functioning of the technologies that assist drivers in performing their driving tasks. These 
electronic safety and driver assistance systems are not being tested in the current PTI.  

To keep pace with this trend, adaptations in the methods of inspecting vehicles throughout 
their lifetime are necessary. These may require fundamentally new approaches in the field 
of vehicle testing, taking into account ongoing developments in vehicle automation. Visual 
and mechanical vehicle inspections, which are still the predominant modes to date, may 

33 Note that the 2016 calculation included the UK, but the 2022 one did not. The ACEA data combines the 
registration years for vehicles ten years and older, so that it is not possible to calculate average vehicle age 
for 2016 omitting UK registrations. 
34 Hudec J., et al. (2021), Examination of the results of the vehicles technical inspections in relation to the 
average 
states, 
https://www.sciencedirect.com/science/article/pii/S2352146521004695 
35  The  General  Safety  Regulation  requires  that,  from  2022,  new  vehicle  types  are  equipped  with  these 
features, and the features will be mandatory on all new vehicles from July 2024 onwards.  

vehicles 

selected 

age 

EU 

of 

in 

19 

010203040506070201620172018201920202021Percent over 10 years oldCarLCVMHCVBus 
 
 
 
progressively need to be complemented or even replaced by inspection modes that access 
vehicle status and operational data by other means.  

Related to this last issue, improved vehicle technologies offer opportunities to enhance PTI 
with improved and comprehensive data, but also carry a risk that current testing services 
are becoming outdated. The introduction of sophisticated electronic safety and advanced 
driver assistance systems have outpaced the existing standardised inspection methods at 
PTI. Systems like ADAS require information from manufacturers which is necessary to 
electronically access and diagnose them. However, the actual availability of data is not the 
only issue. The costs due to the divergence of format of vehicle data necessary to carry out 
the inspection is also a problem. The divergence of formats of data and functions across 
vehicle brands poses a major obstacle to the development of improved PTI methods. The 
limited  access  by  vehicle  inspection  authorities  and  authorised  entities  to  the  functions 
relevant  for  roadworthiness  testing  means  that  the  inspection  of  the  safety  and  driver 
assistance systems may not be carried out properly. Hence, expected benefits to prevent 
crashes could be negatively impacted. The same applies to pollutant emissions when, for 
example, the software integrity of the emission control system cannot be checked in the 
absence of access to relevant vehicle functions.  

Member States have also repeatedly reported difficulties to the Commission in effectively 
enforcing road safety measures in EU cross-border traffic and vehicle trade. These mostly 
have their origin in difficulties for competent authorities in accessing vehicle register data 
and other safety-relevant information of vehicles, notably if these are registered in another 
Member State. These difficulties may also negatively impact upon attempts to combat the 
presence on the roads of vehicles with defects or tampered components, which negatively 
affects road safety, consumer welfare and environment in the EU.  

One of the issues regarding the implementation of the RWP is related to the increasing 
roll-out  of  vehicles  with  alternative  power  train  technologies  (e.g.  hybrid  and  zero-
emission  powertrains)  which  require  particular  testing  methods  for  their  safety-  and/or 
environment-relevant  components.  The  RWP  does  not  currently  provide  specific 
guidelines  for  inspecting  such  vehicles  during  PTIs.  When  the  current  Roadworthiness 
Package was adopted in 2014, only around 0.5% of the newly registered vehicles in the 
EU were electric, including hybrids and range extended vehicles, whereas by 2022 battery 
electric vehicles accounted for 12% of new car registrations36. The issue may exacerbate 
in view of the ambitious EU’s goal of climate neutrality by 2050 which will require having 
30 million EVs on the European roads by 203037. 

While air pollutant emissions from road transport have fallen in the past decade in the EU, 
in 2022 road transport remained the principal driver of the exceedances of NO2 emissions, 
as reported by Member States, with 64% of all reported exceedances linked to dense road 
traffic in urban centres and to the proximity to major roads38. The road transport sector was 
also  the  main  source  of  reported NOx emissions,  responsible  for  41%,  followed  by  the 
energy  supply  sector  at  17%.  It  is  also  important  contributor  to  black  carbon  pollution 
(32%), CO emissions (24%) and PM (particulate matter) emissions (20%)39. The impact 

36 Fuel types of new passenger cars in the EU - ACEA - European Automobile Manufacturers' Association 
37 Sustainable and Smart Mobility Strategy, COM(2020) 789 final, 9.12.2020 
38 EEA, Managing Air Quality in Europe, 2023 
39 EEA, Air Pollution in Europe; 2023 reporting status 

20 

 
 
 
of  road  transport  emissions  of  NO2  and  PM  on  air  quality,  especially  in  urban  areas, 
remains high, because they take place close to the ground and the dilution effect is lower. 

Since 2015, the development of real-driving emissions (RDE) legislation as a key policy 
to address high real-world emissions of nitrogen oxides (NOx) from diesel cars led to the 
application of new and more sophisticated emission control technologies and independent 
verification. The change has confirmed the need to move away from reliance on the vehicle 
manufacturer  information  for  checking  the  actual  emissions  (such  as  reading  the  OBD 
instead of tailpipe testing). With Euro 6, the selective catalytic reaction (SCR) technology 
has become standard on light-duty diesel vehicles, passenger cars and vans, and the typical 
NOx emission levels dropped under the emission limits.  

At the same time, the existing EU framework for vehicle inspection (RWP)  continue to 
rely,  to  some  extent,  on  manufacturer  maintenance  information,  i.e.,  on  on-board 
diagnostics (OBD)), without any possibility to check independently its functioning. On the 
other  hand,  the  inspection  and  surveillance  authorities’  tasks  and  responsibilities  were 
extended under the new type-approval and market surveillance legislation in 201840. From 
2020 Member States and type-approval authorities have the task of testing independently 
and  have  no  longer  to  rely  on  certification  documents  and  the  industry’s  own  quality 
control systems. The market surveillance authorities received a broader mandate with more 
means of enforcement. Among these tasks are the checking of the use of defeat devices in 
vehicles,  which  can  increase  the  emissions  disproportionally  in  normal  use,  outside  the 
type-approval tests. The Member States are still adjusting to this new situation.  

The need for comprehensive oversight and coordination of activities has been increasingly 
recognised since 2018. The Member States have developed their own legislation to deal 
with a variety of vehicle emission problems, with national legislation for PTI tests, anti-
tampering, software updates and dealing with car manufacturers. With Euro 4 and (later) 
Euro 5 vehicles slowly leaving the vehicle fleet and the uptake of zero-emission vehicles, 
it is expected that the GHG emissions as well as air pollution due to road transport will 
decrease. However, the issues related to defects and tampering of EGR, particle and NOx 
filters will persist, and so will the wear emissions of tyres and  brakes. These emissions 
would  be  addressed  in  the  proposed  Euro  7  Regulation41,  which  is  currently  in  the 
legislative process, stimulating  new vehicle and  brake  technologies.  Nevertheless, NOx 
emissions from road transport remain the main source of NOx pollution as long as vehicles 
with internal combustion engines are on the road. Hence, the environmental performance 
of vehicles will have to be ensured, notably through adequate roadworthiness testing. 

4  EVALUATION FINDINGS (ANALYTICAL PART) 

4.1  To what extent was the intervention successful and why?  

4.1.1  Effectiveness 

This  section  summarises  to  what  extent  the  Directives  have  been  successful  in  (a) 
contributing to road safety by increasing the quality and better coordination of national PTI 
and  roadside  inspection  systems  and  (b)  helping  to  reduce  greenhouse  gases  and  air 
pollutant emissions from road transport through detecting more effectively and removing 

40  https://eur-lex.europa.eu/EN/legal-content/summary/eu-approval-and-market-surveillance-measures-for-
motor-vehicles-and-their-trailers.html  
41 COM(2022)586, https://ec.europa.eu/commission/presscorner/detail/en/ip_22_6495 

21 

 
 
from circulation vehicles which are over-polluting. In addition, the section also provides 
insight  into  what  extent  the  Directives  were  successful  in  the  creation  of  a  harmonised 
framework for roadworthiness control and vehicle registration, and cooperation between 
Member States in this field, which helps the free movement of EU citizens and the smooth 
functioning of the internal market.  

4.1.1.1  Factors  contributing  to  the  road  crashes  related  to  the  technical  status  of  a 

vehicle  

While not the most important cause of road crashes, defects of vehicles due to technical 
malfunctions and/or inadequate maintenance have been found to be the cause for a small 
share of crashes on EU roads. Deficiencies of those vehicles can compromise vehicle safety 
and increase the likelihood of occurrence of road crashes and associated injuries. The 2012 
Impact Assessment had identified that on average, technical defects are responsible for 6% 
of all traffic collisions. In view of the expected overall increase in the number of passenger 
cars  in  use,  it  was  expected  that  in  principle  the  risk  of  crash  occurrence  would  also 
increase, despite the downwards trend in fatalities. The 2012 Impact Assessment assessed 
that it was probable that the share of crashes caused by technical defects would even rise 
from the estimated 6%. 

A  2021  study42  examined  the  status  of  temporarily  roadworthy43  vehicles.  There  was  a 
significant variation observed among Member States in terms of PTI failures, which may 
be due to the variation in the stringency with which testing is applied in selected countries, 
and not necessarily that vehicles are less roadworthy in those countries.  

Table 5: Average value of temporarily roadworthy and not roadworthy vehicles assessed 
by PTI in selected European states in 2019 

Countries observed in the study 

% of temporarily roadworthy and not 
roadworthy in 2019 

Poland 

Czech Republic 

Austria  

Slovakia 

Estonia 

Spain 

Germany 

Finland 

Ireland 

2.00 

8.46 

10.14 

13.03 

15.06 

20.66 

20.77 

27.00 

35.76 

of 

age 

42 Hudec J., et al. (2021), Examination of the results of the vehicles technical inspections in relation to the 
average 
states, 
https://www.sciencedirect.com/science/article/pii/S2352146521004695 
43 A vehicle is considered to be “temporarily roadworthy” if the technical inspection is carried out and at 
least  one  major  defect  is  detected,  but  no  dangerous  defect  is  detected.  A  vehicle  is  considered  "not 
roadworthy" if at least one major or dangerous defect is detected on the vehicle. In both instances the vehicle 
has failed the inspection test. 

vehicles 

selected 

EU 

in 

22 

 
 
Latvia 

39.97 

Source: Ricardo, 2023, Impact assessment support study 

The age of a vehicle is an important factor that contributes to the risk of roadworthiness 
faults.  Studies  have  consistently  shown  significantly  higher  failure  rates  among  older 
vehicles, specifically those exceeding 10 years of age. For example, a study from 201844, 
which used data from Spain, found that failure rates in PTI went up with age for passenger 
cars and light commercial vehicles, and that failure rates were particularly high for vehicles 
more than 10 years old. A similar pattern was found related to crashes, with older vehicles 
featuring more frequently due to defective tyres, steering and brakes.  

The analysis of the involvement rates of older vehicles in crashes in the period before the 
RWP was in place supports the argument that older vehicles pose an extra safety risk: the 
analysis comparing the share of involvements in fatal crashes for passenger cars aged 10 
years or more with the share of vehicle registrations concluded that those vehicles have a 
13% higher involvement than the average for all vehicles. Given that the literature reports 
that older passenger cars have considerably lower annual mileage, compared to younger 
vehicles, that over-involvement is likely to be about 50% higher when calculated on a per 
km  basis  as  opposed  to  a  per-vehicle  basis,  i.e.  to  be  around  19.5%,  which  suggests  a 
substantial extra safety risk for the use of older vehicles45. 

Regarding the role of technical defects in road safety at both EU and national levels there 
are various estimations. According to the report from the EPRS in 202046, technical vehicle 
defects  are  deemed  responsible  for  around  5%  of  accidents  involving  goods  transport 
vehicles while poor maintenance causes about 4% of accidents for road users. The most 
comprehensive studies on the subject show that vehicle defects are a contributing factor in 
6.5% to 12.6% of traffic crashes; for motorcycles, it is 5% to 12% of accidents47. Technical 
faults  were  registered  as  a  cause  or  contributing  factor  in  3%  of  traffic  collisions  in 
Norway, primarily associated with worn tires and incorrect air pressure48. The 2012 Impact 
Assessment  reported  varying  estimations  of  technical  defects'  contribution  to  traffic 
collisions, ranging from 3% to 19%.  

There is also further evidence based on results of PTI in selected countries, showing the 
link between improved technical  condition of the vehicles and increased road safety.  A 
study49 on data from Spain attempted to assess the impact of PTI on road safety in terms 
of  numbers  of  avoided  road  crashes,  injuries  and  fatalities  for  each  vehicle  category. 
According to the study, thanks to the inspections carried out during 2016, at least 17,632 
crashes, about 12,103 injuries and 133 deaths have been prevented, which translated into 
an economic benefit of  at  least EUR  330 million.  It  should be noted that  the estimated 
impacts  should  be  nevertheless  treated  with  caution  since  the  underlying  assumptions 

44  Diaz  Lopez  et  al.,  2018,  https://www.aeca-itv.com/wp-content/contribucion-itv-seguridad-vial-medio-
ambiente/eng/files/assets/common/downloads/ROADWORTHINESS%20TESTING%20CONTRIBUTIO
N%20TO%20VEHICLE%20SAFETY%20AND%20ENVIRONMENT.pdf?uni=8643c3a2724634911b854
c6080952f96. 
45 VVA et al. (2023), Evaluation support study 
46 European Parliamentary Research Service (2020), Report on the implementation report on the road safety 
aspects of the Roadworthiness Package 
47 Sarkan et al. (2022), Effect of periodical technical inspections of vehicles on traffic accidents in the Slovak 
Republic 
48 Norwegian Public Roads Administration (2021), Special Analysis, Fatal Motorcycle Accidents 2005-2009 
49 UC3M (2019), Roadworthiness testing contribution to vehicle safety and environment 

23 

 
 
concerning  the  contribution  of  PTI  to  the  reduction  of  road  accidents  are  not  generally 
accepted.  

Table 6. Impact of vehicle technical inspections on road safety in Spain  
Avoided Traffic 
Collisions 

Avoided Injuries 

Avoided Fatalities 

Passenger cars 

Vans 

Motorbikes and mopeds 

Total 

Source: UC3M, 2019 

11,895 

2,127 

3,610 

17,632 

7,602 

864 

3,637 

12,103 

80 

12 

41 

133 

In relation  to  vehicle age and deficiencies, the database from in-depth  investigations of 
road  crashes  IGLAD,50  containing  data  for  Austria,  Czechia,  France,  Greece,  Italy, 
Sweden, Slovakia and Spain was analysed in the evaluation support study. Figure 3 shows 
a comparison of the average age of the vehicles in IGLAD selected countries compared 
with the average age of the vehicles for which a defect was coded as a contributory factor. 
While  there  is  considerable  year-to-year  variation  for  the  defect  coding,  it  can  still  be 
observed that an overall trend for the age of vehicles with defects rose faster that the age 
of all the vehicles involved. This indicates a growing problem of defects for older vehicles, 
perhaps related to some very old vehicles. 

Figure  3.  Average  age  of  vehicles  in  IGLAD  database  compared  with  average  age  of 
vehicles coded with a defect as a contributory factor. 

Blue: all vehicles involved in the road crashes, Orange: vehicles with defects 
Source: VVA et al. (2023), Evaluation support study  

4.1.1.2  Contribution of the RWP to road safety objectives  

The stakeholders surveyed emphasised that by providing a common framework for PTIs, 
the RWP plays a central role in maintaining high vehicle standards, improving road safety 
and  reducing  emissions.  Some  stakeholders  mentioned  how  PTI  could  have  an  indirect 

50 Initiative for the Global Harmonisation of Accident Data, http://www.iglad.net/  

24 

 
 
 
 
psychological effect on vehicle owners: the awareness of the obligation to undergo a PTI 
can  lead  vehicle  owners  to  preventively  fix  certain  defects  before  the  inspection  itself, 
thereby contributing to their safety. If the RWP had not been implemented, then they may 
not  have had the same incentive to  do so. While most of the respondents  to  the survey 
acknowledge the contribution of PTI and RSI Directives to improved road safety to a large 
or even to a high extent, the opinions are more divided regarding the contribution of the 
VRD  Directive  to  improved  safety:  where  vehicle  registration  authorities  maintain  a 
neutral opinion while EU associations and road safety authorities stated that registration 
documents lead to increased safety on the road and environmental compliance. Availability 
of accurate vehicle registration data is essential for the proper functioning of the cross-
border exchange of information related to road safety offences. While the survey did not 
indicate specifically the role played by the Directive on facilitating cross-border exchange 
of information on road-safety-related traffic offences (Directive 2015/413/EU)51, the inter-
institutional negotiations leading to the adoption of this Directive in 2015 confirmed the 
enabling  function  of  vehicle  registration  data  for  the  purpose  of  enforcement  and  have 
identified areas for further improvements.  

Regarding  the  success  of  the  RSI  Directive  to  contribute  to  road  safety,  stakeholders 
consulted in the survey - ministries, road safety authorities and PTI bodies - agree to a large 
extent  that  RSI  has  contributed  to  improved  road  safety,  although  just  over  half  of  the 
respondents do not have an opinion on the matter (see Figure 4). Road safety authorities 
mentioned that figures on crashes in general have decreased since the Directive came into 
force.  

Figure 4. Stakeholder opinions regarding the effectiveness of the RWP in improving road 
safety  and  contributing  to  the  reduction  of  road  fatalities  and  serious  injuries  in  road 
transport (n=49). 

Source: VVA et al. (2023), Evaluation support study, Survey results 

Stakeholders reported in the context of RSI, that the identified deficiencies have slightly 
increased since the entry into force of the Directive, helping reduce the number of vehicles 
in circulation with dangerous defects.  

Table  7  illustrates  the  total  number  of  RSIs  performed  in  selected  EU  Member  State, 
including percentages of failed vehicles. The percentage of RSI failed vehicles for the years 
2021 and 2022 ranges from 3.8% (reported for Poland) to a maximum of 58.2% (reported 
for Sweden), with a total average of 9.6% of failed RSI checks.52 

51 EUR-Lex - 32015L0413 - EN - EUR-Lex (europa.eu) 
52 The  RSI  failure rates in Member States can vary for a number of reasons, including whether the RSI 
checks are random or are targeted on the basis of a risk assessment, and the nature of the initial check. 

25 

 
 
 
Table 7. RSI checks by selected EU countries for the period 2021-2022 

Source: VVA et al. (2023), Evaluation support study  

The rules related to the training of inspectors, the detailed listing of deficiencies and the 
prevention of conflicts  of interest  have contributed to  making roads safer, but  there are 
several  gaps  that  are  not  explicitly  addressed  by  the  RWP.  For  example,  electronic 
manipulation  of  engines,  diesel  particles  exhaust  emissions,  ADAS  suspensions  and 
electronic systems cannot be checked based on current PTI standards. Also, desk research 
suggests  that  not  all  deficiencies  can  effectively  be  detected  by  applying  the  current 
technical standards for vehicle inspections and that the protocols set in the RWP are not 
sufficient to detect malfunctions and tampering, possibly leading to high emissions of key 
air pollutants.  

Findings from interviews with stakeholders also indicate that the likelihood of road crashes 
due to technical defects increases as the PTI validity approaches its end. Some stakeholders 
therefore thought that shortening the PTI interval for vehicles older than 10 years might be 
a  beneficial  measure,  as  the  probability  for  deficiencies  is  particularly  high  in  older 
vehicles. 

Finally, the analysis carried out in the evaluation support study for the years the 2016 to 
2020 examined whether the changes over the years in the share of fatal involvements by 
older passenger cars could be explained by changes in the share of older vehicles in the 
fleet. Data from the countries included in the CARE database analysis of passenger car 
fatal  involvements  was  used,  alongside  registration  data  for  those  countries.  The 
conclusion was that there was very little difference between the predicted evolution of fatal 

26 

  Reporting Country Total  Checked Failed Percentage failed BE 17516 3157 18.0% EE 16566 2593 15.7% FI 16621 6280 37.8% HR 16852 2272 13.5% IT 10082 2367 23.5% LT 9963 1371 13.8% LV 16566 2593 15.7% MT 6193 2638 42.6% PL 780185 29762 3.8% PT 335 184 54.9% SE 67388 39201 58.2% Total 958267 92418 9.6%  
 
 
involvements (counterfactual situation) and the actual evolution (CARE data). Beyond the 
crash data analysis, there appears to  be a general  scarcity of empirical  data allowing to 
establish a clear link between roadworthiness testing and improved road safety. Despite 
this,  the  analysis  based  on  an  examination  of  the  available  literature  on  safety  and  the 
stakeholder input combined, suggests that vehicles on the road have generally been made 
safer  through  the  introduction  of  common  standards  for  roadworthiness  testing,  testing 
centres and personnel training, as well as by the adoption of standard rules for frequency, 
scope and methods for testing.  

4.1.1.3  Contribution of the RWP to emissions reduction objective 

Regarding the objective of the RWP to help reducing GHG emissions and air pollution, 
roadworthiness emission checks have the potential to identify high-emitting vehicles that 
are  responsible  for  most  of  the  air  pollution  from  road  transport.  These  high-emitting 
vehicles  include  vehicles  with  technical  problems,  as  well  as  vehicles  with  tampered 
emission systems. Emission reduction technologies reduce emissions significantly. As a 
consequence, when this technology is not functioning properly, a small fraction of vehicles 
with malfunctioning emission technology has a major impact on the total emissions. This 
phenomenon has been reported by study on remote sensing53 based on on-road emission 
measurements  carried  out  in  2019.  Figure  5  presents  the  results  of  the  study  which 
demonstrates that the few high emitters54 reported are responsible for a relative high share 
of pollution.  

53  Hooftman  N.,  Ligterink  N.,  Bhoraskar,  A.,  (2020),  Analysis  of  the  2019  Flemish  remote  sensing  campaign. 
Commissioned by the Flemish Government - Flanders Environment Agency - Team Air quality policy 
54 The term "high emitter" is generally considered to refer to a margin over legal limits. In the Flemish remote 
sensing study, they defined high emitters as emitting at least 1.5 times above the average of their vehicle 
category emission class, and they looked at real driving emissions 

27 

 
 
 
Figure 5. NOx emissions per vehicle category, fuel type and Euro class. 

Source: Hooftman et al., 2020 

To  understand  the  impact  of  the  2014  EU  rules,  using  the  number  of  PTI  failures  on 
emission  and  the  data  from  the  various  studies,  the  effect  of  PTI  was  estimated  in  the 
evaluation support study as presented in Table 8. 

Table 8. Estimates of the effect of PTI 

Source: VVA et al. (2023), Evaluation support study  

Based on these estimations, on average, emissions would increase by 10% to 13% for PM 
and by 4% to 10% for NOx without the current PTI procedures. However, the number on 
high  emitters  on  the  road  despite  the  current  inspection  efforts  also  demonstrates  that 
further  reductions  in  emissions  are  needed.  Literature  review  has  also  pointed  at  the 
problem  that the current  procedures are inadequate for detecting tampering, removal or 
malfunction of EGR, SCR and Three-Way Catalytic converter (TWC) and DPF 55.  

55 Ligterink, N.E., Elstgeest M., Frateur T., de Ruiter J.M., Paschinger P. (2022) Approaches for detecting 
high  NOx  emissions  of  aged  petrol  cars  during  the  periodic  technical  inspection  TNO  report 
https://publications.tno.nl/publication/34639407/wqLoW7/TNO-2022-R10659.pdf 

28 

Engine Pollutant High emitter share of vehicles High emitter share on emission  High emitter share of vehicles (no PTI assumed) High emitter share on emission (no PTI assumed) Factor increase emission (no PTI against RWP) Petrol car, van PM 10.5%  78.5% 11.50% 80.17% 107.24% Petrol car, van NOx 6.9% 41.1% 7.90% 44.68% 105.32% Diesel car, van PM 10% 80.4% 10.50% 81.24% 103.91% Diesel car, van NOx 4.6% 19.4% 5.10% 21.15% 101.69% HDV Diesel NOx 6.14% 54.7% 6.64% 56.76% 104.21%   
 
 
 
Regarding the impact of the RWP on CO2 emissions, the policy measure that targeted the 
CO2 reduction was the increased frequency of the testing for “older” cars (i.e. more than 
6  years  old),  which  would  have  lead  to  better  maintanence  of  vehicles  and  reduce  the 
presence  of  high-emitting  vehicles  on  the  EU  roads.  This  measure  was  however  not 
retained  in  the  finally  agreed  text  of  the  PTI  Directive.  It  should  also  be  noted  that 
emissions depend on fuel consumption and the type of powertrain. No effect from the RWP 
for CO2 emission reduction could therefore be identified in the evaluation. The only impact 
could be indirect through the measures targeting the tampered vehicles, but no evidence 
was found on this in the evaluation. Therefore, the effect of the RWP on CO2 emission 
can be expected to be very minor.  

Stakeholders’ views regarding the effectiveness of the RWP in reducing emissions were 
divided:  while  representatives  from  some  Member  States  reported  having  positive 
experiences  with  dealing  with  stricter  air  pollutant  limits  for  diesel  cars  and  for 
hydrocarbons of petrol cars, others claim that current emissions requirements are no longer 
applicable and therefore need to be updated. Basic tests for diesel engines are not able to 
accurately take emission measurements for Euro 5 and Euro 6 vehicles, and they do not 
detect  faults  in  newer  diesel  cars  and  older  cars  with  missing  catalysts.  For  example, 
opacity testing measurement56 is outdated as it no longer applies to new diesel vehicles in 
circulation  and  it  does  not  accurately  capture  GHG,  particle  matter  and  NOx  counts. 
According  to  some  of  the  stakeholders  consulted,  particle  number  (PN)  measurement 
should  be  used  as  the  control  method  for  newer  diesel  cars  to  detect  tampering  with 
emission control systems, and remote sensing emission limits should be set for each type 
of vehicle and Euro standard to standardise remote sensing across the EU. 

Survey  respondents  gave  varied  responses  to  the  question  on  the  extent  to  which  the 
provisions of the RWP have contributed to reduced air pollutants from road transport since 
it  came  into  effect  in  2018.  The  majority  did  not  have  specific  views  or  were  neutral, 
whereas slightly more stakeholders who provided a reply considered that the contribution 
was high or to some extent, than those who thought it was only limited or not even that 
(see Figure 6). 

56  Exhaust  gas  opacity  is  a  result  of  the  presence  of  solid  particles,  hydrocarbons  and  water  vapour.  An 
increase  in  exhaust  gas  opacity  is  usually  accompanied  by  an  increase  in  the  emission  of  other  harmful 
exhaust gas components (CO2, CO, HC, NOx). Exhaust smoke opacity measurement is conducted by using 
an adsorption opacimeter. 

29 

 
 
 
Figure 6. Contribution of rules and provisions of the RWP to reduced air pollutants (n=49) 

Source: VVA et.al (2023), Evaluation support study, survey results 

According to the EU associations57 active in this policy area and road safety authorities 
which responded to the survey 58, the PTI Directive ensures the environmental performance 
of motor vehicles by regular testing throughout their entire service life, and they considered 
that the proportion of vehicles failing emission tests at PTI has declined from its start of 
implementation in 2018. However, according to the EU associations, additional equipment 
and testing methods, such as PM and NOx requirements for AdBlue systems, and OBD 
scanning tools for commercial and non-commercial vehicles, would be needed to increase 
the detection of high emitters. The same stakeholder group also agreed to some extent that 
the  current  PTI  testing  is  able  to  detect  malfunctions  and  tampering  leading  to  high 
emissions of air pollutants, whereas national ministries and road safety authorities agreed 
to  a  limited  extent.  Feedback  from  ministries  and  road  safety  authorities  showed  that 
vehicles with defects that have been tampered, which are not covered by the EOBD system 
or those specifically related to NOx emissions (e.g. defects in sensors required by ADAS 
systems) will not necessarily be detected by the current PTI regimes. An OBD check and 
complementary tailpipe measurement are perceived to be the optimal way to perform an 
emissions test, and to leverage all potential PN measurements. 

4.1.1.4  Contribution of the RWP to improved exchange of information and functioning 

of the internal market 

Regarding  the  improvement  of  the  exchange  of  information  on  testing  results  between 
actors and Member States, according to most stakeholders consulted there appears to be 
significant room for improving the current framework. Although the legislation enables 
data  exchanges  between  Member  States  authorities,  it  does  not  mandate  it  (and  not  all 
countries use this), nor does it define essential elements for the exchange of information, 
especially  for  the  compliance  with  the  existing  EU  data  protection  standards59  and 
cybersecurity aspects. Many Member States use the EUCARIS system on a voluntary basis 
for import/export of vehicles and registration processes. 

Some stakeholders stated that additional EU legislation might be desirable to formalise the 
use of services to improve information exchange, including cross-border odometer fraud. 
Several  EU  associations  highlighted  that  in  case  more  countries  were  connected  to  a 
common platform, this could result in a quick win for facilitating information exchange 
and making relevant vehicle mileage data available to car buyers and inspection operators 
across  borders.  Just  over  a  half  of  the  survey  respondents  (28  out  of  49)  expressed  no 

57  The  group  ‘EU  association’  in  the  survey  carried  out  by  the  external  contractor  includes  business 
associations, NGOs and consumer associations.  
58 VVA et al. (2023), Evaluation support study, survey results 
59 Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and 
on the free movement of such data (General Data Protection Regulation) 

30 

 
 
 
opinion on whether the 2014 RWP made it possible to further digitalise the re-registration 
process, while only 7 out of 49 considered that it made it easier to further digitalise the re-
registration process.  

From a legal point of view, the current situation brings therefore uncertainty as regards a 
key enabling factor of the EU-wide cooperation between relevant authorities. Uncertainties 
also exist regarding the enforcement of data protection rules applicable in the Union when 
it comes to exchange of information between national authorities.  

Regarding the contribution of the RWP to facilitating free movement for EU citizens and 
the smooth functioning of the internal market, 20 stakeholders (EU associations, ministries, 
and road safety authorities) out of 49 considered that the VRD Directive has contributed 
to  the  free  movement  of  citizens,  while  25  had  no  opinion  on  that.  EU  associations 
highlighted that the obligation to keep electronic record of data on all vehicles registered 
in their territory and to exchange information between Member States helps improve free 
movement of EU citizens, as well as the recognition of PTI certificates in EU countries. 

Even if the harmonisation of vehicle registration documents was made easier for citizens 
to register vehicles from other Member States and EEA, there seems to be room for further 
advancing  the  digitalisation  process  to  make  it  even  easier.  Moreover,  although  some 
countries have entered bilateral agreements (such as between Sweden and Spain), there is 
no mutual recognition of a PTI across Member States. Currently, PTIs must be performed 
in  the same country  where the vehicle has been  registered,  which in  practice limits  the 
effects of the EU harmonisation. 

Other factors having driven or hindered the achievement of the objectives 

During  this evaluation, stakeholder views on the  main  elements  currently hindering  the 
achievements of the objectives defined by the RWP were also collected, such as the lack 
of harmonisation of PTI standards, equipment and procedures across Member States and 
the inconsistencies identified between the RWP and the Type Approval Directive. Most 
stakeholders,  especially  EU  associations  and  Member  States  authorities  (ministries  and 
road  safety  authorities)  agreed  on  the  importance  of  ensuring  free  access  to  relevant 
standardised  in-vehicle  data  and  functions  to  authorised  service  providers,  as  well  as 
creating an electronic information platform to drive digitalisation and set standards for a 
common document platform in  the EU. Besides,  some shortcomings in  PTI/RSI testing 
could  be  avoided  in  their  views  if,  already  at  the  stage  of  type-approval  legislation, 
requirements  would  ensure  easier  testable  vehicles.  Therefore,  some  of  them  called  for 
type-approval made by design to testing needs.  

Some additional factors hindering the achievement of objectives have been highlighted by 
stakeholders during consultations, namely:  

▪  The absence of dedicated requirements for electric and hybrid vehicles such as 

safe, direct measurement sample points at the high voltage system; 

▪  The  exclusion  from  the  RWP  of  safety  functions  managed  by  electronics, 

ADAS systems and new intelligent headlights; 

▪  The ‘hidden’ wear and tear on cars with odometers that have been tampered 
with,  which  negatively  affects  maintenance  schedules  and  therefore  road 
safety;  

▪  No binding cargo securing rules which would ensure this area is regulated and 

would minimise accidents; 

31 

 
▪  The lack of PTI information in certification documents; and 
▪  The perceived excessive costs of testing equipment and the time  required by 

inspections. 

Regarding odometer fraud, the 2014 RWP introduced measures requiring Member States 
to ensure that the odometer data recorded at the previous roadworthiness test were made 
available during the next inspection. Member States have transposed this requirement, but 
in  many  cases,  there  were  no  effective  and  dissuasive  penalties  put  in  place  when  an 
odometer fraud was detected; moreover, the measures in place were in many cases rather 
generic, not specifically aimed at odometer fraud. Also, the existing measure does nothing 
to address the issue of odometer tampering between PTIs, or before a vehicle passes the 
first PTI. Moreover, in the absence of information exchange on odometer fraud between 
national authorities, cross-border odometer fraud persists. All these shortcomings point at 
ineffectiveness of the RWP as regards the odometer fraud. On the other hand, the examples 
of national implementing measures such as introduced by Belgium and Netherlands proved 
to be effective, as they addressed the issue of regular collection of odometer readings from 
vehicles, which takes place in-between PTIs (such as vehicle repair workshops, including 
tyre and windscreen repair services) and well before the first PTI. In addition, these two 
countries  introduced  an  exchange  of  the  odometer  history  data  between  the  national 
databases.  These  more  targeted  measures  proved  to  be  more  effective  in  tackling  the 
odometer fraud and could also be replicated at the EU level. 

4.1.2  Efficiency 

The efficiency analysis explores the extent to which the costs associated with the RWP 
have been proportionate to the overall benefits achieved.  

The  evaluation  support  study60  estimated  the  administrative  costs  for  vehicle  owners 
(citizens and businesses) at around EUR 10 billion in 2019. They were calculated based 
on the number of PTI inspections for all vehicle categories and the respective PTI charges. 
Regarding the possible benefits, the evaluation support study estimated 1,300 lives saved 
for 2019, and 10,600 serious injuries and 59,600 slight injuries avoided. In monetary terms, 
using the Handbook on the External Costs of Transport61, this would translate into benefits 
of around EUR 12.7 billion. In addition, the reduction in the external costs of air pollutants 
(NOx and PM) was estimated at EUR 0.7 billion. Thus, the total benefits are estimated at 
EUR 13.4 billion and the net benefits at EUR 3.4 billion. However, while these estimates 
can help understand the magnitude of costs and benefits of the PTI regime, they should be 
interpreted with a significant degree of caution. 

Stakeholders  assessed  rather  positively  the  extent  to  which  the  benefits  of  the  RWP  in 
terms  of increased road  safety,  reduced air pollutants and improved  free  movement  are 
justified compared to the costs and effort invested in implementing the EU rules (Figure 
7). Representatives of Member States’ authorities (ministries, road safety authorities) and 
EU associations mostly  agreed  that the  costs/benefits  ratio of PTI, RSI  and registration 
documents are justified. Ministries and the road safety authorities of several EU Member 
States stated that implementation of the RWP has not caused significant administrative and 

60 VVA et al. (2023), Evaluation support study 
61 https://op.europa.eu/fr/publication-detail/-/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1 

32 

 
 
 
 
adjustment  costs  as  they  already  had  a  developed  system  of  PTI  and  RSI.  National 
representatives noted that there is available evidence that demonstrate the contribution of 
the RWP Package – and in particular PTI – to the reduction of fatalities, thus justifying the 
investments. On the other hand, EU associations stated that EU legislation such as PTI can 
reduce the number of illegally polluting cars on the EU's roads and reduce the human costs 
of air pollution. 

Figure 7. Benefits of the RWP (increased road safety, reduced air pollutants) justification 
compared to the costs and efforts invested in implementing the RWP rules (n=49) 

Source: VVA et al. (2023), Evaluation support study, survey results 

Despite the lack of sufficient and reliable empirical data to perform a comprehensive cost-
benefit analysis for the RWP, the benefits of its implementation are likely to outweigh the 
associated costs. For instance, a 2018 study on odometer manipulation in motor vehicles 
in the EU62 showed that the total economic costs of odometer fraud in second-hand cars 
traded cross-border in the EU can be estimated to be at least EUR 1.31 billion, with the 
most probable fraud rate scenario incurring a loss of around EUR 8.77 billion.  

In the stakeholder interviews63, it was also suggested that a way to simplify the RWP and 
reduce  costs  could  be  to  prioritise  the  adaptation  of  PTI  procedures  to  keep  up  with 
technical  advancements  and  thus  strengthen  the  safety  of  vehicles.  Stakeholders  also 
pointed out that it would be important to establish universal standards for in-vehicle data 
access to facilitate inspections. To further reduce expenses, some stakeholders considered 
to  be  made  mandatory  for  original  equipment  manufacturers  (OEMs)  to  provide 
information required for carrying out the inspections to PTI operators free of charge. Along 
with  a  unified  digital  format  for  registration  documents  and  the  definition  of  universal 
standards  for  data  extraction,  this  requirement  could  greatly  simplify  the  RWP  and 
minimise  expenses.  Finally,  some  stakeholders  suggested  adjusting  the  scope  of  the 
Directives  to  exclude  weights  for  roller  brake  testers  and  heavy  vehicle  lifting  testing 
methods to simplify the RWP and reduce costs.  

Administrative burden for authorities, businesses and citizens 

The  RWP  has  placed  several  administrative  responsibilities  on  public  authorities  in 
Member  States.  Interviewed  stakeholders  generally  considered  the  administrative 

62  EPRS  study  “Odometer  manipulation  in  motor  vehicles  in  the  EU”,  January  2018,  available  at: 
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_E
N.pdf 
63 VVA et al. (2023), Evaluation support study, stakeholder interviews 

33 

 
 
 
workload  generated  by  the  three  Directives  a  necessary  condition  for  its  effective 
implementation.  The  major  administrative  challenges  and  related  costs  faced  by  PTI 
centres included training of highly qualified inspection personnel, investments in necessary 
equipment and materials, analysing statistical data from technical controls, and monitoring 
of  inspector  activities,  including  the  supervision  of  testing  centres  and  verification  of 
inspectors. To reduce administrative burden on national authorities, some best practices 
include  developing  e-PTI  (electronic  PTI)  based  ISO  standards,  which  can  allow  for 
automatic real-time transmission of diagnostic data through the OBD port and streamline 
procedures  for  monitoring  the  implementation  of  the  RWP.  The  stakeholders  consulted 
pointed out that important vehicle data is often not accessible to inspectors: therefore, it 
has been suggested that testing would be improved if information for vehicle inspections 
was made available to inspection centres free of charge. 

Odometer  tampering  causes  to  the  buyers  of  tampered  cars  higher-than-expected 
maintenance and repair costs because the cars are not inspected based on their real mileage. 
Some  Member  States  have  introduced  instruments  to  minimise  odometer  manipulation, 
such  as  Car-Pass  in  Belgium  and  Nationale  AutoPas  (NAP)  in  the  Netherlands;  both 
Member States use a database collecting odometer readings at every maintenance, service, 
repair, or periodical inspection of the vehicle, without collecting any personal data, and 
both have almost eradicated odometer fraud in their domains within a short timeframe64. 

Ministries, road safety authorities and vehicle registration authorities emphasised in their 
interviews that digital data exchange and harmonisation of vehicle documents is needed 
for  streamlining  the  vehicle  re-registration  process  since  standardising  the  content  and 
format  of  vehicle  files  would  facilitate  the  digital  transfer  of  registration  information 
between national databases and reduce the administrative burden and costs associated with 
the  process.  The  interviewees  stressed  the  need  for  a  legal  framework  to  support  this 
exchange of data and digital services for efficient re-registration process. The introduction 
of  digital  information  systems  and  structured  messages  exchanges  was  also  seen  as 
possibly  helping  to  improve  communication  among  Member  States  and  to  reduce 
administrative burden.  

In terms of the administrative burden RWP imposed on businesses and citizens, most 
stakeholders in the survey (30 out of 49) did not provide any opinion or were neutral of 
whether the RWP has generated administrative burden for businesses. Similarly, more than 
half of the survey respondents (32 of 49) did not have an opinion or were neutral on the 
administrative burden generated by the RWP for citizens. However, it was highlighted that 
certain requirements were considered burdensome for citizens, such as the requirement for 
citizens to present their registration certificate when undergoing re-registration. This was 
perceived  as  time  consuming  and  add  to  the  overall  administrative  burden  faced  by 
citizens. Also, EU associations stated that digital (mobile) vehicle registration documents 
could  further  facilitate  the  digitalisation  of  the  vehicle  registration  and  data-keeping 
processes and reduce costs for citizens and businesses. Furthermore, a well-assessed test 
methodology  was  also  considered  important  to  avoid  false  negative  and  false  positive 
outcomes  during  PTI  and  to  achieve  a  harmonised  approach  to  test  procedures  and 
equipment.  This  would  help  improving  the  efficiency  of  inspections  and  could 
consequently positively impact both citizens and businesses.  

64 European Parliament resolution of 31 May 2018 with recommendations to the Commission on odometer 
manipulation in motor vehicles: revision of the EU legal framework (2017/2064(INL)) 

34 

 
 
4.1.3  Coherence 

The evaluation  of coherence covers both  the internal  coherence dimension which looks 
how  well  various  elements  of  the  RWP  operate  together,  and  the  external  coherence, 
meaning if and how the RWP is consistent with other related EU legislation and policies. 

The evaluation found no real issues with internal coherence of the RWP. Regarding the 
external coherence, the evaluation looked in the coherence with relevant EU legislation 
and policies in the field of EU road safety, such as the EU Road Safety Policy Framework 
2010 to 2020, and its successor, the Road Safety Action Plan 2021-2030, as well as the 
Sustainable and Smart Mobility Strategy. Stakeholders overall agreed on the consistency 
between  the  RWP  Directives  and  the  objectives  of  EU  road  safety  policy.  Periodic 
technical inspections and roadside inspections were considered essential instruments for 
achieving  the  European  Commission’s  Vision  Zero  approach  on  fatalities  and  serious 
injuries on European roads by 2050.  

type-approval 
However,  some  of 
requirements  should  enable  lifelong  testing  by  design  and  called  therefore  for  better 
coherence between the type-approval regulation and the RWP.  

interviewed  stakeholders  highlighted 

that 

the 

Regarding interventions at international level, EU associations also added that the UNECE 
whole-lifetime compliance is at a very preliminary stage while RWP is at a more mature 
stage and can be treated as state of the art legislation in the international context. Survey 
replies  however  reflected  the  opinion  that  more  coherence  between  the  RWP  and  the 
UNECE standards would be needed as regards the life-cycle approach. 

The evaluation identified the following specific coherence issues in relation to relevant 
EU legislation: 

•  The lack of coherence between the PTI Directive and Regulation 2018/858 
on  type-approval  requirements  for  motor  vehicles  makes  it  difficult  to 
perform thorough inspections, and the issue is likely to grow with deployment 
of automated devices, electronic sensors and safety features.  

• 

the  VRT  Directive,  definitions  of 

•  Coherence  with  Regulation  2018/858  on  type-approval  requirements 
regarding tampering: vehicles should not be allowed to be altered in a way that 
diminishes the original functioning of the emission and safety controls without 
further  legal  checks  and  it  should  be  possible  to  monitor  any  deviations  or 
alterations  during  PTI  or  RSI.  PTI  does  not  provide  an  effective  tool  to 
counteract  the  tampering  such  as  removing  particulate  filters  and  emulating 
SCR systems. 
In 
the  vehicle  registration 
data/terminology in  some instances do not  correspond to  those in  the type-
approval legislation. This leads to confusion and potential errors in recording 
and tracking vehicle information. 
Inconsistencies  of  definitions  existing  between  the  VRD  Directive  and  the 
End-of-Life  Vehicles  Directive  (Directive  2000/53/EU).  Terms  such  as 
‘registration’,  ‘de-registration’  ‘temporary  de-registration’,  ‘suspension’, 
‘cancellation  of  the  registration’  and  ‘permanent  cancellation  of  the 
registration’ should be harmonised across these two Directives. 

• 

•  General Safety Regulation (EU) 2019/2144 requires that all motor vehicles 
will  have  to  be  equipped  with  safety  features  such  as  intelligent  speed 

35 

 
assistance,  driver  drowsiness  and  attention  warning  systems;  these  systems 
should be also covered by roadworthiness testing. 

•  Lack of data coherence between the RWP and relevant EU legislations due to 
divergence  of  safety  relevant  vehicle  data.  According  to  interview 
respondents, a common problem with the RWP is the limited direct access to 
in-vehicle data and functions for authorised inspection service providers. For 
example, even two models of the same manufacturer can require different file 
formats, which makes the daily use of reference vehicle data very difficult;  
•  UNECE  regulations  on  whole-lifetime  compliance  set  out  methods  for 
checking  electric  vehicles  when  undergoing  a  technical  inspection  while  the 
PTI Directive does not specify such requirements. 

4.2  How did the EU intervention make a difference and to whom? 

The EU level intervention on roadworthiness testing and vehicle registration documents 
brought benefits beyond those which would have been possible at national or local level 
alone.  The  2021  European  Parliament  resolution65  strongly  endorsed  action  on 
roadworthiness at EU level, pointing out that there had been improved harmonisation of 
national procedures in the Member States, increased quality of PTI and better coordination 
in RSI. The report suggested that these actions had improved road safety standards.  

This  view  was  widely  acknowledged  by  relevant  stakeholders  consulted  during  this 
evaluation  who  perceived  the  RWP  as  contributing  towards  the  harmonisation  of 
roadworthiness  rules  among  Member  States.  By  creating  a  common  framework  for 
identifying  vehicle  defects,  the  RWP  ultimately  benefits  both  EU  citizens  and  business 
entities. Crucially, according to most consulted stakeholders, the introduction of minimum 
standards  for  periodical  technical  inspections  and  roadside  inspections  contributed  to 
preventing road crashes, thus being beneficial to vehicle owners and citizens at large.  

The  RWP  contributed  to  SDG  11  through  making  cities  and  human  settlements  more 
inclusive and sustainable, primarily by focusing on improving road safety (Target 11.2) 
and by reducing the adverse impact of cities, by focusing on air quality (Target 11.6), in 
particular the reduction of air pollutants such as NOx.  

The  interviewed  stakeholders  considered  that  had  the  RWP  not  been  in  place,  the  road 
safety policy in the EU would be more fragmented and with Member States possibly taking 
very  different  actions.  The  RWP  set  a  minimum  standard  for  all  Member  States  and 
provides a basic framework for detecting and addressing roadworthiness defects, ensuring 
that all Member States take action to improve road safety. 

Similarly, survey respondents agreed that the implementation of the RWP created value in 
terms  of  road  safety  and  environmental  protection  compared  to  what  could  have  been 
achieved without EU intervention (Figure 8). According to some of the EU associations, 
RWP sets a minimum standard across the EU and ensures that all Member States need to 
act  for  road  safety  and  environment  protection,  providing  a  basic  framework  and 
orientation  for  defects  with  a  wider  scope  and  more  detailed  description.  However,  as 
observed  by  some  ministries  and  road  safety  authorities,  several  Member  States  had 

65 Procedure File: 2019/2205(INI) | Legislative Observatory | European Parliament (europa.eu) Texts adopted 
- Implementation report on the road safety aspects of the Roadworthiness Package - Tuesday, 27 April 2021 
(europa.eu) 

36 

 
 
 
already implemented high-level roadworthiness test regimes before the implementation of 
the RWP. Across all stakeholder categories the need to improve mutual recognition of PTI 
inspections  was  emphasised,  since  this  adds  value  to  the  functioning  of  the  EU  single 
market, while it also helps increasing vehicle safety and environmental protection. 

Figure 8. Stakeholder views on RWP added value (n=49) 

Source: VVA et al. (2023), Evaluation support study, Survey results 

The  harmonisation  of  emission  standards  and  practical  implementation  to  test  these 
standards at EU level improves the level playing field for the commercial transportation 
of  goods  and  passengers  in  the  EU,  as  companies  in  different  Member  States  must 
comply  with  similar  technical  roadworthiness  requirements  leading  to  similar  cost-for-
vehicle purchases and maintenance in commercial activities. As vehicles and pollution do 
not stop at the border, it is rational for EU vehicles to meet the same emission standards 
and that throughout their lifetime operations. Finally, in requiring the mutual recognition 
of roadworthiness certificates from other Member States for the purpose of re-registration, 
the RWP provisions also facilitate free movement within the EU.  

4.3 

Is the intervention still relevant? 

Relevance in view of road safety objectives  

The Commission laid out a Road Safety Policy Framework for the decade 2020 to 203066 
which sets a 50% reduction target in deaths and serious injuries over the decade on the way 
to the goal of zero fatalities by 2050. The document recognises the importance of ensuring 
vehicle roadworthiness: “As safety problems often appear after the placing on the market, 
regular  roadworthiness  checks  are  important  to  ensure  that  consumers  are  protected 
through the lifetime of the vehicles.” Regular roadworthiness checks play a central role in 
ensuring consumer protection throughout the entire lifetime of the vehicles. 

It  can  also  be  argued  that  the  requirement  as  of  6  July  2022,  to  fit  a  variety  of  new 
Advanced Driver Assistance Systems (ADAS) systems introduced by the revision of the 
General  Safety  Regulation  of  201967  increases  the  relevance  of  vehicle  roadworthiness 
testing. These systems are potentially subject to malfunctions, they may require software 
updates to ensure intended performance and they could be the target of tampering. The 
projections  of  road  safety  benefits  from  these  systems  were  made  on  the  basis  that  the 
systems would be fully functional over the vehicle’s lifetime. Thus, the installation of these 
new ADAS systems requires expanding the scope of roadworthiness testing to verifying 
the operation of the mandated electronic systems. Similar findings on the importance of 

66 EUR-Lex - 52018DC0293 - EN - EUR-Lex (europa.eu)  
67 EUR-Lex - 32019R2144 - EN - EUR-Lex (europa.eu) 

37 

 
 
 
 
inclusion  of  the  recent  safety  systems  in  vehicles  come  from  a  study  published  by  the 
Commission in 2019 on the inclusion of eCall in periodic roadworthiness testing of motor 
vehicles. The study notes68 that the eCall equipment on a vehicle is subject to deterioration 
and that the inclusion of this equipment in PTI would have a high benefit-to-cost return.  

The  average  age  of  vehicles  has  been  increasing  in  recent  years.  According  to  ACEA 
data69, the average age of passenger cars in the EU was 10.7 years in 2016, whereas by the 
beginning of 2022 it had risen to 12.0 years. The average age of other vehicle categories 
rose  in  a  similar  way.  In  this  context,  the  International  Motor  Vehicle  Inspection 
Committee (CITA) points out70 that the average age of the vehicle fleet has increased and 
will continue to rise and that serious defects are more likely to emerge as vehicles age.  

The  RWP  is  recognised  by  technical  and  institutional  stakeholders  as  a  significant 
contribution towards road safety. It is generally acknowledged that the introduction of a 
common  EU  framework  for  conducting  PTIs  and  RSIs  has  yielded  many  advantages, 
allowing for better detection of deficiencies in malfunctioning vehicles throughout their 
lifecycle.  

With regards to the relevance of the RWP for the current needs of roadworthiness, all the 
objectives set out in the Directives are recognised to be relevant to a high or some extent 
by a majority of consulted stakeholders. As for the relevance of the RWP to  the future 
needs of roadworthiness, all the objectives are also deemed very relevant by the majority 
of  stakeholders  consulted:  despite  the  gradual  shift  to  e-mobility,  cars  with  internal 
combustion  engines  will  likely  still  be  on  EU  roads  for  decades,  and  the  RWP  has  the 
potential to continue to play an important role in monitoring emissions and ensuring road 
safety.  However,  all  stakeholders  consulted  during  the  evaluation  highlighted  the 
importance of adapting the Directives to the changes in vehicle technology. They take the 
view that the relevance of the RWP has been diminished by the widening gap between the 
existing  requirements  and  the  new  systems  installed  in  modern  vehicles.  In  particular 
driver assistance interfaces (e.g. ADAS), Intelligent Transportation Systems (ITS), human-
machine interface (HMI) and electronic safety features were considered by stakeholders as 
not sufficiently addressed by the RWP directives. On ADAS, the RWP does not seem to 
provide a sufficiently comprehensive framework for evaluating the safety performance of 
ADAS and automated vehicles of SAE Level 3 and higher. Another area that the RWP 
does not cover is the definition of specific testing protocols to ensure the compliance and 
maintenance of electric, hybrid and hydrogen vehicles, including how to handle software 
updates  in  a  safe  and  efficient  manner.  In  addition,  as  the  number  of  vehicle  classes  is 
growing  faster than the testing  centres’ ability to  diagnose their defects,  parameters for 
technical  inspections  are  not  sufficiently  updated  to  allow  the  efficient  acquisition  of 
important safety-related data and the monitoring of new sensors and functions. 

In terms of keeping up the RWP with the technological and scientific progress, most of the 
stakeholders interviewed considered that it is essential to update the Directives to include 
features  such  as  the  ADAS  interface,  the  tyre  pressure  monitoring  system  (TPMS)  and 
laser or LED lighting, which have been embedded in cars for around a decade but are not 
tested  by  standard  PTIs.  This  is  consistent  with  the  views  from  survey  respondents, 
especially  ministries,  road  safety  authorities  and  PTI  bodies,  which  considered  that  the 
current  RWP  and  its  objectives  address  the  technological  advancement  in  automated 

68 eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=PI_COM:C(2021)4992 
69 ACEA-report-vehicles-in-use-europe-2023.pdf  
70 In its position paper submitted alongside its response to the public consultation on RWP 

38 

 
 
systems only to a limited extent. The technology used in vehicles has surpassed what the 
current  framework  covers  and  new  rules  for  inspection  of  new  safety  systems,  such  as 
ADAS, are needed. Furthermore, since current tools like the OBD system do not fit some 
cars in circulation for diagnostic purposes, the scope of the RWP would also become more 
relevant should it be broadened to enable the inspection of new software and to improve 
testing facilities. According to the evidence gathered, the RWP intervention is currently 
not adapted to teleoperated and autonomously driving vehicles, as well as their sensors, 
radar  systems  and  cameras  that  act  and  function  in  network.  Concrete  testing  of  high-
voltage vehicles and their components is also currently missing. 

Relevance in view of environmental objectives 

The  RWP’s  objective  to  contribute  to  reduction  of  greenhouse  gases  and  air  pollutant 
emissions from road transport is still relevant in the context of the EU climate objectives 
and the ambitions put forward in the related key strategies, the European Green Deal71, the 
EU Zero Pollution Action Plan72, and at international level, the Sustainable Development 
Goals.  

The objective of identifying  gross emitters  through periodical  technical  inspections  and 
roadside  inspections  and  removing  them  from  road  traffic  contributes  to  the  emission 
reduction targets established by different EU instruments, such as the newly proposed Euro 
7 norms, the national emission reduction commitments for the main air pollutants set in 
Directive 2016/2284, and the stricter air quality standards recently proposed by the revision 
of Ambient Air Quality Directive73 .  

In the stakeholder consultations, most stakeholders maintained that the three Directives are 
still very relevant to the achievement of wider EU environmental policy goals, in addition 
to the overall improvement of road safety.  

With internal combustion engine vehicles becoming cleaner (as per the Euro norms), some 
of  the  tests  used  in  PTI  are  no  longer  sufficiently  sensitive  to  detect  emission  failures. 
Given the undetected problems for vehicles equipped with emission control systems, diesel 
particulate  filters  (diesel  Euro  5  and  6)  and  three-way  catalysts  (petrol  from  Euro  1), 
existing evidence supports the claim that the current testing procedures are not fit to meet 
the EU policy goals. Modern vehicle engines and exhaust gas systems have other critical 
detection criteria that are not covered by the currently prescribed test methods, and current 
PTI tools are not functional for measuring PN and NOx. Considering these shortcomings, 
the current RWP’s contribution to reducing the number of vehicles in circulation with high 
emissions has become less relevant. While some stakeholders suggested that DPF filters 
might reduce considerably particulate matter emission for Euro 5 categories or later, the 
measurement  of  nitrogen  oxide  emissions  or  PM/PN  values  for  new  cars  are  still  not 
covered by the current RWP. Additionally, there are currently no EU provisions for testing 
vehicles for NOx manipulation/defect  or manipulation/defect  of diesel  particulate filter. 
On  this  point,  many  stakeholders  expressed  interest  in  evolving  the  testing  of  engine 
management  and  exhaust  emission  control  systems  towards  updated,  more  sensitive 
measurement procedures. According to some consulted stakeholders, consideration should 

71 COM/2019/640 final 
72 COM/2021/400 final 
73 COM/2022/542 final 

39 

 
 
also be given to mandating that original equipment manufacturers (OEMs) provide type-
approval information for PTIs.  

Relevance in view of other technological developments 

The  evidence  and  stakeholder  views  gathered  suggests  that  there  have  been  numerous 
significant  changes  in  vehicle  technology  since  the  RWP  came  into  effect,  making  the 
current RWP not adapted to new developments and less relevant.  

Regarding vehicle software, the stakeholders in the survey (24 out of 49), especially among 
EU associations, but also ministries, road safety authorities and PTI bodies, pointed out 
that it is necessary to identify the vehicle software version in the PTI test, to ensure the 
vehicle updates have been installed. Still, 16 out of 49 respondents did not have an opinion 
on the matter; EU associations stated that only safety-critical and environmentally critical 
software  updates  are  relevant  to  PTI  and  RSI,  whereas  ministries  and  road  safety 
authorities pointed out that vehicle manufacturers should make available a database with 
the latest software versions for every vehicle. 

Furthermore, 26 stakeholders out of 49 in the survey, in particular EU associations and PTI 
bodies, opined that on-board fuel and energy consumption meter (OBFCM) devices, OBD 
(on-board diagnostics) and on-board monitoring (OBM) data should be registered centrally 
during PTI checks. Ministries and road safety authorities highlighted that OBFCM data 
collection during PTI is already established by the Implementing Regulation EU 2021/392. 
In relation with OBM, as proposed in Euro 7, the OBM sensors could be checked/compared 
with real tailpipe measuring during PTI. However, in contrast with the equipment installed 
in PTI stations, the OBM sensors are not submitted to any metrological control during the 
life of the vehicle. Moreover, EU associations stated that centrally registered OBFCM and 
PTI data can help detect tampering with the odometer or with OBFCM/OBM data itself, 
as it can allow for the easy analysis of the collected data and flagging of suspicious outliers.  

Finally, even though stakeholders’ opinion on the need for standards and regulations on 
mobile  vehicle  registration  documents  was  divided,  most  EU  associations  consulted 
considered  that  such  standards  are  needed.  EU  associations  and  vehicle  registration 
authorities expressed the view that vehicle registration documents must be readable in all 
Member States, and this is the reason why standards are very important, since documents 
which are only valid at national level have only limited value (Figure 9). 

Figure 9. Need for standards and regulations on mobile vehicle registration documents 
(n=49) 

Source: VVA et al. (2023), Evaluation support study, Survey results 

40 

 
 
 
5  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1  Conclusions 

The evaluation’s findings lead to several conclusions regarding the overall performance of 
the three Directives of the RWP, which can be grouped by evaluation criterion as follows: 

5.1.1  Effectiveness 

The evaluation is based on evidence available for the period between 2018 and 2021. At 
the  same  time,  it  should  be  borne  in  mind  that  Member  States  had  to  transpose  the 
provisions  of  the  RWP by  May  2017.  While  there  are  gaps  in  the  requirements  for  the 
Member States’ reporting on RWP, the evaluation considers the available implementation 
reports for the PTI and RSI Directive. While there was no sufficient quantified evidence 
which would allow to establish a clear link between roadworthiness testing and improved 
road safety, the evaluation analysis based on the examination of the available studies on 
safety  and  stakeholders’  input  combined,  suggests  that  vehicles  on  EU  roads  have 
generally  been  made  safer  through  the  introduction  of  common  standards  for 
roadworthiness testing, testing centres and personnel training, as well as by the adoption 
of standard rules for frequency, scope and methods for testing. 

Regarding the role of technical defects in road safety at both EU and national levels various 
estimations are available. The most comprehensive studies estimate that vehicle defects 
are a contributing factor between 6.5% to 12.6% of road crashes. The improved technical 
condition  of  the  vehicles  should  hence  contribute  to  increased  road  safety  in  terms  of 
numbers of avoided road crashes, injuries and fatalities, which has also been confirmed by 
the results of periodic technical inspections in selected countries, showing the link between 
improved technical condition of the vehicles and increased road safety. Moreover, given 
that the age of a vehicle was found to be an important factor which increases the risk of 
roadworthiness faults, and in the context where the average age of the EU vehicle fleet has 
increased in the recent years, the contribution of RWP to road safety objectives appears 
even more important. Most stakeholders consulted considered that PTIs and RSIs helped 
to some extent to reduce the number of vehicles in circulation with dangerous defects. 

Regarding the objective of the RWP to help reducing emissions, roadworthiness emission 
checks can identify high-emitting vehicles that are responsible for most of the air pollution 
from  traffic. However, the effectiveness  of the RWP was rather limited, especially  in  a 
fast-evolving  sector:  while  there  were  some  positive  experiences  with  adopting  stricter 
emission limits for diesel cars and for hydrocarbons of petrol cars, the current emissions 
requirements under PTI and RSI are no longer applicable and have to be updated. Basic 
tests for diesel engines are not able to accurately take emission measurements for Euro 5 
and Euro 6 vehicles, and they do not detect faults in newer diesel cars and older cars with 
missing catalysts. The opacity testing measurement is outdated as it no longer applies to 
new diesel vehicles in circulation and it does not accurately capture GHG, particle matter 
and NOx counts. Instead, PN measurement should be used as the control method for newer 
diesel cars to detect tampering with emission control systems, and remote sensing emission 
limits  should  be  set  for  each  type  of  vehicle  and  Euro  standard  to  standardise  remote 
sensing across the EU. To ensure adequate levels of accuracy and efficiency in detecting 
NOx emissions, it is necessary to have access to the vehicle itself and to reference values 
during the approval process, which is not the case today. 

41 

 
Regarding  the  improvement  of  the  exchange  of  information  on  testing  results  between 
actors  and  Member  States,  the  current  framework  for  information  exchange  is  not 
considered  as  successful.  Although  the  legislation  enables  data  exchanges  between 
Member State authorities, not all countries use this possibility. Even if the harmonisation 
of vehicle registration documents was made easier for citizens to register vehicles from 
other Member States  and EEA, there seems  to  be room for further improvement  in  the 
process to make it even easier. Moreover, there is no mutual recognition of PTIs across 
Member States. Currently, PTIs must be performed in the same country where the vehicle 
has been registered, which in practice limits the positive effects of the RWP on the free 
movement for EU citizens and the smooth functioning of the internal market. 

5.1.2  Efficiency 

Despite the lack of sufficient empirical data to perform a more robust cost-benefit analysis 
for the RWP, it is generally accepted by the stakeholders consulted that the benefits of its 
implementation  outweigh  the  associated  costs.  Representatives  of  Member  States’ 
authorities (ministries, road safety authorities) and EU associations mostly agreed that the 
costs/benefits ratio of PTI, RSI and registration documents are justified. Ministries and the 
road  safety  authorities  of  several  EU  Member  States  stated  that  implementation  of  the 
RWP has not caused significant administrative and adjustment costs as they already had a 
developed system of PTI and RSI. Nevertheless, opinions are divided on the level of costs 
involved in certain aspects of the RWP and some practical suggestions have been identified 
to reduce costs associated with its implementation. 

The major administrative challenges and related costs faced by Member States included 
the enforcement procedures, training of highly qualified inspection personnel, investments 
in necessary equipment  and materials, analysing statistical data from technical controls, 
and  monitoring  of  inspector  activities,  including  the  supervision  of  testing  centres  and 
verification of inspectors. To reduce administrative burden on national authorities, some 
best  practices  include  developing  e-PTI  (electronic  PTI)  based  ISO  standards,  which 
enable automatic real-time transmission of diagnostic data through the OBD connector and 
streamline procedures for monitoring the implementation of the RWP. 

In terms of the administrative burden RWP imposed on businesses and citizens, there were 
certain  requirements  which  were  considered  burdensome  for  citizens,  such  as  the 
requirement  for  citizens  to  present  their  registration  certificate  when  undergoing  re-
registration. This can be time consuming and add to the overall administrative burden faced 
by  citizens.  Also,  digital  (mobile)  vehicle  registration  documents  could  furthermore 
facilitate  the  digitalisation  of  the  vehicle  registration  and  data-keeping  processes  and 
reduce costs for citizens and businesses. 

5.1.3  Coherence 

The  evaluation  finds  that  there  is  consistency  between  the  RWP  Directives  and  the 
objectives  of  EU  road  safety  policy.  Periodic  technical  inspections  and  roadside 
inspections  are  considered  essential  instruments  in  the  policy  toolbox  for  achieving  the 
European  Commission’s  Vision  Zero  approach  on  fatalities  and  serious  injuries  on 
European roads by 2050.  

However, it appears that more consistency should be ensured between the type-approval 
regulation  and the RWP.  For example, in  the responses to  the survey, 92% (46, 25 ‘no 
responses’ or ‘Don’t knows’) believed that updating the PTI to cover the safety systems 

42 

 
introduced  by  the  General  Safety  Regulation  (GSR)  would  ensure  better  consistency, 
objectivity, and quality of roadworthiness testing. Also, the coherence between the RWP and 
relevant EU policies could be improved through the standardisation of safety relevant data 
regarding vehicles. In the response in relation to vehicle registration, one EU representative 
organisation74  called  for  a  standardised  exchange  of  data  between  type  approval  and 
licencing  authorities,  to  eliminate  the  need  to  carry  the  registration  certificate  in  the 
vehicle, and the possibility for relevant authorities and bodies to access vehicle registration 
data. Another stakeholder organisation75 also underlined the importance of access to in-
vehicle data and diagnostic information in an independent and reliable way, specifically 
the information made available in the context of EU type approval legislation, along with 
unrestricted  access  to  the  vehicle  data  and  software,  covering  the  whole  lifetime  of  the 
vehicle. 

 Regarding interventions at international level, the EU RWP measures should set standards 
for related legislation at UNECE level, as it is currently in the case of the recommendation 
on PN measurement. The RWP is  also  not  sufficiently  aligned with  the General  Safety 
Regulation (GSR) (EU) 2019/2144 regarding responsibilities for manufacturers during the 
vehicle’s  lifecycle.  Defining  responsibilities  more  clearly  and  mandating  that  relevant 
information is made available for PTIs across Member States for free could better address 
sovereign tasks and reduce procedural overlaps, thus improving the overall accuracy and 
efficiency of inspections. 

5.1.4  EU added value 

The  road  transport  and  the  automotive  industry  are  international  sectors,  therefore  a  certain 
minimum level of harmonisation in vehicle testing and exchange vehicle data between Member 
States is more effective than uncoordinated national approaches. While historically, the national 
practices differ, the EU level intervention on roadworthiness testing and vehicle registration 
documents brought benefits beyond those which would have been posssible at national or 
local level alone. The overwhelming majority of interviewed stakeholders agreed that if 
the RWP had not been implemented, the road safety policy and its implementation in the 
EU would be far more fragmented, with Member States taking different actions. The RWP 
sets  a  minimum  standard  for  all  Member  States  and  provides  a  basic  framework  for 
detecting  and  addressing  roadworthiness  defects,  ensuring  that  all  Member  States  take 
action to improve road safety. 

The  harmonisation  of  emission  standards  and  practical  implementation  to  test  these 
standards  at  EU  level  improves  the  level  playing  field  for  the  transport  of  goods  and 
passengers  in  the  EU,  as  companies  across  the  EU  must  comply  with  similar  technical 
roadworthiness  requirements  leading  to  similar  cost  for  vehicle  purchases  and 
maintenance. Since vehicles and pollution do not stop at the border, it makes sense for EU 
vehicles to meet the same emission standards throughout their lifetime operations. Further 
harmonisation of the minimum level PTI and RSI requirements in the revision of the RWP 
would be useful to improve consistency of laws, standards and practices within the EU. 
Common rules applied to testing modern vehicle technologies (EVs, ADAS, and the most recent 
emission control equipment), would on the one hand help Member States realise economies of 
scale,  and  on  the  other  hand  the  testing  equipment  manufacturers  could  operate  on  a  more 
homogenous market. There is also a scope to improve mutual recognition of PTI inspections 

74 CITA Home - CITA International Motor Vehicle Inspection Committee 

75 FSD German central agency for PTI 

43 

 
 
by  the  Member  States,  which  would  add  value  to  the  EU  internal  market,  benefit  the 
consumers and it would also help increasing vehicle safety and environmental protection. 

5.1.5  Relevance 

With regards to the relevance of the RWP for the current needs, all the objectives set out 
in the Directives are still recognised as relevant. With regards to the future needs, the RWP 
has the potential to continue to play an important role in monitoring emissions and ensuring 
road  safety.  However,  it  will  be  important  that  the  Directives  adapt  to  the  changes  in 
vehicle technology.  

The  relevance  of  the  RWP  has  been  diminished  in  recent  years  by  the  widening  gap 
between the existing roadworthiness requirements and the new systems installed in modern 
vehicles.  In  particular  on  advanced  driver  assistance  systems  (e.g.  ADAS),  Intelligent 
Transportation  Systems  (ITS),  human-machine  interface  (HMI)  and  electronic  safety 
features  the  three  Directives  do  not  seem  to  provide  a  sufficiently  comprehensive 
framework. Another area which is increasing in relevance is the roll-out of low and zero 
emission vehicles; the RWP currently does not cover specific testing protocols to ensure 
the  compliance  and  maintenance  of  electric,  hybrid  and  hydrogen  vehicles,  including 
software updates, in a safe and efficient manner. Also, parameters for technical inspections 
are not sufficiently updated to allow the efficient acquisition of important safety-related 
data and the monitoring of new sensors and functions. Beyond, according to the evidence 
gathered, the RWP intervention would not be adapted to teleoperated and autonomously 
driving vehicles. 

The  RWP’s  objective  to  contribute  to  emissions  reduction  from  road  transport  is  still 
relevant in the context of the EU climate and environmental objectives. However, some of 
the  tests  used  in  PTI  are  no  longer  sufficiently  sensitive  to  detect  emission  failures  in 
internal combustion powered vehicles. Modern vehicle engines and exhaust gas systems 
have critical detection criteria that are not covered by the currently prescribed test methods, 
and current PTI tools are not functional for measuring PN and NOx. Considering these 
shortcomings,  the  current  RWP’s  contribution  to  reducing  the  number  of  vehicles  in 
circulation with high emissions has become less relevant. Additionally, there are currently 
no  EU  roadworthiness  provisions  for  testing  vehicles  for  NOx  manipulation/defect  or 
manipulation/defect  of  diesel  particulate  filter.  Stakeholders  considered  that  if  the 
Directives are not adapted to modern driving features and safety systems, the gap between 
vehicle technology and testing techniques will widen excessively. 

5.2  Lessons learned 

Although EU roads are the safest in the world and road safety has improved significantly 
over the last decades, casualties of road crashes continue to represent a high cost to society.  

Defective  vehicles  may  not  always  be  detected,  as  some  categories  of  vehicles  are  not 
subject to PTI or RSI in some Member States, or the frequency or scope of the testing is 
not adapted to their higher safety and environmental risk. In addition, current test methods 
and procedures are not always capable of detecting defective or tampered vehicles and are 
not  designed  to  test  the most  recent  vehicles,  such  as  electric  vehicles  or  vehicles  with 
advanced driver assistance systems. At the other end of the spectrum, older vehicles (over 
10 years) are found to be defective more frequently than newer ones. This is a concern 
with the gradual ageing of the EU vehicle fleet.  

44 

 
In relation to emissions, there are still many vehicles with defective or tampered emission 
control  systems  that  go  undetected.  There  are  multiple,  readily  available,  and  cheap 
solutions to cheat existing emission control technologies, and the current testing (PTI and 
RSI) methods are not suited to measuring the emission performance of modern vehicles.  

Member States still report difficulties in effectively enforcing road safety measures in EU 
cross-border traffic and vehicle trade. These difficulties can be caused by Member States 
recording  different  sets  of  vehicle  data,  or  difficulties  for  competent  authorities  in 
accessing  vehicle  register  data  and  other  safety-relevant  information  of  vehicles, 
particularly  when  these  are  registered  in  another  Member.  These  difficulties  can  also 
negatively impact the fight against the widespread malpractice of odometer tampering.  

5.3  Robustness of the conclusions  

The evaluation is based on evidence available for the period between 2018 and 2021. At 
the  same  time,  it  should  be  borne  in  mind  that  Member  States  had  to  transpose  the 
provisions  of  the  RWP by  May  2017.  While  there  are  gaps  in  the  requirements  for  the 
Member States’ reporting on RWP, the evaluation considers the available implementation 
reports for the PTI and RSI Directive. In addition, it also takes into consideration results 
of the implementation assessment of the European Parliamentary Research Service (EPRS) 
from 2020, which established that the transposition of the RWP at national level has led to 
improved  harmonisation  of  procedures,  such  as  the  frequency  and  content  of  vehicle 
testing, and the provisions of the RWP Directives have enhanced the quality of periodical 
technical inspections and roadside inspections, as well as road safety standards.  

Regarding  the  contribution  of  the  RWP  to  road  safety,  the  evaluation  considered  all 
available  evidence  and  in  particular  corroborated  the  findings  from  desk  research  and 
various independent studies on the role of technical defects in road safety, the results of 
PTI in selected EU countries showing the link between improved technical condition of 
the  vehicles  and  increased  road  safety,  with  the  evidence  and  views  provided  by  the 
stakeholders,  which  confirmed  that  the  RWP  plays  a  central  role  in  maintaining  high 
vehicle  standards  and  improving  road  safety,  based  on  their  most  recent  practical 
experience with all three Directives of the package. It should be kept in mind though that 
the effectiveness of the RWP regarding road safety has to be considered in the context of 
an already high level of the roadworthiness testing legal framework and implementation in 
the EU, and it should  also  be assessed as  a  complementary tool to  relevant  road safety 
regulations  (such  as  EU  type-approval  Regulations  for  motor  vehicles)  and  other  road 
safety policy measures already in place. 

45 

 
 
 
ANNEX I: PROCEDURAL INFORMATION 

Lead DG, Decide Planning/CWP references  

The lead DG is Directorate General for Mobility and Transport (MOVE), Unit C2: Road 
Safety  

DECIDE reference number: PLAN/2021/10932  

This initiative was referred to in point 16 of the Sustainable and Smart Mobility Strategy. 
Action 7 in the Action Plan called for improved emission testing in roadworthiness tests. 

This initiative is included in the Commission Work Programme 202376, item 3 in Annex II 
(REFIT initiatives), under headline A – A European Green Deal. 

Organisation and timing  

The impact assessment and the ex-post evaluation of the Roadworthiness Package were 
performed in a back-to-back manner (i.e. the evaluation and impact assessment have been 
launched at the same time) in 2021-2023.  

The combined evaluation roadmap/ inception impact assessment was published on Have 
your say on 4 October 202177.  

The  ex-post  evaluation  and  the  impact  assessment  on  a  possible  review  of  the 
Roadworthiness Package were coordinated by an Inter-Service Steering Group (ISG). The 
Commission Services participating in the ISG were: Secretariat-General, Legal Service, 
Directorates-General GROW, RTD, CLIMA, ENV, JRC, CNECT, EMPL, JUST. The ISG 
met 6 times: 22 September 2021, 14 December 2021, 8 July 2022, 24 November 2022, 9 
October 2023 and 9 November 2023. It was consulted throughout the different steps of the 
evaluation  and  impact  assessment  process:  notably  on  stakeholder  consultation 
questionnaire and deliverables of the external support study and on the draft Staff Working 
Documents.  When  necessary  bilateral  discussions  were  organised  with  the  concerned 
services.  

Consultation of the RSB  

The  draft  impact  assessment  and  evaluation  reports  were  submitted  to  the  RSB  on  15 
November 2023 and were discussed by the Board on 13 December 2023. 

Evidence, sources and quality  

The impact assessment and evaluation are based on several sources, using both quantitative 
and  qualitative  data,  collected  from  Member  States,  industry,  consumer  groups,  NGOs, 
European Parliament etc.  
• Stakeholder consultation activities (see dedicated annex IV);  

76 2023 Commission work programme – key documents (europa.eu) 

77 Vehicle safety – revising the EU’s roadworthiness package (europa.eu) 

46 

 
 
 
• External support studies carried out by two independent consortia (the study supporting 
the evaluation was led by VVA et al. and the one supporting the impact assessment was 
led by Ricardo et al.). The external support studies will be published alongside this report. 
 • Commission experience in monitoring and implementing the Roadworthiness Package. 

47 

 
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

1  Process  

The starting point for the evaluation was the 2012 Impact Assessment accompanying the 
proposal for a revision of the three Directives included in the Roadworthiness Package. 
The IA has notably been used to define the intervention logic, the points of comparison, 
and the overview of costs and benefits.  

Against that background, this evaluation was based on a methodology consistent with the 
Better Regulation Guidelines and Toolbox, with the support of an external study. Further 
to the Call for evidence, the Commission launched the process for contracting the external 
support  study.  The  terms  of  reference  provided  a  draft  intervention  logic  and  draft 
evaluation  questions  to  address  the  five  evaluation  criteria:  relevance,  effectiveness, 
efficiency, and coherence and European added value, which were further refined during 
the evaluation. The support study was undertaken by a consortium led by VVA Economics 
&  Policy,  including  Transport  and  Mobility  Leuven  (TML),  TNO,  VUFO  and  the 
University of Leeds. 

The intervention logic diagram (see Annex V) helps capture the logic of the RWP and the 
causal chain linking problems, objectives, inputs and expected results. It provides the basis 
for the development of the evaluation matrix (see Annex VIII) which sets out the following 
aspects for each evaluation question:  

• Operational questions, breaking down the evaluation questions into smaller, measurable 
aspects.  

• Indicators (quantitative or qualitative), providing the measures/metrics that correspond 
to each operational sub-question,  

• Data sources & methods, identifying the sources of data and information used to inform 
the indicators and outlining the methodology used to answer the evaluation questions and 
form the conclusions.  

The evaluation matrix was reviewed several times during the study, taking into account 
Commission  inputs  as  well  as  evidence  collection  activities  (desk  research,  interview 
programme, survey responses and data requests), to reflect the identification and review of 
data sources, as well as updated evidence needs and gaps and the improved understanding 
of the mechanisms and structures leading to better targeted questions. 

2  Methodological framework 

2.1 

 Data collection  

The data collection was undertaken in the course of the whole evaluation process with a 
view to collate existing quantitative and qualitative evidence. A certain degree of flexibility 
was ensured to deal with unexpected issues arising throughout the data collection phase 
and in particular during the data analysis phase to cover any data gaps.  

Desk research  

The methodology used for the gathering of data consisted of collecting information from 
published sources at EU and Member States level regarding statistical and monitoring data. 
These included Eurostat and ACEA for vehicle fleet data, the EU CARE database for road 
crashes, complemented by two other datasets: GIDAS (which is broadly representative of 

48 

 
crashes in Germany) and IGLAD (which is an aggregation of various global databases and 
was  useful  to  extract  information  for  Austria,  Czechia,  France,  Greece,  Italy,  Sweden, 
Slovakia  and  Spain).  The  existing  evidence  provided  in  published  literature  played  an 
important role in supporting the evaluation in a number of thematic areas. An updated list 
of sources is provided in Annex IX of the support study.  

Field research – stakeholders consultation  

Important part of the data collection phase has been realised through various stakeholder 
consultation  activities, performed by the Commission  and the external  consortium. The 
design of the questionnaires and the specific questions addressed to the stakeholders groups 
were developed on the basis of the evaluation matrix.  

The Open Public Consultation (OPC) questionnaire was accessible on “Have Your Say” 
webpage from 6 July to 28 September 2022. 907 replies including 29 position papers were 
received;  they  were  carefully  reviewed  and  valuable  insights  and  perspective  were 
extracted and used during the evaluation. The factual summary report is available on the 
consultation page and further details on the OPC are presented in Annex IV. 

The  targeted  consultation  consisted  of  tailored-made  surveys  and  interviews  and 
complemented  the  data  gathered  through  desk  research  and  OPC  (the  latter  not  being 
representative).  

Two online surveys were launched at the beginning of the evaluation support study and 
targeted  the  stakeholder  groups  impacted  by  the  legislation:  on  one  side  the  EU 
associations,  consumer  organisations,  ministries  of  EU  Member  States,  road  safety 
authorities  and  vehicle  registrations  authorities;  and  on  the  other  side  the  PTI  bodies 
(centres  authorised  to  conduct  PTIs).  49  replies  were  received  in  total:  16  from  EU 
associations/consumer organisations/NGOs,  17 from  ministries and national  road safety 
authorities, 5 from vehicle registration authorities and 11 from PTI bodies. 

A number of 30 in-depth interviews with selected stakeholders allowed to explore specific 
questions regarding the RWP in a more profound manner thanks to their qualitative nature.  

2.2 

 Data analysis 

Safety 

To analyse the reduction of road fatalities and serious injuries in road transport during the 
RWP period the analysis relied on the EU CARE Database. Despite the fact that vehicle 
registration  year  was  missing  for  some  Member  States,  inconsistently  provided,  or 
incomplete which was a limitation, the complete data available and used for the analysis 
is a fair representation of the EU in terms of country sizes and geographical coverage. The 
CARE database does not contain information on contributory factors in crashes, so it was 
not possible to look directly at the role of vehicle faults in crash involvements. Therefore, 
the  overall  research  question  asked  whether  the  RWP  reduced  the  proportion  of 
involvements by older vehicles, by comparing the relative share of involvements of older 
vehicles in total involvements in the period before the implementation of the RWP. Data 
for the period between 2016 and 2021 (the last year with data available) was examined. 
Two categories were used to define older vehicles: vehicles aged 10 to 19 years at the time 
of  the  crash  and  vehicles  aged  20  years  or  more.  Involvement  by  vehicles  in  these 
categories was compared with total vehicle involvements. The results indicate that over 
the period analysed, vehicles aged 20 years or more are involved in a higher share of fatal 
crashes. 

49 

 
Emissions 

PTI aims to identify high emitters that are then taken out of circulation or repaired, in order 
to reduce the air pollutants from road transport.  

During the evaluation support study, data on exhaust emission in real driving conditions 
detected by remote sensing technology has been analysed. It has been estimated that the 
share of vehicles with malfunctioning emission technology ranges from a few percents to 
10%.  Nevertheless,  their  contribution  to  pollution  is  considerable  as  PM  and  NOx 
emissions  are  increasing  by  a  factor  of  10  to  100  for  these  vehicles.  High  emitters  can 
represent up to 80% of the total emission in PM, and up to 25% of the total emissions in 
NOx, for particular euro classes and vehicle categories.  

Detailed data available for 3 Member States show that for the years 2019-2021, an average 
of 0.7% of vehicles failed the emission test during PTI in Denmark, 0.9% for petrol engines 
and 0.4% for diesel engines in Finland and 0.62% for petrol engines and 0.36% for diesel 
engines in The Netherlands. 

50 

 
 
 
ANNEX III. OVERVIEW OF BENEFITS AND COSTS  

Table 9: Overview of costs and benefits identified in the evaluation 

Citizens/Consumers  

Businesses 

Administrations 

Quantitati
ve  

Comment 

Quantit
ative  

Comment 

Comment  

Qua
ntitat
ive 

Administrative 
costs 
(per year relative to the 
baseline) 

COSTS 

- 

- 

Part of the costs 
EUR  10  billion 
in  2019  were 
experienced  by 
businesses. 

EUR  10 
billion  in 
2019.  

This  covers 
both citizens 
and 
businesses. 
Only  part of 
these  costs 
was 
experienced 
by citizens.  

- 

- 

- 

- 

costs:  
Enforcement 
(costs  associated  with 
activities  linked  to  the 
implementation  of  an 
as 
initiative 
monitoring,  inspections 
and 
adjudication/ 
litigation) 

such 

Direct  benefits  (such  as 
improved  well  being: 
  in  pollution 
changes 
levels, 
safety,  health, 
employment;  market 
efficiency) 

EUR 13.4 
billion  in 
2019,  of 
which 
EUR 12.7 
billion 
external 
costs 
savings 

in 

-  MS  administrations 
faced  costs  related 
to  the  enforcement 
procedures, training 
of  highly  qualified 
inspection 
personnel, 
investments 
necessary 
and 
equipment 
materials, analysing 
statistical data from 
technical  controls, 
and  monitoring  of 
inspector  activities, 
the 
including 
supervision 
of 
testing  centres  and 
of 
verification 
inspectors 

BENEFITS 

- 

- 

- 

- 

The 
reduction  in 
external 
costs 
savings 
accidents 
and 
pollution 
represent 

for 

air 

51 

 
 
 
 
 
benefits  for 
the 
society 
at large.  

related  to 
accidents 
and  EUR 
0.7 
billion 
external 
costs 
savings 
related  to 
air 
pollution  

- 

- 

- 

- 

- 

- 

Indirect  benefits  (such 
as  wider 
economic 
benefits, 
macroeconomic 
benefits,  social  impacts, 
environmental impacts) 

52 

 
 
 
 
 
 
ANNEX IV. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

This stakeholder consultation synopsis report provides a summary of the outcomes of the 
stakeholder  consultation  activities  which  were  carried  out  as  part  of  this  back-to-back 
evaluation and impact assessment in view of a possible revision of the Roadworthiness 
Package  (RWP).  It  provides  a  basic  analysis  of  the  responses  of  stakeholder  groups 
involved in the consultation process and a summary of the main issues which they raised. 
The full  analysis  of the  consultation  results  is  presented in  the stakeholder consultation 
reports  annexed  to  the  two  external  support  studies. The  same  report  is  included  in  the 
evaluation SWD and in the impact assessment SWD, as an annex to both reports. 

Stakeholder involvement was vital for the evaluation and impact assessment in order to 
collect facts, data and opinions enabling the Commission to:  

•  On the one hand, assess the performance of the RWP against the five evaluation 
criteria,  identify  possible  issues  with  the  existing  legal  framework  and,  on  this 
basis, learn lessons for future action;  

•  On  the  other  hand,  (i)  substantiate,  validate  and  develop  the  problems  and  the 
underlying drivers, (ii) conceive corresponding policy objectives, (iii) elaborate a 
list  of specific possible policy measures and policy options and (iv) assess  their 
likely impacts on the various categories of stakeholders.  

This report also aims at informing stakeholders on how their input has been considered. 

This  document  should  be  regarded  solely  as  a  summary  of  the  contributions  made  by 
stakeholders  in  the  various  consultation  activities  on  the  back-to-back  evaluation  and 
impact assessment in view of a possible revision of the Roadworthiness Package (RWP). 
It cannot in any circumstances be regarded as the official position of the Commission or 
its  services.  Responses  to  the  consultation  activities  cannot  be  considered  as  a 
representative sample of the views of the EU population. 

1 

OVERVIEW OF CONSULTATION ACTIVITIES 

Consultation activities took place from October 2021 to August 2023.  

The  consultation  strategy  set  different  focuses  for  the  consultation  activities  for  the 
evaluation  and  the  IA  to  complement  each  other.  The  evaluation  related  survey  and 
targeted  interviews  gathered  stakeholders’  views  and  input  on  the  selected  evaluation 
questions and evaluation criteria. They are complemented with the views expressed at the 
OPC.  

The focus of the survey and interviews for the IA were on defining the different policy 
measures to meet the objectives set as part of the revision of the Roadworthiness Package, 
particularly  the  costs  and  potential  impacts  of  these  policy  measures.  The  underlying 
problem  drivers  of  the  RWP  were  extensively  discussed  with  stakeholders,  e.g.  in  the 
Roadworthiness  Expert  Group  and  are  also  a  result  of  the  stakeholder  consultation 
activities of the evaluation. Having said that, both the survey and interviews did briefly 
cover  the  baseline,  problem  drivers  and  objectives,  as  well  as  potential  impacts  of  the 
measures, so on all parts of the IA. 

The stakeholder consultation included the following activities:  

•  Targeted online survey for the evaluation: two online surveys were conducted 
targeting the stakeholders identified at the inception stage of the Evaluation Study 
and  covered  the  5  evaluation  criteria  of  relevance,  effectiveness,  efficiency, 

53 

 
coherence and EU value added. It was launched on 8 December 2022 and ran until 
20 January 2023. One survey targeted relevant EU associations, relevant ministries 
of EU Member States, road safety authorities and OEMs; In total 38 responses were 
received: 17 from ministries and road safety authorities, 16 from EU associations, 
consumer  organisations  and  NGOs,  5  from  vehicle  registration  authorities.  The 
other survey was addressed to PTI bodies and 11 responses were received.  

•  Targeted semi-structured interviews for the  evaluation sought to  explore the 
respondents’ views on the RWP for each evaluation question defined. They took 
place in the period between November 2022 and April 2023. The interviews were 
conducted  with  representatives  from  30  selected  technical  or  policy  related 
organisations  including  national  registration  authorities,  technical  inspection 
bodies,  the  Roadworthiness  Committee,  the  Roadworthiness  Expert  Group  and 
road  safety  and  environmental  NGOs.  They  were  selected  in  order  to  gather 
additional evidence, to ensure geographical  coverage and to increase the sample 
size in a group of interviewees by stakeholder type.  

•  Exploratory interviews for the IA. The aim of the exploratory interviews was to 
obtain early engagement with key stakeholders (including authorities, industry and 
user  representatives).  Introductory  calls  were  made  with  key  stakeholders,  i.e. 
CITA, EReg, CORTE and EGEA, to discuss the engagement of these organisations 
and their members with the initiative, including the distribution of the survey and 
the identification of potential interviewees. In addition, user groups, such as FIA 
(car drivers), IRU (lorry drivers) and FEMA (motorcyclists), were informed about 
the initiative and were interviewed as well.  

•  Targeted online survey for the IA. The focus  of the survey was on the policy 
measures  under  consideration,  particularly  the  details  of  the  measures,  their 
potential costs and savings and potential impacts. The survey was online between 
26 June and 14 August 2023. The survey targeted national authorities involved in 
inspection  activities  at  various  levels,  including  policy  development,  inspection 
supervision  and  enforcement,  and  industry  representatives,  including  those  that 
undertake  inspections  and  supply  garage  equipment  and  vehicles.  75  responses 
were received to the survey. 

•  Targeted  stakeholder  interviews  for  the  IA.  The  majority  of  interviews  were 
based on the interviewee’s survey response, with a focus on identifying information 
on  costs.  A  minority  of  interviews  were  undertaken  independent  of  a  survey 
response, e.g. for those organisations, such as users and research representatives, 
for which a survey was less relevant. The interviews began at the same time as the 
survey and continued until the end of August 2023. Overall, 37 interviews were 
undertaken to refine responses provided in the targeted online survey and to collect 
evidence from relevant stakeholders not covered in the survey.  

•  Evaluation roadmap / Inception impact assessment (IIA). As part of the initial 
feedback  mechanism,  stakeholders  had  the  possibility  to  provide  views  on  the 
combined  evaluation  roadmap  /  inception  impact  assessment  published  on  the 
“Have your say” webpage between 4 October and 1 November 2021. Responses 
were  received  from  210  respondents:  171  from  EU  citizens,  9  from  business 
associations, 6 from companies or business organisations, 6 from NGOs, 3 from 
consumer organisations, 3 from non-EU citizens, 2 from public authorities, 1 from 
academia  and  9  other.  174  responses  were  linked  to  a  campaign  from 
predominantly French citizens, while 36 were unique written responses, that were 
analysed individually. 

54 

 
•  Open  public  Consultation  (OPC)  questionnaire,  covering  both  the  IA  and  the 
evaluation,  was  accessible  on  “Have  Your  Say”  webpage from  6  July  to  28 
September  2022.  907  replies  were  received:  758  from  EU  citizens,  47  from 
companies or business organisations, 35 from business associations, 18 from non-
governmental  organisations  (NGOs),  10  from  non-EU  citizens,  10  from  public 
authorities,  5  from  trade  unions,  3  from  consumer  organisations,  2  from 
academic/research institutions, 1 from an environmental organisation and 18 other. 
731 of the responses received were part of a campaign from predominantly 
French citizens. The factual summary report is available on the consultation page.  

2 

STAKEHOLDER GROUPS CONSULTED 

This section provides a short overview of the main types of stakeholders identified and 
targeted as part of the consultation strategy. Overall, the consultation attracted interest from 
various types of stakeholders, which resulted in a good participation level and numerous 
contributions received. All identified stakeholder groups have been reached. However, the 
responses received are not representative of the EU population. 

Table  10:  Identification  of  key  stakeholder  groups  and  mapping  against  consultation 
activities. 

High-level 
stakeholder 
group  
Public authorities 
in charge of road 
safety  

Industry 
associations  and 
companies  

Representations 
of user groups  

Road  safety  and 
environmental 
NGOs  
Research / 
academia  

Citizens 

Description  

in 

involved 

Authorities  involved  in  different  activities  relating  to  the 
inspection, 
registration, 
vehicle 
including 
RWP, 
enforcement  and  policy. 
Initial  engagement  was 
undertaken  via  their  various  representative  associations, 
such as CITA, EReg and CORTE.  
Associations and companies involved in different aspects of 
RWP,  particularly  those 
inspections  and 
supplying equipment to garages. These were engaged with 
initially via their representative associations, such as CITA 
and EGEA. In addition, vehicle manufacturers and vehicle 
component suppliers were also contacted.  
Groups  representing  the  drivers  of  the  various  vehicles 
covered  by  the  RWP  were  engaged  with  to  identify  their 
views on the potential measures.  
The  views  of  specialist  NGOs  were  also  sought  to  ensure 
that the safety and environmental aspects of the measures 
were sufficiently considered.  
Interviews  were  undertaken  with  selected  road  safety 
academic experts.  

responded 

Citizens 
combined  evaluation 
roadmap/IIA  and  OPC  both  individually  and  as  part  of  a 
campaign, both from within and outside the EU.  

the 

to 

Stakeholder 
engagement activity  

Exploratory interviews  
Targeted surveys  
Targeted interviews  
OPC 
Call for Evidence 
Exploratory interviews  
Targeted surveys  
Targeted interviews  
OPC 
Call for Evidence 

Targeted interviews 
OPC 
Call for Evidence 
Targeted interviews  
 OPC 
Call for Evidence 
Targeted interviews  
 OPC 
Call for Evidence 
OPC 
Call for Evidence 

55 

 
 
 
 
3 

ANALYSIS OF THE KEY RESULTS OF THE STAKEHOLDER CONSULTATION  

This chapter presents key findings from the analysis of stakeholder contributions to the 
consultation process.  

3.1  FEEDBACK RECEIVED ON THE EU ROADWORTHINESS RULES BY EVALUATION 

CRITERIA  

Relevance 

•  Survey respondents and interviewed stakeholders generally consider that the scope 
and objectives of the RWP are relevant as a well-designed legislative package. 
Interviewed stakeholders overwhelmingly agree that the three Directives within the 
RWP are still thematically relevant to the wider EU policy goals. 

•  However  according  to  the  overwhelming  majority  of  survey  and  interview 
respondents,  there  have  been  numerous  significant  changes  in  vehicle 
technology since the RWP came into effect, which the current RWP does not 
account  for.  There  is  a  need  to  adapt  the  Directives  to  environmental  and 
technological  developments  and  digitalisation.  Additionally,  according  to  the 
respondents, the current measurement methods outlined by the RWP are considered 
inadequate  for  obtaining  accurate  readings  of  air  pollutants  emitted  by  vehicles, 
and traditional smoke opacity testing methods are deemed outdated and insufficient 
in detecting various pollutants. Some interviewed stakeholders also emphasise the 
need to increase the frequency of inspections for all vehicles due to the growing 
prevalence of shared mobility strategies and suggest clarifying certain aspects of 
testing to make it more targeted. 

•  Relevance  of  the  current  EU  rules  on  periodic  roadworthiness  testing  and 
technical  roadside  inspections  in  improving  road  safety.  Several  stakeholder 
categories,  including  academic  and  research  institutions,  public  authorities,  and 
consumer  organisations,  who  have  participated  in  the  OPC,  consider  the  rules 
relevant or very relevant in areas such as minimum standards for testing centres, 
facilities, and equipment, as well as categorising deficiencies during periodic tests. 
However, there are varying opinions from some responding NGOs, EU citizens, 
and environmental organisations, who perceive some aspects of the rules as less or 
not relevant. In particular, many respondents being part of the campaign consider 
the  periodic  testing  of  high-speed  tractors  and  heavy  motorcycles  and  applying 
different time intervals between periodic tests according to the age of vehicle and 
vehicle type as less or not relevant.  

•  Relevance  of  current  EU  rules  on  periodic  roadworthiness  testing  and 
technical  roadside  inspections  in  reducing  air  pollutant  emissions.  Business 
associations,  public  authorities,  and  trade  unions,  who  participated  in  the  OPC 
consider  the  rules  relevant  in  areas  such  as  establishing  minimum  standards  for 
testing  centres,  facilities,  equipment,  and  inspectors'  competence,  training,  and 
objectivity.  However,  there  are  varying  opinions  from  responding  EU  citizens, 
environmental  organisations,  and  some  public  authorities,  who  perceive  certain 
aspects of the rules as not relevant in reducing air pollutant emissions. In particular, 
many respondents being part of the campaign consider the rules related to periodic 
testing of high-speed tractors and heavy motorcycles as not relevant for the purpose 
of reducing air pollutant emissions. 

56 

 
•  Relevance  of  current  EU  rules  on  registration  documents  for  vehicles  in 
facilitating free movement of goods and people within the EU. The majority of 
the respondents, who participated in the OPC, consider the current EU rules to be 
relevant or very relevant in facilitating free movement, regarding the obligation on 
Member States to recognise roadworthiness certificates upon change of ownership. 
Views among those who responded being part of the campaign are more varied.  

Effectiveness 

•  Effectiveness of the current EU rules on periodic roadworthiness testing and 
technical roadside inspections in improving road safety and contributing to the 
reduction of road fatalities and serious injuries in road transport in  the EU. The 
majority of respondents, who participated in the OPC, view the current EU rules as 
effective  in  improving  road  safety  and  contributing  to  the  reduction  of  road 
fatalities  and  serious  injuries  in  road  transport  in  the  EU  in  areas  such  as 
establishing  minimum  standards  for  testing  centres,  facilities,  and  equipment, 
categorising deficiencies during periodic tests, obliging Member States to perform 
roadside tests on commercial vehicles, and implementing different time intervals 
based on vehicle age and type, except for periodic testing of high-speed tractors 
and  heavy  motorcycles  on  which  views  are  diverging.  The  respondents 
participating in the campaign, perceive the current EU rules on roadworthiness as 
less or not  effective in  in certain  aspects,  such  as periodic testing  of high-speed 
tractors  and  heavy  motorcycles,  and  minimum  standards  for  inspectors' 
competence,  training,  and  objectivity.  The  majority  of  survey  respondents  and 
interview  stakeholders  agree  that  PTIs  and  RSIs  helped  reduce  the  number  of 
circulating vehicles with dangerous defects. 

•  The  feedback  collected  from  survey  respondents  and  interviewed  stakeholders 
suggests that vehicles on the road are perceived to have generally been made safer 
through  the  introduction  of  common  standards  for  testing  centres  and  personnel 
training, as well as with the adoption of same rules for frequency, scope and method 
for vehicle testing. However, interviewed stakeholders acknowledge that reduction 
in road deaths witnessed over the past 10 years could be due to a combination of 
factors (e.g. gas prices, driver behaviour, infrastructure) and it is therefore difficult 
to determine how many accidents are directly caused by mechanical defects and 
how  many  of  the  lives  saved  and  injuries  avoided  are  specifically  linked  to 
PTIs/RSIs. 

•  Effectiveness  of  current  EU  rules  on  periodic  roadworthiness  testing  and 
technical  roadside  inspections  in  reducing  air  pollutant  emissions.  80  %  of 
public authorities, who have responded to the OPC, consider as effective the rules 
regarding minimum standards for inspectors' competence, training, and objectivity. 
Respondents in the OPC part of the campaign, have differing perspectives, with a 
majority of those respondents  viewing  the rules as not  effective for the periodic 
testing  of  high-speed  tractors  and  heavy  motorcycles  and  for  applying  different 
time intervals between periodic tests, according to the age of vehicles and vehicle 
type 

•  However, interviewed stakeholders also pointed out that not all deficiencies can 
effectively  be  detected  by  applying  the  current  technical  standards  for  vehicle 
inspections. Among the survey respondents and interviewed stakeholders, there is 
no clear-cut  opinion on the extent to  which the provisions of the RWP Package 
have  contributed  to  reduced  air  pollutants  from  road  transport.  According  to 

57 

 
surveyed ministries and road safety authorities, vehicles that have been tampered 
with  defects  which  are  not  covered  by  the  EOBD  system  or  those  specifically 
related to NOx emissions will not necessarily be detected by the current EU PTI 
regimes. 

•  Effectiveness  of  current  EU  rules  on  registration  documents  for  vehicles  in 
facilitating free movement of goods and people within the EU. The majority of 
respondents to the OPC from public authorities and business associations find the 
current  EU  rules  effective  in  facilitating  free  movement.  On  the  other  side,  the 
participants  in  the  campaign  have  diverging  opinion  on  the  effectiveness  of  the 
current  EU  rules  on  registration  documents  for  vehicles  in  facilitating  free 
movement.  

Efficiency 

•  Cost-effectiveness  of  the  roadworthiness  rules.  Respondents  in  the  targeted 
survey and the interviews deemed the benefits associated with its implementation 
generally proportionate to the costs, especially with regards to the improvement 
of air quality. This is in line with the views expressed by the survey respondents, 
who consider that the implementation of the RWP has generated limited extra costs 
for  authorities,  citizens,  and  businesses.  PTI  inspections  have  not  become  more 
expensive,  and  the  use  of  the  EUCARIS  system  is  cost-effective  according  to 
survey respondents. However, certain provisions like OBD checks have incurred 
costs  for  citizens.  Ministries,  road  safety  authorities,  and  EU  associations 
participating in the survey agree that the benefits of the RWP in terms of road safety 
and  reduced  air  pollution  justify  the  costs.  EU  associations  also  emphasise  its 
potential in combating illegal pollution and the human costs of air pollution. 

•  However,  while  some  respondents  did  not  consider  RWP  provisions  as 
extraordinarily expensive, others mentioned that the costs associated with installing 
and upgrading testing equipment for testing stations is high.  

• 

Interviewed stakeholders consider the administrative burden generated by the three 
Directives to be smaller for businesses and citizens than for public authorities. 

•  Ministries and PTI bodies, who have participated in the survey, acknowledge that 
the RWP and its implementing acts have created to some extents administrative 
burden  for  public  administration.  They  emphasise  the  need  for  digitalisation  in 
vehicle  re-registration  to  reduce  costs  and  administrative  workload,  particularly 
through  data  exchange  and  document  harmonisation.  Vehicle  registration 
authorities who have responded to the survey, call for improved legal provisions 
and  digitalisation  to  streamline  the  process.  Additionally,  EU  associations 
responding  to  the  survey  propose  providing  type-approval  information  to  PTI 
centres without charge. 

•  Most respondents of the survey did not express an opinion on whether the RWP 
package  and  its  implementing  acts  have  imposed  administrative  burdens  on 
businesses. Survey respondents emphasised the importance of mutual recognition 
to  enhance  cost  effectiveness 
inspections.  They  also  recommended 
implementing systems like Car-Pass in Belgium on an EU-wide scale to address 
odometer fraud. Furthermore, it was highlighted by them that a well-assessed test 
methodology  is  crucial  to  avoid  inaccurate  outcomes  in  PTI  and  ensure  a 
standardised approach to testing procedures and equipment. 

in 

•  The  majority  of  survey  respondents  did  not  express  an  opinion  on  the 
administrative burden imposed by the RWP Directives on citizens. However, EU 

58 

 
associations  suggested  that  implementing  mobile  vehicle  registration  documents 
could  enhance  the  digitalisation  of  registration  and  data  management  processes, 
resulting in reduced costs for citizens. 

Coherence 

•  While the Directives comprised in the RWP are deemed internally coherent by 
the  interviewed  stakeholders,  a  few  inconsistencies  between  the  RWP  and 
other road safety legislations have been identified by interviewed stakeholders. 
As a response to the survey a similar message was passed by responding ministries, 
road safety authorities, and EU associations, who acknowledged that to some extent 
there are inconsistencies, overlaps, and gaps between the RWP Directives and other 
EU and international interventions. 

•  According to the interviewed stakeholders the lack of harmonisation between the 
PTI  and  the  type  approval  legislations  makes  it  difficult  to  perform  thorough 
inspections,  as  the  number  of  automated  devices,  sensors  and  safety  features  is 
growing faster than the PTI operators’ ability to check them.  

•  The need for consistency between periodic technical inspection (PTI) requirements 
and type approval regulation was also emphasised by the respondents of the OPC. 
PTI should not go beyond what is specified in type approval regulations according 
to  their  views.  Moreover,  according  to  OPC  respondents,  Member  States  have 
different conditions and contexts for L-category vehicles, and they should have the 
flexibility to determine effective ways to reduce accidents. 

•  The  Registration  Directive  and  the  Type  approval  Regulation  are  not  fully 
consistent in the view of interviewed stakeholders: the fact that each country has 
the possibility of allowing a national type approval with more flexibility than EU 
type approval gives some Member States the chance to be less strict than others, 
thus raising road safety issues. 

•  According  to  the  interviewed  stakeholders  the  General  Safety  Regulation  could 
better align with the RWP: for instance, the GSR identifies more responsibilities 
for  manufacturers  during  the  vehicle’s  lifecycle  than  those  foreseen  by  the  PTI 
legislation. 

•  The  feedback  received  from  interviewed  stakeholders  points  to  a  lack  of  data 
coherence,  whereby  no  one  has  a  holistic  view  regarding  the  whole  life  of  the 
vehicle: from vehicle definition to vehicle scrapping. 

•  According to the OPC respondents, standardisation of rules among EU countries is 
considered  essential  for  the  effectiveness  of  the  EU  technical  control  package. 
Disparate  rules,  particularly  concerning  the  approval  of  controllers,  need  to  be 
addressed in their view. 

EU added value 

•  The EU rules on roadworthiness have added value for citizens and businesses 
compared to what could be achieved by Member States at national and/or regional 
and  international  level  according  to  the  respondents  to  the  OPC.  There  is 
disagreement among EU citizen responding to the OPC whether the EU rules on 
roadworthiness  provide  added value compared to what  could  be achieved at  the 
national,  regional,  and  international  levels.  However,  there  is  a  significant 
agreement among academic and research institutions, who have participated in the 
OPC that the EU rules do offer added value for citizens and businesses. 

59 

 
•  The interviewed stakeholders widely acknowledged the added value of the three 
Directives in their contribution towards the harmonisation of roadworthiness rules 
among  Member  States.  By  setting  up  minimum  standards  for  carrying  out 
periodical  technical  inspections  and  roadside  inspections,  the  RWP  sets  up  a 
common  framework  to  identify  vehicle  deficiencies,  prevent  accidents,  reduce 
vehicle emissions and promote fair competition in the field of road transport. 

•  When expressing views in the survey, ministries, road safety authorities, and PTI 
bodies considered that additional EU action is necessary to enhance the RWP and 
achieve  the  objectives  of  reducing  fatalities,  serious  injuries,  and  improving  air 
quality through PTI and RSI inspections in the EU. They emphasised the need for 
minimum  requirements  across  Member  States  to  ensure  effective  PTI  and  RSI 
contributing to road safety and air quality. 

•  The overwhelming majority of interviewed stakeholders agree that if the RWP had 
not  been  implemented,  the  road  safety  scenario  in  the  EU  would  be  far  more 
fragmented, with Member States taking greatly differing actions. 

3.2  FEEDBACK RECEIVED ON THE PROBLEM DEFINITION 

In the OPC, respondents were asked for their views on three problems that the revision of 
the RWP could address. A majority of respondents – between two-thirds and four-fifths in 
each case – supported a revision of the EU’s roadworthiness rules addressing each of the 
specified  problems.  The  problem  that  received  most  support  was  the  need  to  address 
vehicles circulating on the roads with defects or tampered components (78%; 123, six ‘no 
responses’ or ‘Don’t knows’), followed by methods for PTI of vehicles to test electronic 
safety and driver assistance systems in vehicles (74%; 116, seven ‘no responses’ or ‘Don’t 
knows’). Two thirds (67%; 100, 14 ‘no responses’ or ‘Don’t knows’) of respondents also 
believed that a revision to the legislation should address the availability of relevant vehicle 
data to enforcement authorities in the EU Member States in cross-border traffic. Themes 
raised in response to the open questions included that it was important to update inspections 
to reflect changes to vehicles and their technology, that it was important to have access to 
in-vehicle data to support inspections, that more action was needed to address tampering 
and that it was important to support public authorities in the inspection of foreign vehicles 
on  their  roads.  Others,  while  recognising  that  changes  to  inspections  were  needed, 
underlined that inspections had to remain affordable for consumers.  

The survey produced similar results of support for the revision of the EU’s roadworthiness 
rules addressing the different identified problem areas, see Figure 10.  

60 

 
Figure 10: Survey results on stakeholders’ views on identified problems.  

Source: Ricardo et al. (2023), Impact assessment support study, survey results  

In the survey, respondents were asked for their views on more detailed problem areas, and 
their associated drivers and on three Specific Objectives (SOs):  

•  SO1:  Adapt  testing  to  today's  and  tomorrow's  vehicles  (improve  consistency, 

objectivity and quality) 

•  SO2:  Significantly  reduce  fraud  and  tampering  (of  safety  and  emission  control 

systems) and improve the detection of defective vehicles)  

•  SO3: Improve  electronic storage and exchange of relevant  vehicle identification 

and status data.  

There was a high level of agreement – around two thirds or more – for each set of problems 
and  problem  drivers,  and  overwhelming  support  (at  least  89%)  for  each  of  the  specific 
objectives.  

Figure 11. Survey results: Stakeholders’ views on identified specific objectives 

Source: Ricardo et al. (2023), Impact assessment support study, survey results  

Respondents  to  the  IIA  made  a  number  of  general  comments  about  the  revision.  A 
common theme that was raised by those responsible for inspections was the importance of 
more consideration being given to coordinating between type approval and roadworthiness 
legislation,  and  the  importance  of  maintaining  the  independence  of  inspection 
organisations and inspectors from other parts of the automotive trade, including repair and 
maintenance.  The  importance  of  a  more  consistent  approach  to  roadworthiness  testing 
across the EU was also mentioned.  

61 

 
 
 
3.3  FEEDBACK RECEIVED ON THE BASELINE/ EXISTING LEGISLATION  

In  their  response  to  the  survey  and  interview  questions,  respondents  were  often  split 
between  those  who  believed  that  the  different  factors  listed  had  had  a  high  impact  on 
various aspects of roadworthiness, and those who believed that the impact had been low. 
The question to which respondents were mostly having a common view with 75% agreeing 
(51 of 75; seven ‘Don’t knows’ or no responses) – was in relation to the belief that the 
enforcement of roadworthiness legislation had had a high impact on the number of unsafe 
vehicles on the EU’s roads since 2014. The majority (60%; 40 of 75; eight ‘Don’t knows’ 
or no responses) of respondents also felt that technological and market developments had 
had a high impact on the number of unsafe vehicles on the EU’s roads since 2014. On the 
other hand, a majority of respondents believed that technological and market developments 
had had a low impact on reducing the number of vehicles with tampered or defective noise 
control systems (77%; 46 of 75; 15 ‘Don’t knows’ or no responses), or tampered odometers 
(64%; 39 of 75; 14 ‘Don’t knows’ or no responses), since 2014. The responses relating to 
the impact on the number of vehicles with tampered or defective emissions control systems 
and the vehicle re-registration process were much more split between those who felt that 
the impact had been high or low.  

Respondents were asked to explain their responses. A common reason listed amongst those 
responsible for inspections, as well as users, was the need to update PTIs (and so the PTI 
Directive) to take account of the way in which vehicles have developed and will continue 
to develop. Many of these respondents also underlined the problem of detecting tampering 
during a PTI, particularly tampered odometers.  

3.4  FEEDBACK RECEIVED ON POSSIBLE SOLUTIONS 

Policy measures: Scope of PTI Directive  

The first group of policy measures related to the potential extension of the scope of the 
PTI Directive. In their responses to the IIA, various industry respondents, including those 
organisations responsible for inspections, called for the extension of the PTI Directive to 
cover all vehicles that are able to use roads. For example, In the response for IIA, CITA 
called for the extension of the scope of PTI to L-category vehicles and light trailers, as it 
had undertaken a study that concluded that this would have a positive cost-benefit impact; 
it also specified its proposed frequency for inspecting these vehicles. The French National 
Council  of  Automotive  Professions  (Conseil  national  des  professions  de  l'automobile; 
CNPA)  and  GOCA  Vlaanderen  also  supported  extending  the  scope  of  PTI  to  these 
vehicles.  The  Portuguese  National  Association  of  Automobile  Inspection  Centres 
(Associação Nacional de Centros de Inspeção Automóvel; ANCIA) called for testing to be 
mandatory for all motor vehicles used on public roads. Inspection company Applus also 
suggested that the general rule should be that all vehicles that can circulate on roads in the 
EU  should  be  covered  by  the  PTI  Directive,  although  they  proposed  allowing  some 
exceptions for certain L-category vehicles where alternative measures were in place. The 
European  Garage  Equipment  Association  (EGEA)  also  underlined  the  importance  of 
extending roadworthiness testing to all road transport vehicles.  

On the other hand, various motorcycle users’ groups that submitted contributions to the 
IIA argued against the mandatory extension of the scope of the PTI to motorcycles, in line 
also with the responses from the campaign. The Federation of European Motorcyclists’ 

62 

 
 
Associations (FEMA) argued that the evidence was that the technical state of motorcycles 
only played a marginal role in accidents involving motorcycles. 

In the OPC, among the respondents not linked to the campaign, there was a small majority 
that supported extending the scope of the PTI Directive to cover L-category vehicles (53%; 
73, 25 ‘no responses’ or ‘Don’t knows’), whereas again the responses that were part of the 
campaign were against such an extension to motorcycles.  

Figure 12. Survey responses: In your view what would the contribution of this measure be 
to: 

Source: Ricardo et al. (2023), Impact assessment support study, survey results  

Figure  13.  Survey  responses:  In  your  view,  to  which  categories  of  motorcycle  should 
mandatory PTI be extended? (multiple responses possible): 

Source: Ricardo et al. (2023), Impact assessment support study, survey results  

In the survey,  respondents  were  asked  about  different  potential  measures to  extend the 
scope of the PTI Directive. For each of the potential measures, around two thirds or more 
of the respondents believed that the respective measure would contribute to a high level to 

63 

 
 
 
 
 
delivering Specific Objective 2, i.e. extending the scope to motorcycles (80%; 41, 24 ‘no 
responses’  or  ‘Don’t  knows’);  agricultural  and  forestry  tractors  (78%;  31,  35  ‘no 
responses’  or  ‘Don’t  knows’);  and  light  trailers  (66%;  27,  34  ‘no  responses’  or  ‘Don’t 
knows’).  In  the  survey  and  interviews,  it  was  noted  that  many  Member  States  already 
required a PTI for motorcycles, tractors and/or trailers. Some potential challenges of this 
measure were mentioned by the respondents, including the distance that would need to be 
travelled to  take motorcycles and tractors for an inspection at  an inspection centre, and 
whether  a  PTI  should  be  required  for  tractors  that  were  not  used  on  public  roads.  In 
addition,  for  the  lightest  trailers  (O1),  it  was  questioned  whether  a  PTI  was  needed  for 
these, due to the way in which these were used, and also due to the fact that these trailers 
are not registered in some countries, such as the Netherlands and France.  

In  the  responses  to  the  OPC,  SMEs  who  had  responded  were  much  less  supportive 
extending the scope of the PTI Directive to motorcycles than large enterprises participating 
in the OPC, with 38% (eight) not supporting it, compared to no large enterprise. In the 
response to the survey and interviews, the fear was expressed that costs for SME inspection 
companies could increase, if they had to buy more equipment, or if SME rental companies 
had to have their vehicles tested more often.  

Policy measures: Frequency of PTI tests  

The second group of measures considered in the survey and interviews covered measures 
to  increase the  frequency of testing for certain  vehicles.  In the  survey,  more than two 
thirds of respondents believed that four of the measures would contribute to a high level to 
delivering  Specific  Objective  2,  i.e.  an  annual  PTI  for  N1  vehicles  (70%;  30,  32  ‘no 
responses’ or ‘Don’t knows’), an annual PTI for vehicles over 10 years olds (78%; 39, 25 
‘no responses’ or ‘Don’t knows’), a mandatory PTI for crashed vehicles with significant 
damage (70%; 33, 28 ‘no responses’ or ‘Don’t knows’) and for vehicles with significant 
modification  (67%;  32,  27  ‘no  responses’  or  ‘Don’t  knows’).  On  the  other  hand,  a 
significant majority of respondents (85%; 34, 35 ‘no responses’ or ‘Don’t knows’) believed 
that the remaining measure, a simplified PTI for vehicles that had recently passed an RSI, 
would have a low contribution to delivering Specific Objective 2.  

In the IIA response, CITA called for an increased frequency of PTI for some vehicles. For 
example, they supported annual tests for vehicles over 12 years’ old, as the number of these 
was increasing in the EU and they would experience more frequent defects as they aged. 
GOCA Vlaanderen called for more frequent PTIs for certain vehicles, such as N1 vehicles 
and vehicles of more than 10 years’ old. The EGEA also mentioned possibly increasing 
the frequency of inspections for high mileage vehicles. The French CNPA and a French 
inspection company called for the alignment of the frequency of testing of N1 vehicles, 
with those of N2 and N3 vehicles, arguing that in France, where N1 vehicles are tested at 
the same frequency as cars, they already often had many deficiencies by the time of their 
first PTI. The Spanish Association of PTI service providers (AECA-ITV) called for annual 
PTIs  for  all  cars,  light  commercial  vehicles  and  L-category  vehicles.  The  Portuguese 
ANCIA  also  called  for  an  increased  frequency  of  testing  for  vehicles  used  for  shared 
mobility  or  for  public  transport  services.  They  also  called  for  a  mandatory  PTI  after  a 
vehicle had been in an accident affecting its main safety components, which should have 
the active involvement of insurers, and on the transfer of ownership of a vehicle. Inspection 
company Applus also called for a mandatory PTI after a vehicle had been in an accident 
(as reported by an insurer), and on the transfer of ownership of a vehicle. Finally, they 
recommended  that  a  quality  standard  for  inspection  entities  and  supervisory  bodies  be 
created to improve vehicle inspection and to make this more consistent across the EU.  

64 

 
A  common  argument  in  favour  of  more  frequent  testing  for  N1  vehicles,  which  were 
mentioned  in  different  consultation  exercises,  wase  that  such  vehicles  were  used 
frequently, and often experienced a number of technical issues by the time of their first 
PTI, although other respondents were not convinced of the added value of this measure. 
For older vehicles, it was widely suggested that these deteriorate more quickly than newer 
vehicles, and so should be tested more frequently. The main argument against having a 
simplified PTI for vehicles that had recently passed an RSI was, that it was not possible to 
test a vehicle in an RSI in the same way as it was in a PTI  -while the potential cost of 
setting up a system to record and exchange this information was noted-, as was the time 
that would be needed to amend each PTI to the take account of the recent RSI history of 
the vehicle. In relation to requiring a mandatory PTI for crashed vehicles with significant 
damage  and  for  vehicles  with  significant  modification,  challenges  were  identified  in 
relation to who makes the respective judgements and how the information is exchanged. 
In  addition,  some  respondents  considered  that  a  standard  PTI  was  not  sufficient  to 
determine the roadworthiness of some crashed or modified vehicles.  

Policy measures: Mutual recognition of PTI certificates  

The third set of measures included two alternative approaches to enable the recognition of 
PTI certificates in other countries, i.e. other than the one in which the PTI was undertaken. 
In  the  OPC,  a  majority  of  respondents  (63%;  97,  11  ‘no  responses’  or  ‘Don’t  knows’) 
agreed with the proposal that measures were needed to enable a vehicle owner to obtain a 
valid roadworthiness  certificate, to  be accepted throughout the EU, in a  Member State 
other than the Member State of registration of the vehicle. In the survey, respondents were 
split on the extent of the contribution of each of the two measures to Specific Objective 3. 
A marginal majority (51%; 19, 38 ‘no responses’ or ‘Don’t knows’) felt that requiring the 
mutual  recognition  of  PTI  certificates  under  certain  conditions  would  have  a  high 
contribution to Specific Objective 3, whereas a minority (38%; 12, 43 ‘no responses’ or 
‘Don’t knows’) felt that way about mutual recognition under bilateral agreements.  

In responses to the variation consultation exercises, users and those not directly involved 
in inspections tended to be more in favour of the mutual recognition of PTI certificates 
under  certain  conditions,  although  some  recognised  that  the  mutual  recognition  under 
bilateral agreements would be a good first step. However, those more actively involved 
with  inspections  were  concerned  that  the  extent  of  the  variation  between  the  approach 
taken to PTIs in different Member States meant that mutual recognition would be difficult 
and potentially lead to adverse effects on safety, unless mutual recognition was the subject 
of a bilateral agreement. Linked to this, concerns were also raised that mutual recognition 
without the increased harmonisation of PTIs would lead to “PTI tourism”, where drivers 
had their vehicles tested in countries where it was easier to pass a PTI.  

Policy measures: Electronic roadworthiness certificates  

The  fourth  set  of  measures  consisted  of  a  single  measure,  i.e.  require  that  the 
roadworthiness  certificate  is  issued  in  an  electronic  format.  In  their  responses  to  the 
survey, the overwhelming majority of respondents (94%; 49, 23 ‘no responses’ or ‘Don’t 
knows’) believed that this measure would have a high contribution to addressing Specific 
Objective 3, with a majority of these (63%; 33) believing that a paper version should still 
be  available  on  request.  In  their  responses  to  the  survey  and  interview,  various 
respondents underlined their support for this measure, and for the increased digitalisation 
of  all  aspects  of  the  roadworthiness  testing  process  more  generally,  due  to  its  potential 

65 

 
 
benefits for efficiency, the environment (less paper use), enforcement and in potentially 
opening the door for new services. The importance of retaining the option to have a paper 
copy of the certificate was underlined, so as not to exclude owners who were less digitally 
literate. The importance of having a standardised format for the electronic roadworthiness 
certificate was also a common remark of the respondents. A potential challenge of such 
digitalisation was identified for SMEs that undertake PTIs in some countries, if they were 
not yet digitally connected to the agency that oversaw inspections.  

Policy measures: Content of PTI tests  

The  fifth  group  covered  measures  to  improve  the  current  PTI  test  requirements  and 
procedures. In their responses to the OPC, a small majority (60%; 91, 13 ‘no responses’ 
or ‘Don’t knows’) was in favour of measures to specifically tackle noise-related tampering 
/ non-compliance problems in vehicles inspected at the roadside. SMEs responding to the 
OPC were less supportive of this measure, with 29% (six) not supporting it, compared to 
no large enterprise among the responding large enterprises.  

In the survey, around two thirds or more of respondents believed that the measures would 
contribute  to  delivering  the  respective  Specific  Objectives  to  a  high  level,  with  one 
exception.  The  measure  that  the  vast  majority  (91%;  50,  20  ‘no  responses’  or  ‘Don’t 
knows’) thought would contribute at a high level to achieving Specific Objective 1 was to 
require  the  training  of  PTI  inspectors  to  inspect  electric  vehicles.  Around  two  thirds 
thought that advanced noise testing for motorcycles (65%; 28, 32 ‘no responses’ or ‘Don’t 
knows’) and more advanced testing of braking for HDVs (69%; 27, 36 ‘no responses’ or 
‘Don’t knows’) would contribute to Specific Objective 2 at a high level. The response was 
more  ambivalent  with  respect  to  the  contribution  of  advanced  testing  of  advanced 
headlamps, as only a slight majority (52%; 23, 31 ‘no responses’ or ‘Don’t knows’) thought 
that this would make a contribution to addressing Specific Objective 2, although a majority 
(79%; 37, 28 ‘no responses’ or ‘Don’t knows’) thought that this measure would address 
Specific Objective 1 at a high level.  

More detailed responses in both the survey and interviews regarding the advanced noise 
testing for motorcycles ranged from that this was already done in a number of countries, 
such as Spain, to a concern that such tests would not be effective, as users could remove 
any tampered devices before the PTI. The latter responses came from national authorities, 
inspecting companies and user groups, although some felt that such adaptation prior to the 
PTI  was  still  an  additional  burden  for  users.  With  respect  to  the  advanced  testing  of 
advanced headlamps, some, such as the FIA, were not yet clear of the scale of the problem, 
whereas others, such as CITA, argued that such testing was not yet possible. On the other 
hand, in some countries it was considered that such tests were already undertaken, e.g. in 
Germany and Belgium, using a range of different methods. Some respondents noted that 
there  could  be  additional  costs  for  SMEs  resulting  from  these  measures,  if  a  measure 
required  new  equipment  or  additional  training,  particularly  in  countries  with  a 
decentralised testing system, such as the Netherlands.  

The introduction of new PTI test requirements and procedures  was the subject  of the 
sixth group of measures. In the responses to the OPC, around two thirds of respondents 
supported similar measures to those covered in the survey and interviews. For example, 
70% (106, 13 ‘no responses’ or ‘Don’t knows’) supported methods to test the functioning 
of safety-relevant electronic components, advanced driver assistance systems (ADAS) and 
automated functions being included in the revision of the PTI Directive, with 66% (100, 
12  ‘no  responses’  or  ‘Don’t  knows’)  supporting  the  inclusion  of  new  methods  to  test 
vehicles  with  alternative  powertrain  technologies  (hybrid,  full-electric,  hydrogen)  and 

66 

 
64%  (96,  13  ‘no  responses’  or  ‘Don’t  knows’)  new  methods  for  measuring  exhaust 
emissions, for example particle number (PN) and nitrogen oxides (NOx). Many responses 
to the IIA also called for similar measures.  

In  the  responses  to  the  survey,  at  least  80%  of  respondents  thought  that  the  respective 
measures would address the specified Specific Objectives, e.g. 92% (46, 25 ‘no responses’ 
or ‘Don’t knows’) believed that updating the PTI to cover the safety systems introduced 
by the General Safety Regulation (GSR) would address Specific Objective 1 to a high level 
and 88% (45, 24 ‘no responses’ or ‘Don’t knows’) felt the same way about adapting the 
PTI  to  the  particularities  of  EVs  and  hybrids.  Similar  proportions,  81%  (43,  22  ‘no 
responses’  or  ‘Don’t  knows’)  for  mandatory  PN  counting  and  82%  for  requiring  NOx 
testing according to the JRC methodology, thought that these measures would address both 
Specific Objective 1 and Specific Objective 2 to a high level. In the open responses to the 
survey and the interviews, there was some concern regarding the feasibility of applying 
NOx testing according to the JRC methodology in northern Member States, particularly the 
requirement that testing be undertaken when the vehicle has a warm engine. Again, there 
were some concerns about the impact of any additional costs from these measures on SMEs 
that undertake inspections, particularly where the PTI system was decentralised.  

Policy measures: Scope of RSI Directive  

The seventh set of measures focused on extending the scope of RSIs. In the responses to 
the  OPC,  there  was  a  high  level  of  support  for  mandatory  checks  during  roadside 
inspections of commercial vehicles to ensure the safe securing of cargo (70%; 99, 22 ‘no 
responses’ or ‘Don’t knows’). However, there was only a marginal majority in favour of 
extending  the  rules  to  other  vehicles,  (e.g.,  light  commercial  vehicles,  and  passenger 
vehicles,  including  cars,  powered  two-  and  three-wheelers  (N1,  M1  and  L-category 
vehicles) (51%; 77, 14 ‘no responses’ or ‘Don’t knows’). In particular, respondents who 
were SMEs were much less supportive of this measure, with 38% (eight) not supporting 
it, compared to no large enterprise participating in the OPC.  

In  the  survey,  between  two-thirds  and  three-quarters  of  respondents  believed  that  the 
respective  measures  would  address  the  associated  Specific  Objectives  at  a  high  level, 
although in all cases at least half of the respondents to the survey did not express a view. 
On one hand, two-thirds of respondents (67%; 20, 45 ‘no responses’ or ‘Don’t knows’) 
believed  that  the  introduction  of  mandatory  standards  in  relation  to  cargo  securing 
inspections would address Specific Objective 1 at a high level. On the other hand, around 
three quarters of respondents believed that the extension of the scope of the RSI Directive 
to N1 and L-category vehicles would address Specific Objective 2 at a high level (76%; 
28, 38 ‘no responses’ or ‘Don’t knows’; and 74%; 23, 44 ‘no responses’ or ‘Don’t knows’, 
respectively). In their responses to the survey and interview, various respondents noted 
that some of these measures were already undertaken in their respective countries, although 
a minority of respondents were not convinced of the added value of each of these measures. 
In  relation  to  introducing  RSI  for  N1  vehicles,  it  was  suggested  that  this  could  bring 
additional costs, in terms of lost time, for SMEs operating such vehicles. 

Policy measures: Content of RSIs  

The introduction of new RSI test methods and procedures was the subject of the eighth 
group of measures. In the responses to the OPC, a small majority supported consideration 
of relevant measures, as 60% (91, 13 ‘no responses’ or ‘Don’t knows’) supported measures 
to  specifically  tackle  noise-related  tampering  /  noncompliance  problems  in  vehicles 
inspected at  the roadside  and 53% (78, 17 ‘no responses’ or ‘Don’t knows’) supported 

67 

 
extended  emission  testing  (e.g.,  NOx  and  PN),  including  the  use  of  remote  sensing 
equipment. SMEs participating in the OPC were much less supportive of either of these 
measures  (29%  (six)  and  40%  (eight),  respectively),  compared  to  no  respondent  large 
enterprise in both cases.  

In the responses to the survey, a majority of respondents, who expressed a view, thought 
that each of the proposed measures would contribute to addressing both Specific Objective 
1 and Specific Objective 2 at a high level, although more than half of respondents did not 
have a view on any of these measures. For example, 81% (26, 43 ‘no responses’ or ‘Don’t 
knows’)  believed  that  PN  testing  for  commercial  vehicles  would  address  Specific 
Objective 2 at a high level, as did 77% (24, 44 ‘no responses’ or ‘Don’t knows’) for NOx 
and  noise  testing  for  all  vehicles  using  remote  sensing.  The  measure  that  the  fewest 
respondents believed would address Specific Objective 2 at a high level was plume chasing 
for commercial vehicles  (61%; 14, 52 ‘no responses’ or ‘Don’t knows’). The responses 
relating to Specific Objective 1 were similar for each measure. In the responses to the open 
questions in the survey and interviews, various respondents from national authorities were 
not convinced of the added value of requiring PN counting during an RSI, if this was also 
measured in the course of a PTI. It was also suggested that remote sensing would only be 
able to identify vehicles that exceed the respective emission standards significantly, rather 
than being able to identify slight exceedances.  

In  the  IIA  response  in  relation  to  the  RSI  Directive,  CITA  called  for  cargo  securing 
requirements  for  cargo  vehicles  to  be  set  in  type  approval,  in  order  to  facilitate  the 
inspection  of  the  security  of  cargo  in  RSIs.    Ireland’s  RSA  called  for  some  changes  to 
improve  the  RSI  Directive,  including  more  specific  wording  around  failures  involving 
frontal protection systems and tampered emission control systems. They also suggested 
that  consideration  could  be  given  to  expanding  the  scope  of  the  RSI  Directive.  The 
inspection  company  Applus  suggested  that  the  RSI  Directive  should  be  extended  to  all 
vehicles that were able to circulate on roads in the EU to check their emission levels, noise 
levels, overloading and other relevant technical issues. They also suggested that remote 
sensing  could  be  used  to  identify  the  need  for  additional  inspections  for  high  polluting 
vehicles. The Nordic Logistics Association highlighted the importance of electronic data 
exchange and the storage of the results of RSIs, and for RSI authorities to have access to 
this information, in order to prevent drivers being subject to another RSI when they cross 
a border. They also underlined the importance of digital tools, including those that could 
support the registration of vehicles, in making it easier to inspect vehicles, and so make 
this more efficient, thus saving time for inspectors and for those being inspected.  

Policy measures: Testing software in PTIs and RSIs  

The  ninth  set  of  measures  included  a  single  measure  relating  to  both  the  PTI  and  RSI 
Directives:  require  the  testing  of  software  status/integrity  of  safety  and/or  emission 
relevant systems in the PTI for all vehicles and as part of technical roadside inspections 
of commercial vehicles. The OPC included a question on a similar measure, but only in 
relation to PTI, which was supported by two thirds of respondents (65%; 100, nine ‘no 
responses’ or ‘Don’t knows’). The importance of checking a vehicle’s software, at least 
during PTIs, was highlighted by a number of inspection bodies in the IIA. In the survey, 
a high proportion of respondents believed that the measure would address both Specific 
Objective 1 (86%; 42, 26 ‘no responses’ or ‘Don’t knows’) and Specific Objective 2 (81%; 
38, 28 ‘no responses’ or ‘Don’t knows’) at a high level. In the open responses to the survey 
and  interviews,  some  authorities  were  concerned  about  the  additional  costs  of  this 

68 

 
 
measure,  particularly  on  SMEs.  On  the  other  hand,  those  that  undertook  inspections 
believed that the test could be relatively straightforward, even automated, as long as those 
undertaking inspections had easy access to the relevant information within the vehicle and 
also to relevant manufacturer databases that contained the necessary information on the 
software used.  

Policy measures: Access and exchange of information/data  

The tenth set of measures focused on access and exchange of information/data that was 
needed to support PTIs and RSIs. 

In the response to IIA, CITA called for all those undertaking inspections to have access to 
vehicle-specific original data in a non-discriminatory, free and independent manner, given 
that technical inspections are undertaken for the authorities of the Member States, They 
also underlined the importance of relevant stakeholders being able to verify that the right 
version of approved software was being used by the vehicle. Germany’s Central Agency 
for PTI, the FSD, also underlined the importance of access to in-vehicle data and diagnostic 
information  in  an  independent  and  reliable  way,  specifically  the  information  made 
available in the context of EU type approval legislation, along with unrestricted access to 
the vehicle data and software, covering the whole lifetime of  the vehicle. Similarly, the 
Spanish AECA-ITV underlined the importance of PTI inspection providers having access 
to the original vehicle data, including up-to-date software, in a non-discriminatory, free 
and independent manner, so that vehicles could be appropriately tested. The Portuguese 
ANCIA also underlined the importance of testing services having access to the technical 
specifications of a vehicle’s safety systems to be able to properly test these, and to be able 
to check that a vehicle’s software was approved and up to date. Austrian VFT and BdF, 
and  the  German  DKZ  also  underlined  that,  in  order  to  facilitate  the  inspection  of  the 
functionality of safety systems, testing centres should have easy access to the relevant OBD 
data, free of charge. They also noted that the implementation of Regulation (EU) 2019/621 
regarding  ePTI  had  been  more  difficult  than  expected  and  so  more  detailed  provisions 
should  be  included  in  the  revised  RWP.  GOCA  Vlaanderen  also  emphasised  the 
importance of free access to specific PTI-related data for each individual vehicle in order 
to  be  able  to  properly  inspect  modern  vehicles.  Similarly,  Ireland’s  RSA  called  for 
manufacturers  to  be  required  to  provide  to  Member  States  with  “accessible  and 
standardised” information relating to the test items, at no cost to Member States, and to 
provide sufficient  access to  in-vehicle data in  PTIs to  enable the necessary inspections. 
They also  argued that testing inspection companies should have similar  access  to these 
information and data. Inspection company Applus argued that organisations involved in 
statutory activities, such as vehicle inspections, should have a “clear and unfiltered access” 
to vehicle data, potentially via a central hub. They also called for the information needed 
for  an  inspection  to  be  made  available  in  a  standardised  format  in  an  easy-to-access, 
computer-readable  format  on  the  European  level,  to  facilitate  access  to  the  OBD,  for 
example. Applus also underlined the importance of inspections being able to check that 
the appropriate, non-modified software was present on the vehicle. The EGEA underlined 
the  importance  of  direct  access  to  in-vehicle  data  to  facilitate  the  testing  of  safety  and 
environmental control systems, and also called for all inspection equipment to have digital 
network capability to enable the secure transmission of data between inspection sites and 
the respective authorities. GTÜ, the German association of independent PTI inspectors, 
also  underlined  the  importance  of  being  able  to  access  vehicle  data  using  standardised 
interfaces, and of having internet access at all inspection sites. They also noted that they 
would welcome a system that would allow Member States to issue inspection reports solely 
in a digital format. The FIA also underlined that the relevant diagnostic data and functions 

69 

 
must be made “conveniently accessible” for inspection bodies free of charge, as these were 
undertaking a government activity, with the explicit consent of users. They also called for 
the  implementation  of  an  independent,  vehicle  security  certification  scheme  to  allow 
“efficient  and  effective”  verification  during  testing  to  ensure  that  the  most  up-to-date 
security, safety and environmental protection updates have been installed. The ÖAMTC’s 
response made similar points. 

In the OPC, questions were asked about relevant measures relating to both PTIs and RSIs. 
Two-thirds  of  respondents  (67%;  102,  11  ‘no  responses’  or  ‘Don’t  knows’)  supported 
extending (or clarifying) existing rules on access to in-vehicle data…, with data protection 
safeguards for PTIs, whereas a slightly smaller proportion (62%; 93, 15 ‘no responses’ or 
‘Don’t  knows’)  supported  this  for  RSIs.  In  both  cases,  vehicle  and  equipment 
manufacturers/suppliers,  who  participated  in  the  OPC,  were  less  supportive  of  this 
provision than other respondents, e.g. for PTI (58%; seven, three ‘no responses’ or ‘Don’t 
knows’) and for RSI (50%; six, three ‘no responses’ or ‘Don’t knows’). In addition, 59% 
(92, nine ‘no responses’ or ‘Don’t knows’) supported new methods for reading out onboard 
data  stored  in  the  vehicles  for  PTIs,  although  again  vehicle  and  equipment 
manufacturers/suppliers,  who  participated  in  the  OPC,  were  less  supportive  of  this 
measure  (38%;  five,  two  ‘no  responses’  or  ‘Don’t  knows’)  than  other  respondents.  In 
addition,  nearly  two  thirds  of  OPC  respondents  (64%;  96,  14  ‘no  responses’  or  ‘Don’t 
knows’) were supportive of granting roadside inspection authorities access to electronic 
data, which again was less supported by vehicle and equipment manufacturers/suppliers, 
who participated in the OPC, than other respondents (31%;  four, two ‘no responses’ or 
‘Don’t knows’).  

In the survey, a majority of respondents believed that further defining data governance 
procedures and the means of access to vehicle technical information by testing centres free 
of charge and in standardised format would address both Specific Objective 1 (87%; 45, 
23 ‘no responses’ or ‘Don’t knows’) and Specific Objective 3 (75%; 38, 24 ‘no responses’ 
or ‘Don’t knows’) to a high level. A similarly high proportion believed that enabling and 
use of independent remote access to in-vehicle data in the RSIs of commercial vehicles 
would address both Specific Objective 1 (81%; 34, 33 ‘no responses’ or ‘Don’t knows’) 
and Specific Objective 2 (73%; 30, 34 ‘no responses’ or ‘Don’t knows’) to a high level. 
Around  three-quarters  of  respondents  (75%;  24,  43  ‘no  responses’  or  ‘Don’t  knows’) 
believed that requiring the electronic storage of RSI reports in national databases, as well 
as the access and exchange of RSI-relevant data to RSI authorities in other EU Member 
States through a common IT system would address Specific Objective 3 at a high level. In 
response to the open survey and interview questions, various respondents underlined that 
enabling and use of  independent  remote access  to  in-vehicle data  was  as important  for 
PTIs as it was for RSIs, and so underlined that this measure should also be considered in 
the context of PTIs. In this context, EReg underlined that they supported the three measures 
in  this  section  applying  to  all  three  Directives  that  are  part  of  the  RWP.  Various 
respondents, including CITA, EGEA and EReg, underlined the importance of free and easy 
access to in-vehicle data to enable the proper inspection of vehicles.  Many respondents 
also underlined the importance of storing relevant data in a structured format, rather than 
storing the full RSI report. A couple of respondents suggested that SMEs would benefit 
from having easier access to information.  

Policy measures: Measures relating to vehicle registration  

70 

 
 
The final – eleventh – set of measures focused on potential amendments to the Vehicle 
Registration Documents Directive.  

In  the  IIA  response  in  relation  to  vehicle  registration,  CITA  called  for  a  standardised 
exchange of data between type approval and licencing authorities, to eliminate the need to 
carry the  registration certificate in  the vehicle (or even its replacement entirely  with  an 
electronic version) and the possibility for relevant authorities and bodies to access vehicle 
registration data, no matter which Member State the vehicle was  registered in.  Spanish 
AECA-ITV called for the establishment of an electronic platform in which Member States 
were  able  to  access  the  registration  documents  and  certificates  of  conformity  of  all 
vehicles. The Nordic Logistics Association agreed with the difficulties in enforcing road 
safety measures in cross-border traffic and trade in the EU, and underlined its belief that 
sharing  vehicle  registration  data,  and  other  safety-relevant  information,  of  vehicles 
between Member States was important to address this problem. 

In the OPC, respondents were asked whether they supported four relevant measures, each 
of which was supported by around three-quarters of respondents, with the most popular 
being adding data on major accidents of a vehicle to the vehicle register (76%; 115, 13 
‘no  responses’  or  ‘Don’t  knows’).  This  was  followed  by  improved  exchange  of 
roadworthiness  data  between  Member  States  in  electronic  format  (75%;  116,  10  ‘no 
responses’ or ‘Don’t knows’), full digitalisation of registration documents (74%; 110, 16 
‘no responses’ or ‘Don’t knows’) and adding odometer data to the vehicle register (72%; 
111,  nine  ‘no  responses’  or  ‘Don’t  knows’).  Responses  to  the  IIA  also  supported  the 
sharing of relevant information between Member States.  

In the survey, a large majority of respondents that had a view (at least 85% in all cases) 
believed that the respective measures would have a high impact on the respective Specific 
Objectives. Over 90% of respondents believed that providing electronic access to relevant 
data  to  the  registration  authorities  of  other  EU  Member  States  through  the  use  of  a 
common IT system (95%; 38, 35 ‘no responses’ or ‘Don’t knows’) and adding a minimum 
set of new data to the vehicle register (93%; 42, 30 ‘no responses’ or ‘Don’t knows’) would 
address  Specific  Objective  3  to  a  high  level.  Slightly  fewer  respondents  believed  that 
introducing  the  requirement  that  any  vehicle  transformation  has  to  be  approved  and 
registered  and  increasing  the  harmonisation  of  the  technical  data  in  the  vehicle 
registration  documents  on  the  basis  of  a  common  standard  would  address  Specific 
Objective 3 at a high level (91%; 30, 42 ‘no responses’ or ‘Don’t knows’; and 88%; 28, 43 
‘no responses’ or ‘Don’t knows’, respectively).  The proportion believing  that  requiring 
issuing of the registration certificates (Annex I) in digital format and that requiring that 
Member States update vehicle registration data on a regular basis would address Specific 
Objective 3 at a high level was marginally lower (85%; 23, 48 ‘no responses’ or ‘Don’t 
knows’; and 86%; 25, 46 ‘no responses’ or ‘Don’t knows’, respectively).  

In the responses to open questions in the survey and interviews, many national authority 
respondents highlighted that 17 Member States already used Eucaris for the purpose of 
data  exchange,  and  that  this  system  worked  well.  Many  of  the  same  organisations 
underlined  that  data  on  the  vehicle  register  should  be  harmonised  and  available  to  all 
organisations  that  were  involved  in  undertaking  PTIs  and  RSIs  for  national  authorities, 
while EReg and some if its members called for a larger set of data to be included in the 
vehicle register. EReg also generally supported the digitalisation of the vehicle registration 
documents and the mutual  recognition  of these.  Various national  authorities, and users, 
underlined  the  importance  of  the  data  in  the  vehicle  register  being  updated  as  soon  as 

71 

 
 
relevant changes happen. It was suggested that additional costs could arise for SMEs that 
were  not  currently  digitally  connected  in  order  to  be  able  to  access  electronic 
documentation and information, although it was also suggested that SMEs would have a 
lot to gain by having better access to relevant standardised information.  

3.5  FEEDBACK RECEIVED ON POLICY OPTIONS 

Various industry respondents, including PTI operators, called for the extension of the PTI 
Directive  to  cover  all  road  vehicles.  PO3  and  PO1b  introduce  the  obligation  to  inspect 
motorcycles  at  PTI,  albeit  at  a  various  level  of  stringency  and  with  PO3  being  more 
ambitious,  while  PO2  and  PO1a  allow  to  substitute  PTI  with  RSI.  While  stakeholders 
belonging to motorcyclists’ groups at EU or national level did not support such extension 
in  the  OPC,  in  the  survey  most  of  the  respondents  supported  mandatory  PTI  for 
motorcycles with the objective to reduce tampering and the detection of defected vehicles. 
Stakeholders also noted that many Member States already required a PTI for motorcycles, 
as well as for tractors and/or trailers. In the consultations, SMEs were much more likely 
not  to  support  extending  the  scope  of  the  PTI  Directive  to  motorcycles  than  large 
enterprises, arguing that costs for SME inspection companies could increase, if they had 
to buy more equipment. 

All policy options include mandatory testing after significant modification of a vehicle, 
which was supported by stakeholders in the survey. Regarding the increased frequency of 
testing, PO1b and PO2 introduce annual emission testing for vans and a requirement for 
an  annual  PTI  for  vehicles  over  10  years  old,  all  these  measures  being  supported  by  a 
majority of stakeholders in the survey. 

The recognition of PTIs conducted in another Member State was an issue that the majority 
of stakeholders responding to the OPC considered as necessary to address. PO3 introduces 
a full recognition, while PO1b and PO2 require the recognition of the PTI from another 
MS than the MS of registration for a period of up to 6 months. PO1a on the other hand 
envisages  only  a  recognition  based  on  bilateral  agreements.  Stakeholder  views  on  this 
differ  to  quite  some  extent:  vehicle  owners  and  those  not  directly  involved  in  PTI 
inspections tended to be more in favour of the mutual recognition of PTI certificates under 
certain conditions, although some recognised that the mutual recognition under bilateral 
agreements would be a good first step. Those more actively involved with inspections were 
concerned  that  the  difference  between  the  approach  taken  to  PTIs  in  different  Member 
States  meant  that  mutual  recognition  would  be  difficult  and  potentially  lead  to  adverse 
effects on safety. Concerns were also raised that mutual recognition without the increased 
harmonisation of PTIs would lead to “PTI tourism”, where drivers had their vehicles tested 
in countries where it was easier to pass a PTI. 

All policy options tackle odometer tampering. New methods for tackling odometer fraud 
were considered as necessary by 69% (107) respondents in the OPC and adding odometer 
data to the vehicle register was welcomed by 72% (111) respondents in the OPC. In the 
consultations, in relation to odometer readings, some stakeholders suggested that it should 
be mandatory to record odometer data at certain events, such as following accidents and 
the  transfer  of  ownership,  and  that  potential  buyers  should  have  access  to  all  this 
information. Not all stakeholders were however positive about this measure: some called 
on odometer system manipulation to be addressed via type-approval legislation, rather than 
the revision of the PTI Directive (FIA), and others questioned the potential inclusion of 

72 

 
 
new methods to tackle odometer fraud, arguing that inspection organisations did not have 
the legal means or ways to detect and sanction such fraud (CITA).  

Regarding  the  content  of  RSI,  PO1b,  PO2  and  PO3  introduce  mandatory  NOx  and  PN 
measurement and inspection of cargo securing. In the responses to the survey, a majority 
of  respondents  (81%  and  77%  respectively)  thought  that  PN  testing  for  commercial 
vehicles and NOx and noise testing for all vehicles using remote sensing would improve the 
detection of defective vehicles and reduce tampering. In the OPC, a small majority supported 
extended  emission  testing  (e.g.,  NOx  and  PN),  including  the  use  of  remote  sensing 
equipment, during RSI. Regarding cargo securing, in the responses to the OPC, there was 
a high level of support for mandatory checks during roadside inspections of commercial 
vehicles  to  ensure  the  safe  securing  of  cargo  (70%;  99).  In  the  survey,  two-thirds  of 
respondents (67%; 20) believed that the introduction of mandatory standards in relation to 
cargo securing inspections would contribute to road safety.   

PO2 and PO3 also introduce the extension of scope of RSI to light commercial vehicles. 
In the OPC, there was only a marginal majority in favour of extending the rules to other 
vehicles (51%; 77). In the survey, around three quarters of respondents thought that the 
extension of the scope of the RSI to light commercial vehicles would contribute to better 
detection of defective and tampered vehicles (76%; 28). In relation to introducing RSI for 
these vehicles, some stakeholders suggested that this could bring additional costs, in terms 
of lost time, for SMEs operating such vehicles.   

Regarding  access  and  exchange  of  information/data,  PO2  and  PO3  both  introduce  the 
procedures for access to vehicle technical information by testing centres free of charge. In 
the OPC, two-thirds of respondents (67%; 102) supported clarifying the existing rules on 
access  to  in-vehicle  data.  Vehicle  and  equipment  manufacturers/suppliers  were  less 
supportive of this provision than others. In the survey, a majority of respondents (87%; 45) 
supported this approach to address the objectives of the initiative. In response to the open 
survey and interview questions, various respondents (including CITA, EGEA and EReg), 
underlined the importance of free and easy access to in-vehicle data to enable the proper 
inspection of vehicles.  

Finally,  all  policy  options  include  measures  aimed  at  facilitating  exchange  of  PTI  and 
registration data. PO1a, PO2 and PO3 furthermore introduce measures on the digitalisation 
of  registration  certificates  and  new  data  sets  to  be  included.  A  large  majority  of 
stakeholders supported these measures. National authority respondents highlighted that 17 
Member States already used Eucaris for the purpose of data exchange, and that this system 
worked well. They underlined that data on the vehicle register should be harmonised and 
available to all organisations that were involved in undertaking PTIs and RSIs for national 
authorities. EReg called for a larger set of data to be included in the vehicle register and 
generally supported the digitalisation of the vehicle registration documents and the mutual 
recognition of these. Various national authorities, and users, underlined the importance of 
the data in the vehicle register being up to date as soon as relevant changes happen.  

73 

 
 
 
 
 
 
74 

 
 
 
ANNEX V. INTERVENTION LOGIC  

75 

 
 
76 

GeneralObjectivesTo contribute to the increased road safety, in particular by decreasing fatalities in road transport by increasing the quality and better coordinating national PTI and roadside inspection systems Specific ObjectivesIncrease the scope and the level of requirements for roadworthiness testing and roadside controls across the European UnionRESULTSIncreased detection of defects ,andfewer vehicles in circulation with dangerous defects Citizens benefit from mutual recognition of RW certificates whenbuying or re-registering a vehicle.Roadside testing better targeted at vehicles/fleets with a higher risk profileMore consistent, objective and high quality testing throughout the UnionGreater assurance for citizens buying used vehicles Reduced admin burden and easier exchange of information between MSIMPACTSFewer heavy polluting vehicles in circulationFewer road deaths and fatalitiesReduction of the emissions of GHG and air pollutants from road transport Create the appropriate framework for seamless flow of information between actors and Member States involved in the enforcement of PTI resultsThe reduction of greenhouse gases and air pollutant emissions from road transport by detecting more effectively and removing from circulation vehicles which are over-polluting because of technical defectsIncreased scope of Periodic and Roadside InspectionsFacilitate the free movement of EU citizensand the smooth functioning of the Internal MarketImproved functioning of the Internal MarketProblemToo many vehicles with technical defects present on EU roads, withnegative impact on road safety and environmentToonarrow scope,level of requirements for roadworthiness testing and roadside controls  too lowProblem drivers:The information and data not exchanged between the concerned actorstrols  too lowOutputsCommon minimum  standards for PTI /RSI testing, inspectors, and Compulsory testingof high speed tractors andPTIs for powerful motorcyclesElectronic safety components included in the PTIMeasures to combat odometer fraudMS required to recognise the validity of equivalent RW certificates issued in other MSs when a vehicleTwo-step roadside inspection systemRisk rating system extended to roadside  
 
 
 
ANNEX VI. SUMMARY OF CURRENT LEGISLATIVE FRAMEWORK 

Directive 2014/45/EU (PTI Directive) 

It  establishes  a  comprehensive  framework  for  ensuring  the  safety  and  environmental 
performance of vehicles circulating on European roads and outlines specific activities and 
responsibilities for various stakeholders, including EU Member States, in order to achieve 
harmonised standards and practices across the EU.  

It  entails  regular  and  systematic  roadworthiness  testing  of  vehicles  to  identify  potential 
safety and environmental risks. These periodic tests are conducted at testing centres and 
aim to assess the overall condition of vehicles, including their components, systems, and 
emissions.  

The requirements laid out in the directive apply to the following types of vehicles capable 
of speeds of more than 25 km/hour:  

•  Passenger  cars  and  light  commercial  vehicles (categories  M1  and  N1).  To  be 

tested 4 years after first registration and thereafter every 2 years.  

•  Vehicles in category M1 used as taxis or ambulances, buses or minibuses (M2, 
M3), heavy goods vehicles (N2, N3) and heavy trailers (O3, O4). To be tested 1 
year after first registration and thereafter yearly.  

•  Wheeled  tractors with  a  design  speed  above  40  km/h  (T1b,  T2b,  T3b,  T4.1b, 
T4.2b and T4.3b) and used mainly public roads . To be tested 4 years after first 
registration and thereafter every 2 years.  

•  Two-  or  three-wheeled  vehicles  (category  L3e,  L4e,  L5e,  and  L7e)  with  a 
combustion  engine  larger  than  125  cm3 haves  to  be  tested  from  2022,  unless 
Member  States  notify  to  the  Commission  an  exemption  from  testing  for  such 
vehicles, and road safety statistics for the previous 5 years show that the same level 
of road safety could be achieved by alternative measures. 

In certain circumstances, member States or inspection authorities may require vehicles to 
undergo a test before the due dates. These circumstances include:  

•  after an accident;  
•  when the holder of the registration certificate has changed;  
•  when the safety and environmental systems and components of the vehicle have 

been altered or modified 

•  When the vehicle reaches a mileage of 160,000 km; and 
• 

in cases where road safety is seriously affected. 

Certain types of vehicles may be exempted from roadworthiness tests, including:  

•  vehicles of historic interest;  
•  diplomatic vehicles;  
•  vehicles used by the armed forces, police, customs, fire services or for agricultural 

and forestry purposes only; and  

•  vehicles used exclusively on small islands. 

77 

 
 
 
  
 
Member  States  are  responsible  for  establishing  and  maintaining  a  national  system  of 
periodic roadworthiness testing that complies with the requirements set out in the directive. 
In  particular,  they  have  to,  ensure  that  authorised  testing  centres  meet  the  required 
standards, and are conducting appropriate checks to monitor their performance, ensuring. 
They have to implement the required frequency of tests, where needed using the flexibility 
provided by the Directive. Also, they shall set rules to further detail content and methods 
of the tests, as well as the qualifications and training requirements for testers.  

Additionally,  they  are  tasked  with  establishing  effective  systems  for  registering  and 
maintaining records of the results of roadworthiness tests.  

Furthermore,  the  directive  requires  ensuring  the  independence  and  impartiality  of  the 
testing centres, preventing conflicts of interest, and to guarantee that the testing centres 
operate in a fair and transparent manner. To facilitate cross-border mobility and ensure the 
harmonisation  of  standards,  the  directive  also  encourages  cooperation  and  information 
exchange among Member States including records of roadworthiness tests,  

The  directive  places  responsibility  on  vehicle  owners  to  present  their  vehicles  for 
roadworthiness testing in accordance with established requirements and timelines, and to 
ensure that their vehicles are always maintained in a safe and roadworthy condition.  

Defects  are  classified  as minor, major or dangerous,  with  minor  defects  being 
insufficient to fail vehicles. Where defects are dangerous, the use of the vehicle on public 
roads may be suspended until the fault is rectified.  

When  a  vehicle  already  registered  in  another  Member  State  is  re-registered,  its 
roadworthiness certificate must be recognised by other Member States.  

To detect odometer fraud (manipulating the device used to measure distance travelled), 
data  from  the  preceding  roadworthiness  test  is  to  be  made  available  to  the  inspectors. 
Manipulating the odometer is a punishable offence.  

The directive had to be transposed into national law by 20 May 2017, and it applied from 
20 May 2018. 

Directive  2014/46/EU  on  vehicle  registration  documents (amending  Directive 
1999/37/EC - “VRD directives”) 

In order to  provide  a  comprehensive overview of the legislation  on vehicle registration 
documents,  this  summary  includes  the  provisions  of  the  2014  Directive  and  the  1999 
“mother” Directive. 

The VRD Directives outline the required activities and responsibilities of the authorities in 
the Member States to ensure efficient and harmonised processes for vehicle registration 
and documentation. The directives aim to facilitate the free movement of vehicles within 
the EU while ensuring proper identification, traceability, and compliance with legal and 
administrative requirements.  

78 

 
 
Member States are required to keep an electronic record of data on all vehicles registered 
on their territory, including the outcome of mandatory PTIs and the period of validity of 
the PTI certificate 

Member  States  shall  issue  a  registration  certificate  for  vehicles  which  are  subject  to 
registration  under  their  national  legislation.  The  Directives  provide  that  the  registration 
certificate issued by a Member State shall be recognised by the other Member States for 
the identification of the vehicle in international traffic or for its re-registration in another 
Member State. 

The Member States must issue registration documents in a standardised format that contain 
essential  information  about  the  vehicle,  such  as  its  identification  number,  technical 
characteristics,  and  information  about  the  holder  (and  optionally  the  owner)  of  the 
registration certificate.  

Where a Member State’s competent authority is notified that a roadworthiness test shows 
the authorisation to use a particular vehicle has been suspended, this suspension must be 
recorded electronically and an additional roadworthiness test carried out. The suspension 
is effective until a new roadworthiness test has been passed successfully. 

The directives emphasise the importance of cooperation and information exchange among 
Member States, in particular so as to check, before any registration of a vehicle, the legal 
status of the vehicle in the member state in which it was previously registered.  

Directive 2014/47/EU (RSI Directive) 

Directive 2014/47/EU on technical roadside inspections provides the legal framework for 
Member States to implement technical roadside inspections of commercial vehicles. These 
inspections  focus  on  assessing  the  technical  condition  of  vehicles,  including  their 
components, systems and equipment.  

The requirements set out in the directive apply to the following types of vehicles: capable 
of speeds of more than 25 km/hour:  

•  Taxis, ambulances, buses and minibuses (M2, M3);  
•  heavy goods vehicles (N2, N3); 
•  heavy trailers (O3, O4); and  
•  wheeled tractors with a design speed above 40 km/h (T1b, T2b, T3b, T4.1b, T4.2b 
and T4.3b) and used mainly public roads for commercial road haulage purposes. 

Member States may also carry out inspections on vehicles not covered by this Directive, 
such  as  light  commercial  vehicles,  or  carry  out  inspections  in  places  other  than  public 
roads. 

Member  States  play  a  key  role  in  implementing  and  enforcing  the  provisions  of  the 
directive. They are responsible for establishing a system of technical roadside inspections 
within their territories, including the designation of competent authorities and inspection 
bodies. Member States must ensure that the designated bodies have the necessary expertise, 
resources and equipment to conduct effective inspections. 

79 

 
 
 
Member  States  are  also  responsible  for  establishing  rules  regarding  the  content  and 
methods of the inspections, as well as the qualifications and training requirements for the 
personnel  involved  in  conducting  them.  Competent  authorities  are  responsible  for 
supervising and monitoring the activities of inspection bodies to ensure their compliance 
with  the  directive.  They  must  carry  out  regular  assessments  of  the  inspection  bodies' 
performance and take corrective actions if deficiencies are identified. 

Inspections  comprise initial and,  where  necessary, more  detailed  inspections focusing 
in  particular  on  brakes,  tyres,  wheels  and  chassis,  as  well  as  nuisances  (noise,  exhaust 
emissions,  etc.).  The  rate  of  initial  inspections  is  expected  to  be  proportionate  to  the 
number  of  vehicles  registered  in  each  EU  country.  The  aim  is  for  at  least  5  %  of  all 
commercial vehicles registered in the EU to be inspected (initial inspection) each year.  

Inspectors  must  not  discriminate  on  grounds  of  the  nationality  of  the  driver  or  of  the 
country of registration when selecting a vehicle for inspection. They must be free from any 
conflict of interest that might compromise their impartiality, and remuneration must not be 
dependent on the outcome of their inspections.  

Risk-rating system - From 2019, EU countries must introduce information on deficiencies 
found  during  RSI  tests  into  the  risk-rating  system,  enabling  Member  States  to  check 
undertakings with a high-risk profile more closely and frequently.  

The Directive includes principles for inspections and applicable standards for (optional) 
testing of cargo securing,  

Defects are classified as minor, major or dangerous. Any major or dangerous deficiency 
revealed by an inspection must be rectified before the vehicle is  further used on public 
roads.  

Furthermore,  the  directive  emphasises  the  importance  of  cooperation  and  coordination 
among  Member  States  to  ensure  consistent  inspection  practices  and  to  prevent  non-
compliant  vehicles  from  circulating  within  the  EU.  This  includes  sharing  inspection 
results,  identifying  repeat  offenders  and  collaborating  on  cross-border  enforcement 
activities. Member States are required to designate a contact point to ensure information 
exchange and assist the contact points of other Member States.  

Member  States  are  required  to  define  the  responsibilities  of  undertakings  to  maintain 
vehicles in a safe and roadworthy condition.  

In addition, Member States shall require undertakings and drivers to cooperate with the 
inspection authorities during roadside inspections, and to provide access to the vehicle, its 
parts,  and  all  relevant  vehicle  documentation.  Furthermore,  competent  authorities  are 
responsible  for  monitoring  the  number  of  roadside  inceptions  and  reporting  to  the 
European Commission on a biannual basis. 

80 

 
 
 
ANNEX VII. THE MINIMUM REQUIREMENTS SET OUT IN THE DIRECTIVES AS EXCEEDED 
BY SOME MEMBER STATES  

During the evaluation, the Commission contacted Member States to identify the matters in 
which  the  Member  States  had  exceeded  the  minimum  requirements  as  set  out  in  the 
Directives.  The  responses  from  Member  States  illustrate  that  there  are  several  areas  in 
which at least some Member States exceed the minimum requirements, as permitted by the 
Directives.  

PTI Directive 

•  On the scope, BG, BE, DE, EE, ES, FI, HR, HU, LT, LV, SE, SI and SK. 
•  On the frequency of tests, AT, BG, BE, DE, EE, ES, FI, HR, LV, NL, SE, SI and 

SK. 

•  On the contents of testing: 
➢  On the braking equipment, AT, BG, DE, ES, FI, HR, LV, SE and SK. 
➢  On the steering, AT, BG, ES, LV, SE and SK. 
➢  On the visibility, AT, BG, ES, IE, SE and SK. 
➢  On the lighting equipment and parts of the electrical system, AT, BG, DE, ES, FI, 

LV, SE and SK. 

➢  On the axles, wheels, tyres, suspension, AT, BG, BE (partially), ES, FI, IE, LV, SE 

and SK. 

➢  On the chassis and chassis attachments, AT, ES, LV, SE and SK. 
➢  On other equipment, AT, ES, SE and SK. 
➢  On nuisance, AT, BE, DE, ES, NL, SE and SK. 
➢  On supplementary tests for passenger-carrying vehicles of categories M2 and M3, 

AT, BG, DE, ES and SE. 

•  On inspectors (competence and training), AT, BG, DE, EE, ES, FI, IE, LV and SE. 
•  LV has introduced specific training requirements for testing electric vehicle. 
•  AT,  EE,  ES,  FI,  LV,  NL  and  SK  have  introduced  electronic  roadworthiness 

certificates. 

RSI Directive 

AT, BE78, EE, ES, FI, HR, HU, LV, PL, RO, SE and SK include vehicles currently outside 
the scope . 

VRD Directive 

AT, BG, BE79, DE, FI, HR, HU, LT, LV, NL, PL and SI regularly update vehicle data. 

78 Flanders 
79 Brussels and Flanders 

81 

 
 
 
 
ANNEX VIII. EVALUATION MATRIX AND THE EVALUATION QUESTIONS  

Q1: To what  extent do the scope and objectives of the intervention remain relevant for current and future 
needs? 
Operational sub-questions 

• 
• 

• 

Is there still a need to improve road safety? 
Is there still a need to reduce the emissions GHG and air pollutants from road  transport over the whole 
lifetime of vehicles? 
Is there still a need to facilitate the free movement for EU citizens and smooth functioning of the internet 
market? 

Judgement criteria 

•  Road safety and environmental protection are important considerations for EU citizens.  
• 
• 

EU citizens consider that PTI and roadside inspections are necessary to safeguard road safety and air quality. 
There is still pollution from vehicles because of substandard repair, malfunctioning and tampering of the 
emission control systems. 
There are still accidents and fatalities due to defects in vehicles. 
Stakeholders consider that the facilitation of the free movement for EU citizens and smooth functioning of 
the internal market are still important 

• 
• 

Indicators 

Sources 

•  Number of 

• 

accidents 
due to 
defects. 
Share of 
pollution 
from road 
transport by 
high 
emitting 
vehicles, 
with 
malfunctioni
ng emission 
control 
systems.  

•  Number of 
positive 
opinions on 
the relevance 
of each sub-
question in 
the survey 
•  Number of 
free moving 
people 
within the 
EU  

• 
Targeted interviews 
• 
Survey  
•  Desk research 
•  Data analysis (databases) 

Survey 
Relevant 
stakeholders
: 
Police 
Urban 
authorities 
Inspection 
bodies (PTI) 
Agencies 
responsible 
for 
transport, 
road  safety, 
air  quality, 
law 
and 
enforcement  

Targeted 
interviews 
Interviews 
with: 
Inspection 
bodies (PTI) 
Market 
surveillance 
authorities 
CITA 
National 
vehicle 
emission 
prognoses  and 
authorities 
Agencies 
responsible for 
transport,  road 
air 
safety, 
quality, 
and 
law 
enforcement 

Desk research 
Academic studies  
- Martín-de los Reyes LM, Effect of 
Periodic Vehicle Inspection on Road 
Crashes  and  Injuries:  A  Systematic 
Review.  Int  J  Environ  Res  Public 
Health. 2021 

Roadside observation reports  
National PTI reports 
National regulations 
Vehicle safety reports  
Official  reports,  especially  at  EU-
level, MS-level authorities such as: 
•  OECD,  Road  Safety  –  Annual 

• 

• 

Report 2021,  
ISTAT,  Road  accident,  Italy, 
(2021) link 
Spanish 
Interior  Ministry, 
Number of fatalities by type of 
vehicles, link 
INNSSE,  Road 
Romania, (2017), link 
French  Government,  Road 
Safety Review 2021, link 
Academic  and  scientific  literature 
and articles; 

accident, 

• 

• 

analysis 

Data 
(databases) 
IGLAD / Initiative for 
Global 
the 
Harmonisation 
of 
Accident Data 
EU Data (CARE) 
Accident 
(GIDAS) 
Remote 
Sensing 
databases  for  typical 
fleet average emission 
performance 
CONOX/CARES 
database  and  study 
data 

databases 

Position  papers,  e.g.  from technical 
expert associations 

Q2: To what extent are the 3 Directives still relevant for the wider EU policy goals, and to the objectives of the 
intervention? 
Operational sub-questions 

82 

 
 
  
  
  
  
 
  
  
• 

•  How are road safety, environmental protection and free movement articulated in current EU policy goals, 
such  as  the  European  Green  Deal,  Fit-for-55,  Market  Surveillance,  Euro  7,  improving  air  quality  and 
reducing GHG emissions?  
To what extent is 2014/45/EU relevant for the EU policy goals related to road safety, air quality, and free 
movement? Have these goals evolved since the adoption of the RWP, and if so, in what way? 
To what extent is directive 2014/46/EU on the registration documents for vehicles relevant for the EU policy 
goal of free movement? Have these goals evolved since the adoption of the RWP, and if so, in what way? 
To what extent is 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial 
vehicles circulating relevant for the EU policy goals related to road safety and air quality? Have these goals 
evolved since the adoption of the RWP, and if so, in what way? 

• 

• 

Judgement criteria 

•  Road safety and environmental protection are still important, relevant, and well-integrated in current EU 

• 

policy goals.  
Evidence of the importance of free movement for the EU, especially in the context of information exchange 
mutual recognition of inspection certificates. 
Periodic technical inspection is relevant to the EU policy goals related to road safety and air quality  

• 
•  Roadside inspection is relevant to the EU policy goals related to road safety and air quality. 

Indicators 

Sources 

• 

• 

• 

Progression  towards 
EU  targets  in  terms 
of  road  safety  (Zero 
casualty  by  2050) 
and air quality  
Statistics  on  the  PTI 
tests,  high  emitting 
vehicles, 
and 
vehicles registered in 
the EU 
The  use  of  cross-
border 
registration 
documents  for  EU 
citizens  moving  free 
in Europe 

• 
Targeted interviews 
• 
Survey  
•  Desk research 

Targeted 

interviews 
Interviews with: 
DG 
MOVE 
Expert Group 
MEPs 
Transport 
Committee 

from 

Survey 
Relevant stakeholders: 
Road users’ associations 
Cities  participating  in  the 
and 
Climate-Neutral 
Smart  Cities  Mission, 
Eurocities  
POLIS 

Desk Research 
EU  policies  (Fit  for  55,  Green  Deal, 
Vision 0, etc…) 
Official  reports,  especially  at  EU-
level, MS-level authorities 

Academic and scientific literature and 
articles 
Position  papers,  e.g.  from  technical 
expert associations 

Q3: How well adapted is the intervention to the technological, environmental, and scientific advances that have 
appeared since its introduction? 
Operational sub-questions 

•  Do the current directives sufficiently address changes in the composition of vehicle fleets due to changes in 

vehicle powertrains and emission control technologies?  

•  Do the current directives sufficiently address technological advancement in automated and smart mobility, 

such as ADAS systems and other technologies? 

•  Are the current directives sufficiently advanced in their approach with regard to the digital evolution of 

today (the IoT, connectivity, on-board computer, etc) 

Judgement criteria 

• 

• 

The directives of the roadworthiness package address technological, environmental, and scientific advances, 
including changes in the composition of vehicle powertrains emission control technologies, and OBD.  
The European goals on the shift towards zero-emission vehicles, as laid out in the European Green Deal 
and subsequent targets and frameworks like Euro-7 for cleaner vehicles. 

Indicators 

Sources 

•  Data 

on 

real-world 

environmental 
performance  of  different 
powertrains1  

• 
Targeted interviews 
• 
Survey  
•  Desk research 

83 

 
 
  
  
  
  
  
  
  
  
•  Data  on 

•  Data  on 

the 

the 

safety 
concerns 
regarding 
vehicle batteries in EVs2 
safety 
regarding 
and/or 

concerns 
misaligned 
defective 
of 
sensors/hardware 
safety assistance systems 
and  automated  driving 
systems3 

•  Data  on  the  impact  of 
poor 
defects 
maintenance 
the 
performance  of  ADAS 
and ADS4 

and 

on 

Survey 
Targeted stakeholders: 
Vehicle manufacturers 
associations 
CITA 
Testing 
providers 
DG  MOVE  Expert 
Group 
UNECE 
Group 

equipment 

Working 

Desk Research 
Mapping  of  new  systems  and 
powertrains  and  whether  they 
are covered by the directives 
Available  studies  on  the  links 
between 
the 
defects 
performance of ADAS and ADS 

and 

Official  reports,  especially  at 
EU-level, MS-level authorities 

scientific 

and 

Academic 
literature and articles 
Position  papers,  e.g. 
technical expert associations 

from 

Targeted interviews 
Targeted stakeholders: 
Vehicle 
manufacturers 
associations 
CITA 
Testing equipment 
providers 
DG MOVE Expert 
Group 
UNECE Working 
Groups 
ETSC 
Type approval 
Authorities (safety 
systems) 
CLOVE consortium 
on Euro-7 
implementation 
Parties participating 
in development of 
national PTI 
improvements 

Q4: Have the circumstances changed in the meantime so much that the intervention has to change/adapt to 
them? 
Operational sub-questions 

•  What are the implications of knowledge about the real-world environmental performance of vehicles for 

the intervention of the three Directives?  

•  What are the implications of new vehicle safety standards? 
•  What are the implications of mandatory on-road tests?  
•  What are the implications of ADS and ADAS in terms of PTI and maintenance? Is there a need for self-

check features on these new systems? 

Judgement criteria 

• 

There is a need to expand or modify the intervention in the light of the new challenges occurred or what 
has been learned. 

Indicators 

Sources 

Targeted interviews 

• 
•  Desk research 

Targeted interviews 
Targeted stakeholders: 
Inspection bodies  
CITA 
ACEA/CLEPA 
ETSC 
ERMES5 
T&E 

II 

SET 

SET 

Desk Research 
GIDAS database 
CITA 
and  CITA 
I 
(https://citainsp.org/studies/4259-2/) 
ADAS/ADS investigations by NTSB6 and NHTSA7 
Road Performance Reports (OECD/International Transport 
Forum, UN high-level meetings on road safety, etc.) 
Official 
authorities 
Academic and scientific literature and articles 
Position papers, e.g. from technical expert associations 

reports,  especially  at  EU-level,  MS-level 

studies 

•  Data on real-world 

vehicle emissions and 
effects of undetected 
malfunctions and 
tampering on air 
quality 

•  Reliability of ADAS 

• 

systems  
Frequency of software 
updates necessary to 
ensure ADAS 
performance 

•  Cybersecurity 

requirements to 
mitigate risks 

Effectiveness 

Q5: To what extent have the three Directives been effective in improving road safety and contributing to the 
reduction  of  road  fatalities  and  serious  injuries  in  road  transport,  in  line  with  the  EU  Road  safety  policy 
framework 2010 to 2020, as well as to its successor? 

84 

 
 
  
  
  
 
  
  
  
 
  
  
Operational sub-questions 

•  Compared to what would have happened in absence of the three Directives, in quantitative and qualitative 

• 

• 

terms, to what extent have road fatalities and serious injuries decreased?  
To what extent did fatal and serious crashes change at the EU level in terms of absolute numbers considering 
vehicle age and vehicle type variables? 
To what extent did involvements in fatal and serious crashes change at the Member States’ level in terms 
of absolute numbers considering vehicle age and vehicle type variables? 

Judgement criteria 

•  Changes in the involvement of defective vehicles after the implementation of the directives. The reduction 
of defects, improved control and detection of malfunctions with environmental and safety risks (see “data 
analysis” on page 18 and 19).  

•  Vehicle roadworthiness affects and will continue to affect road safety and environmental performance. 

Indicators 

Sources 

•  Accident analysis 
•  Desk research 
• 

Targeted interviews 

Targeted 
interviews  
Targeted 
stakeholders: 
National 
Authorities  
National 
Road 
Safety Authorities 

Police 

Accident analysis 
EU Data (CARE) 
GIDAS database 
IGLAD  /  Initiative 
the  Global 
for 
Harmonisation 
of 
Accident Data 

• 

• 

• 

• 

Involvements of 
older vehicles in 
accidents of 
different 
severities 
Share of vehicles 
found with 
defects in PTI  
Share of vehicles 
found with 
defects in 
roadside 
inspections 
Proportion of 
vehicles found 
failing emission 
test at PTI 

Desk Research 
National reports on road safety 
Roadside inspections reports  
PTI reports 
Official reports, especially at EU-level, MS-
level authorities 
Academic  and  scientific 
articles 
Position  papers,  e.g.  from  technical  expert 
associations 
“Grey  literature”,  such  as  publications  by 
relevant research centres and think tanks 

literature  and 

Q6: To what extent have the three Directives been effective in increasing the detection of defects and to reduce 
the number of vehicles in circulation with dangerous defects? 
Operational sub-questions 

•  Compared to what would have happened in absence of the three Directives, in quantitative and qualitative 

terms, to what extent are PTI and roadside inspections able to detect defects and fraud?  
To what extent did the detection of defects at EU level and member state level increase?  
To what extent did the number of vehicles in circulation with dangerous defects decrease? 

• 
• 

Judgement criteria 

• 

Increase in the detection of vehicle defects in the PTI and the RSI after the implementation of the RWP. 

Indicators 

Sources 

•  Number  of  periodic  tests  by 
member states each year 

Targeted interviews 

• 
•  Desk research 

85 

 
 
 
 
  
  
  
  
 
  
  
Targeted interviews  
Targeted stakeholders: 
Inspection bodies 
CITA 

•  Number  of  vehicle  defects 
detected in PTI each year 

•  Number 

of 

roadside 

inspections each year 

•  Number  of  vehicle  defects 
detected in RSI each year 
•  Removals  of  vehicles  with 
serious defects vehicles from 
operation 

•  Age of vehicles when put out 

of circulation 

Desk Research 
Reports by Member States  
National reports on road safety 
MS National Institutes of Statistics 
Roadside inspections reports  
PTI reports  
Official  reports,  especially  at  EU-level,  MS-level 
authorities 
Academic and scientific literature and articles 
Position  papers, 
e.g. 
associations 
“Grey  literature”,  such  as  publications  by  relevant 
research centres and think tanks 

technical 

expert 

from 

Q7: To what extent have the three Directives been effective in contributing to the reduction of the emissions of 
GHG and air pollutants from road transport, and to moving towards eliminating the "gross emitting" vehicles 
from the fleet? 
Operational sub-questions 

•  Are current PTI tests able to detect malfunctions and tampering leading to high emissions of air pollutants?  
•  Compared to what would have happened in absence of the three Directives, to what extent have emissions 
of  GHG  and  air  pollutants  from  road  transport  decreased,  in  particular  Euro-7  and  fuel  consumption 
monitoring? 

Judgement criteria 

Evidence on detection of high-emitting vehicles  

• 
•  Reduction in of the emissions of GHG and air pollutants from road transport due to the implementation of 

the Directives, by detecting high emitting vehicles in the fleet as not-roadworthy. 

Indicators 

Sources 

• 

the 

•  Rate  of  detection 
of  malfunctions 
tampering 
and 
great 
from 
emitters 
during 
PTI tests 
Emission  share  of 
gross  emitters  in 
fleet,  well 
the 
type-
above 
limits 
approval 
and 
EOBD 
requirements. 
of 
Sensitivity 
current 
to 
relevant  emission 
levels  
in 
Level 
emissions of GHG 
and  air  pollutants 
from 
road 
transport 

tests 

of 

• 

• 

• 
Targeted interviews 
• 
Survey  
•  Desk research 
•  Data analysis (databases) 

Survey  
Targeted 
stakeholders: 
Environmental 
Associations/ ONG 
Municipalities 
National  Ministries 
of Environment 
POLIS 

Health 

Desk research 
EEA  –  European 
Environment 
Agency reports 
World 
Organisation 
OECD 
and 
Academic 
scientific  literature 
and articles 
Position 
papers, 
e.g.  from  technical 
expert associations 

Targeted 
interviews  
Targeted 
stakeholders: 
Environmental 
Associations/ 
ONG 
Municipalities 
National 
Ministries 
Environment 
Environmental 
agencies 
DG ENV 
DG CLIMA 
DG MOVE 

of 

Health 

analysis 

Data 
(databases) 
World 
Organisation 
Remote 
databases 
typical 
average 
performance 
CONOX database 
National  Institutes 
of Statistics 

Sensing 
for 
fleet 
emission 

Q8: To what extent have the Directives 2014/46/EU, 2014/45/EU and 2014/47/EU improved the framework for 
exchange of information between actors and Member States involved in the enforcement of testing results? 

Operational sub-questions 

•  What information is being exchanged with respect to the mandatory parts in the directive?  

86 

 
  
  
  
  
  
  
•  Are other Member States than those where vehicles are registered able to effectively enforce roadworthiness 

in cross-border use? 
Is the level of exchange of information improved? 

• 

Judgement criteria 

• 

Exchange  of  information  –  quantitative  evolution  of  information  flows  and  qualitative  assessment  of 
stakeholders  

•  Remaining obstacles to information exchange 

Indicators 

Sources 

• 

• 

• 

in 

Increase 
information 
exchange 
Incidence of failures 
to  acquire  desired 
information 
The 
of 
number 
Member  States  that 
allows for electronic 
exchange 

• 
Targeted interviews 
• 
Survey  
•  Desk research 

Targeted Interviews 
Targeted stakeholders: 
National Authorities 
Inspection bodies (PTI) 

Surveys: 
Targeted stakeholders: 
National Authorities 
Inspection bodies (PTI) 

Desk Research:  
European  Court  of  Justice 
decisions 
EUCARIS database 
Reports from member states 

Q9:  To  what  extent  have  the  three  Directives  been  effective  in  improving  the  consistency,  objectivity,  and 
quality of testing throughout the Union? 
Operational sub-questions 

•  What is the trend in test frequency?  
•  What is the trend in test quality? 
•  What is the trend in test consistency throughout the union? 

Judgement criteria 

• 

• 

The tests are more frequent and more comprehensive (test and inspection frequency, manhours and number 
of items checked during inspection)  
The number of differences between the tests among MS is limited. 

Indicators 

Sources 

•  Change in frequency of tests  
•  Regularity of tests (1 Y, 2 Y, 

etc) 

•  Quality  of  tests-  number  of 
items 
checked 
(thoroughness)  and  level of 
for 
required 
training 
accredited providers 
Time  spent  on  PTI  testing 
the  vehicle 
in  manhours 
throughout the union 

• 

Targeted interviews 

• 
•  Desk research 
•  Consultation with CITA  

Targeted interviews  
Targeted stakeholders: 
National Authorities 
Inspection bodies (PTI) 
Agencies responsible for 
transport and road safety 

Desk research 
Reports  by  member 
states 
Member  States’  testing 
protocols 

Consultation  with 
CITA 

Q10: To what extent have the three Directives been effective in facilitating free movement for EU citizens/ and 
smooth functioning of the Internal Market? 

87 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Operational sub-questions 

•  Have  the  directives  made  it  easier  for  citizens  to  register  vehicles  in  another  MS  when  they  move 

permanently? 

•  How have the directives contributed to smooth functioning of the Internal Market? 

Judgement criteria 

• 

Principles  of  safe  movement  and  the  Internal  Market,  investigating  the  correspondence  between  free 
movement and the Directives 

•  Assessment of unfair competition from tampered vehicles 

Indicators 

Sources 

•  Member States feedback   
• 
Stakeholder feedback 
•  Number  of  cross  border 
registrations  per  year  (for 
the few countries where this 
data is available) 

Targeted interviews 

• 
•  Desk research 

Targeted Interviews 
Targeted stakeholders:  
National inspection bodies 
National Authorities 
Agencies responsible for transport 
and road safety 
European 
implementation (EUCARIS) 

register 

vehicle 

Desk Research 
Data on tachograph tampering  
ECJ  cases 
vehicles 
Consultation by EC in 2021 

regarding  export  of 

Q11: Which factors have driven or hindered the achievement of objectives? 

Operational sub-questions 

•  What are the driving forces behind the achievements of the roadworthiness package? 
•  What are the obstacles for the roadworthiness package to achieve its objectives? 

Judgement criteria 

• 
• 

impact of the obstacles have to be significant. 
impact of the drivers have to be significant. 

Indicators 

Sources 

• 

Severity, 
magnitude of an 
obstacle 
Scale of an 
obstacle 
•  Magnitude of a 

• 

driver 

• 
Targeted interviews 
• 
Survey  
•  Desk research 

Survey 
Targeted 
stakeholders: 
National 
Authorities 
Road Associations 
CITA 

Targeted 
interviews  
Targeted 
stakeholders: 
EU 
Commission 
National 
Authorities 
Road 
Associations 
CITA 

88 

Desk research 
Published  studies  and  reports  on  cross-border 
information exchange 
Consultation by EC in 2021 
- 

European  Commission,  Vehicle  safety  – 
revising  the  EU’s  roadworthiness  package, 
Inception impact assessment, link 

Official reports, especially at EU-level, MS-level 
authorities 
- 

European Parliament, Implementation of the 
roadworthiness package, 2020, link 
Academic and scientific literature and articles 

Position  papers,  e.g.  from 
associations 

technical  expert 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
“Grey literature”, such as publications by relevant 
research centres and think tanks 

Q12:  What  implementation  measures  have  been  introduced  in  the  Member  States  in  order  to  ensure  the 
effectiveness of the three Directives? Are there any significant differences in implementation measures and 
effectiveness across the Member States? Is national transposition law sufficiently clear and enforceable to work 
in practice? 
Operational sub-questions 

•  Which implementation measures have the member states introduced?  
•  What is the pattern between characteristics of implementation measures and effectiveness across member 

states?  

•  How does the member states implementation measures and transposition laws work in practice? 
•  What are the obstacles, if any, to implementation at national level? 

Judgement criteria 

• 
• 

Effective implementation measures across member states 
Implementation success measure by the effectiveness of the directives. 

Indicators 

Sources 

Targeted interviews 
Survey  

• 
• 
•  Desk research/ member state reports 
•  Responses to OPC consultation by EC 

Survey 
Targeted 
stakeholders: 
MS 
authorities 
(e.g. RDW/Dutch) 
Inspection 
bodies/Police 

Desk research:  
Member  States’ 
relevant 
legislation 
Member 
reports 
Commission 
implementation 
reports  

States 

to 

Responses 
OPC 
consultation 
by EC 

of 

Targeted 
interviews  
Targeted 
stakeholders: 
MS with varying 
practices 
(number 
roadside 
inspections, date 
of 
first 
inspection  and 
frequency 
of 
subsequent 
ones, 
inspections 
houses  vs.  local 
garages, etc) 

between 

•  Relation 
effective 
implementation 
measures 
effectiveness  
•  Measures  adopted 

compliance 
Directive 2014/45/EC 

•  Measures  adopted 

compliance 
Directive 2014/46/EC 

•  Measures  adopted 

compliance 
Directive 2014/47/EC 

and 

in 
with 

in 
with 

in 
with 

•  Measures  lacking  with 
to  Directive 

respect 
2014/45/EC 

•  Measures  lacking  with 
to  Directive 

respect 
2014/46/EC 

•  Measures  lacking  with 
to  Directive 

respect 
2014/47/EC 

Efficiency  

Q13: To what extent, and in respect of which specific aspects, have the three Directives generated costs and 
benefits, for the relevant national authorities, citizens and businesses? To what extent have the cost associated 
with the three Directives been proportionate to the overall benefits achieved? 
Operational sub-questions 

•  What  are  the  benefits  of  the  implementation  of  the  roadworthiness  package  for  the  relevant  national 

authorities, citizens, and businesses?  

•  What are the costs of the implementation of the roadworthiness package for the relevant national authorities, 

citizens, and businesses?  

Judgement criteria 

• 

Estimation of costs and benefits 

89 

 
  
  
  
  
  
  
  
  
  
Indicators 

Sources 

•  Costs 

incurred 
compared  to 
monetised 
benefits  

• 
Targeted interviews 
• 
Survey  
•  Desk research 
•  Data analysis (databases) 

Survey 
Targeted 
stakeholders: 
Consumers’ 
groups 
FIA  
Road 
transport 
companies/as
sociations 

Targeted 
interviews  
Targeted 
stakeholders: 
Consumers’ 
groups 
(BEUC) 
FIA  
Road 
transport 
companies/as
sociations 

from 

costs 

Desk research 
Reports 
members states 
(Academic) studies 
Hidden 
(maintenance 
scrappage)  
Position  papers,  e.g. 
from  technical  expert 
associations 
IA report on the RWP 
in 2012 

Data analysis (databases)  
Accident databases (GIDAS) 
EU Data (CARE) database 
IGLAD 
National Institutes of Statistics 
Methods  of 
external costs of transport  

internalisation  of 

Q14:  What  is  the  administrative  burden  for  Member  States  generated  by  the  three  Directives?  Is  there  a 
potential  in  the  Member  States  to  simplify  and  reduce  administrative  burden  without  undermining  the 
intended objectives of the Directives? 
Operational sub-questions 

•  What are the administrative costs, time, and red tape of the implementation of the roadworthiness package 

for the relevant authorities in the member states? 

•  What are the identified best practices in terms of administrative burden in relation to the implementation of 

the roadworthiness package? 

Judgement criteria 

•  Additional administrative burden created by the three directives 

Indicators 

Sources 

• 

Efficiency 
outcomes 

in  achieving 

• 
• 

Survey of member states 
Stakeholder views 

•  Administrative cost 
•  Manhours 
spent 
inspection 
Level  of  digitalisation  of 
administration 

on 

• 

Survey of member states 
Targeted stakeholders: 
National Authorities 

Stakeholder discussion 
Targeted stakeholders: 
National Authorities 
Road transport associations 
Consumer Associations 

Q15: What is the administrative burden for citizens and businesses generated by the three Directives? Is there 
a potential to simplify and reduce administrative burden for citizens and businesses without undermining the 
intended objectives of the Directives? 
Operational sub-questions 

•  What are the administrative costs of the implementation of the roadworthiness package for citizens and 

businesses?  

•  What are the identified best practices in terms of administrative burden in relation to the implementation of 

the roadworthiness package? 

Judgement criteria 

•  Additional administrative burden created by the three directives 

Indicators 

Sources 

90 

 
  
  
  
  
  
  
  
  
  
• 

Efficiency  in  achieving 
outcomes,  by  assessing 
the  costs  and  benefits 
for 
and 
citizens 
businesses 

• 

• 

Stakeholder discussion e.g., with organisations representing transport 
companies and civil society 
Stakeholder  organisations  around  national  implementations  of  PTI 
(e.g. SMO/Netherlands) 

•  Cost  of  implementation 
by  MS  per  capita  over 
average cost 
Time spent at inspection 
by citizens 
Increase 
owner by RWP 

in  cost 

for 

• 

• 

Stakeholder discussion 
Targeted stakeholders: 

ACEA 
IRU 
ITF 
FIA 
Consumer organisations such as BEUC 

Coherence 

Q16: To what extent are the three Directives’ objectives coherent with the objectives of relevant EU legislation 
and policies in the field of EU road safety, such as the EU safety Road Policy Framework 2021-2030, and the 
Sustainable and Smart Mobility Strategy? 
Operational sub-questions 

•  What is the degree of coherence, overlap, and gaps between the three Directives’ objectives and relevant 

EU legislation and policies in the field of EU road safety? 

•  What is the degree of coherence, overlap, and gaps between the three Directives’ objectives and relevant 

EU legislation and policies in the field of environment and climate? 

•  What is the degree of coherence, overlap, and gaps between the three Directives’ objectives and relevant 

EU legislation and policies in the field of free movement? 

Judgement criteria 

•  Alignment of the objectives of the three directives of the roadworthiness package with current EU policy 

goals and targets, including Vision 0 on road safety 

Indicators 

Sources 

in 

•  Changes 
EU 
policies 
that  would 
justify  changing  the 
elements 
the 
package 

of 

Targeted interviews 

• 
•  Discussion with DG MOVE  
•  Desk research 

Targeted 
interviews  
Targeted 
stakeholders: 
EURONCAP 
ETSC 
T&E 
ACEA 

Desk research 
EU legislation and policies in the field of EU road safety, including 
EU safety Road Policy Framework 2021-2030 
Official reports, especially at EU-level, MS-level authorities 

- 
- 

- 

European Parliament, Impact Assessment, 2012, link 
European  Parliament,  REPORT  on  the  EU  Road  Safety 
Policy Framework 2021-2030 – Recommendations on next 
steps towards ‘Vision Zero’, link 
European  Commission,  Report  on  the  application  by  the 
Member  States of  Directive 2000/30/EC  of  the  European 
Parliament  and  of  the  Council  of  6  June  2000  on  the 
technical  roadside  inspection  of  the  roadworthiness  of 
Commercial  vehicles  circulating  in  the  Community-
Reporting period 2017- 2018, 2020, link 

Academic and scientific literature and articles 
Position papers, e.g. from technical expert associations 

- 

ETSC, Mid Term Review of the European Commission’s 
Road Safety Policy Orientations 2011-2020, link 

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Q17: To what extent are the three Directives’ objectives coherent with the relevant EU legislation and policies 
in other fields, such as the General Safety Regulation and Euro 6/VI legislation? 
Operational sub-questions 

•  What is the degree of coherence between the three Directives’ objectives and other relevant EU legislation 

• 

and policies in other fields, including environment and climate policies? 
To what extent do the three Directives’ objectives overlap with other relevant EU legislation and policies 
in other fields, including environment and climate policies? 

•  Are there any gap between the three Directives’ objectives and other relevant EU legislation and policies in 

other fields, including environment and climate policies? 

Judgement criteria 

•  Alignment with policies and strategies in other relevant policy areas 

Indicators 

Sources 

• 

Fit  to  other 
EU policies  

•  Assistance  to 
of 
delivery 
policy 
objectives  in 
other  policy 
areas 

Targeted interviews 

• 
•  Discussion with DG MOVE  
•  Desk research 

Targeted 
interviews  
Targeted 
stakeholders
: 
DG CLIMA 
DG GROW 
DG ENV 
Other DGs 
and EU 
bodies 
ETSC 
T&E 
ACEA 
National 
authorities/i
mplementin
g bodies 

Discussion 
with 
MOVE  

DG 

Desk research 
General Safety Regulation and Euro 6/VI legislation 
- 

European  Union,  Regulation  (EU)  2019/2144  of  the 
European Parliament and of the Council of 27 November 
2019 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, link 

Official reports, especially at EU-level, MS-level authorities 

Academic and scientific literature and articles 
Position papers, e.g. from technical expert associations 
-  ACEA,  Principles  for  potential  post-Euro  6  and  post-

Euro VI emission regulations, 2020, link 

Q18:  Are  there  any  inconsistencies/overlaps/gaps  between  the  Directives  and  other  interventions  at 
EU/national/international level which have similar objectives? 
Operational sub-questions 

•  What is the level of consistency, overlaps and/or gaps between the directives and the other national, EU and 
international policies, such as national legislations, UNECE regulations on whole-lifetime compliance?  

Judgement criteria 

Inconsistencies  

• 
•  Overlaps 
•  Gaps 

Indicators 

Sources 

• 

Level 
inconsistenc
ies, 
overlaps, 
and gaps 

• 
Targeted interviews 
• 
Survey  
•  Desk research 
•  Review of interventions including regulations or impending regulations from UNECE 

92 

 
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
Targeted interviews  
Targeted stakeholders: 
UNECE Working Groups 
OECD/International 
Transport Forum 
National 
(Ministries of Transport) 
from 
MEPs 
Transport Committee 

Authorities 

the  EP 

Survey 
Targeted stakeholders: 
UNECE Working Group 
OECD/International 
Transport Forum 
National 
(Ministries of Transport) 
MEPs from the EP Transport 
Committee 

Authorities 

Desk 
research 
Regulatio
ns 
on 
Cybersecu
rity 
ADAS 
Whole-
lifetime 

or 

of 

Review 
interventions 
including 
regulations 
impending 
regulations 
UNECE 
for 
Materials 
UNECE 
working 
Groups under WP.29 

from 

EU Added Value 

Q19: What is the additional value of the 3 Directives, for citizens and businesses, compared to what has been 
or what could have been achieved by Member States at national and/or regional and international level with a 
view to improving road safety and environmental protection? 
Operational sub-questions 

•  What it the EU added value related to the implementation of the roadworthiness package in terms of road 

safety?  

•  What  it  the  EU  added  value  related  to  the  implementation  of  the  roadworthiness  package  in  terms  of 

environmental protection? 

•  What it the EU added value related to the implementation of the roadworthiness package in terms of free 

movement of people? 

Judgement criteria 

•  Do national differences in implementation acts and enforcement cause problems?  
•  Would the objectives of the directive be achieved sufficiently by Member States acting alone? 

Indicators 

Sources 

•  Avoided fatalities 
and injuries  
Saved emissions 

• 

• 
Targeted interviews 
• 
Survey  
•  Desk research 
•  Data analysis (databases) 

national 

Targeted 
interviews  
Targeted 
stakeholders: 
MS 
authorities 
Consumers Groups 
MEPs 
Road 
Associations 
Environmental 
Associations 

Safety 

national 

Survey 
Targeted 
stakeholders: 
MS 
authorities 
Consumers Groups 
MEPs 
Road 
Associations 
Environmental 
Associations 

Safety 

Desk research 
Member  States’ 
reports  on  road 
safety 
(Academic) 
studies 

analysis 

Data 
(databases) 
GIDAS Database 
CARE Database 
IGLAD 
National  Institutes  of 
Statistics 
Remote 
Sensing 
databases  for  typical 
fleet average emission 
performance 
CONOX database 

Q20: To what extent would it have been possible to achieve the same results without these Directives? 

Operational sub-questions 

•  How would the estimated road safety situation have been without the implementation of the roadworthiness 

package at EU level and national level? 

•  How would the estimated emissions/ environmental situation have been without the implementation of the 

roadworthiness package at EU level and national level? 

Judgement criteria 

•  Difference in accident and emissions projections compared to the baseline scenario 

93 

 
  
  
  
  
  
  
  
  
  
Indicators 

Sources 

• 

• 

Fatalities and 
injuries in 
baseline 
Projected 
emissions in 
baseline 

• 
Targeted interviews 
• 
Survey  
•  Desk research 
•  Data analysis (databases) 

national 

Targeted 
interviews  
Targeted 
stakeholders: 
MS 
authorities 
Consumers Groups 
MEPs 
Road 
Associations 
Environmental 
Associations 

Safety 

national 

Survey 
Targeted 
stakeholders: 
MS 
authorities 
Consumers Groups 
MEPs 
Road 
Associations 
Environmental 
Associations 

Safety 

Desk research 
Impact 
assessment 
done  for  the  initial 
RWP (before 2016) 
(Academic) studies 

- 

analysis 

Institutes 

Data 
(databases) 
GIDAS Database 
CARE Database 
IGLAD 
National 
of Statistics 
Sensing 
Remote 
databases 
for 
typical fleet average 
emission 
performance 
CONOX database 

94