COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT on the revision of the Directives of the Roadworthiness package Accompanying the documents 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, and amending Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union Proposal for a Directive of the European Parliament and of the Council on the registration documents for vehicles and vehicle registration data recorded in national vehicle registers, and repealing Council Directive 1999/37/EC
Date: 2025-05-26
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, 26.5.2025  SWD(2025) 96 final/2  CORRIGENDUM This document replaces SWD(2025) 96 final of 24.4.2025 Insertion of the cross-reference to the COM(2025) 180 final  The text shall read as follows:  Roadworthiness package COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  on the revision of the Directives of the Roadworthiness package Accompanying the documents 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, and amending Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union  Proposal for a Directive of the European Parliament and of the Council on the registration documents for vehicles and vehicle registration data recorded in national vehicle registers, and repealing Council Directive 1999/37/EC   {COM(2025) 179 final} - {SEC(2025) 119 final} - {SWD(2025) 97 final} - {SWD(2025) 98 final} - {SWD(2025) 99 final} - {COM(2025) 180 final}  
 
 
Table of contents 

1. 

2. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ................................................. 1 

PROBLEM DEFINITION ....................................................................................................... 7 

2.1.  What is/are the problems?............................................................................................. 7 
2.2.  What are the problem drivers? .................................................................................... 14 
2.3.  How likely is the problem to persist? ......................................................................... 19 

3.  WHY SHOULD THE EU ACT? ........................................................................................... 21 

3.1.  Legal basis .................................................................................................................. 21 
3.2.  Subsidiarity: Necessity of EU action .......................................................................... 21 
3.3.  Subsidiarity: Added value of EU action ..................................................................... 21 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................. 22 

4.1.  General objectives ...................................................................................................... 22 
4.2.  Specific objectives ...................................................................................................... 22 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ....................................................... 23 

5.1.  What is the baseline from which options are assessed? .............................................. 23 
5.2.  Description of the policy options ................................................................................ 26 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................. 31 

6.1.  Economic impacts ....................................................................................................... 31 
6.2.  Social impacts ............................................................................................................. 56 
6.3.  Environmental impacts ............................................................................................... 59 

7.  HOW DO THE OPTIONS COMPARE? .............................................................................. 62 

7.1.  Effectiveness ............................................................................................................... 62 
7.2.  Efficiency .................................................................................................................... 63 
7.3.  Coherence ................................................................................................................... 65 
7.4.  Subsidiarity and proportionality ................................................................................. 66 

8. 

PREFERRED OPTION ......................................................................................................... 67 

8.1. 
Identification of the preferred policy options and stakeholder views ......................... 70 
8.2.  REFIT (simplification and improved efficiency) ....................................................... 72 
8.3.  Application of the ‘one in, one out’ approach ............................................................ 73 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................... 74 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................. 75 

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ................................. 80 

ANNEX 3: WHO IS AFFECTED AND HOW? .......................................................................... 100 

ANNEX 4: ANALYTICAL METHODS ..................................................................................... 108 

ANNEX 5: COMPETITIVENESS CHECK ................................................................................ 262 

ANNEX  6:  BACKGROUND  ON  ROADWORTHINESS  LEGISLATION  AND  PTI 
ORGANISATION IN MEMBER STATES ................................................................................. 265 

ANNEX 7: DETAILED DESCRIPTION OF THE RETAINED POLICY MEASURES ........... 271 

ANNEX 8: DISCARDED POLICY MEASURES ...................................................................... 287 

I 

 
ANNEX  9:  COMPARISON  OF  POLICY  OPTIONS  IN  TERMS  OF  MEETING  THE 
OBJECTIVES .............................................................................................................................. 290 

ANNEX 10: SME TEST .............................................................................................................. 295 

ANNEX 11: LINKS BETWEEN THE CONCLUSIONS OF THE EX-POST EVALUATION 
AND THE IMPACT ASSESSMENT .......................................................................................... 298 

ANNEX 12: IMPACTS ON FUNDAMENTAL RIGHTS .......................................................... 300 

ANNEX 13: IMPACTS ON THE FUNCTIONING OF THE INTERNAL MARKET AND 
COMPETITION ........................................................................................................................... 302 

ANNEX  14:  COHERENCE,  SUBSIDIARITY  AND  PROPORTIONALITY  (DETAILED 
ANALYSIS) ................................................................................................................................. 304 

ANNEX 15: MONITORING ....................................................................................................... 308 

ANNEX 16: SYNERGIES WITH OTHER POLICY INSTRUMENTS ..................................... 310 

ANNEX 17: EVALUATION REPORT (SEPARATE DOCUMENT) ....................................... 313 

II 

 
 
 
 
Term or acronym  Meaning or definition 

Glossary 

ADAS 

CARE 

CITA 

CO 

CoC 

DPF 

EEA 

ELV 

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. 

CARE is a Community database on road crashes resulting in death or 
injury (no statistics on damage-only crashes). 

International  Motor  Vehicle  Inspection  Committee,  worldwide 
association of authorities and authorised companies active in the field 
of vehicle compliance 

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. 

Certificate of Conformity: a statement by a vehicle manufacturer that 
the vehicle conforms to EU type-approval requirements. 

Diesel  Particle  Filter,  a  component  designed  to  remove  diesel 
particulate matter or soot from the exhaust gas of a diesel engine.   

European Environment Agency 

End-of-Life Vehicles 

EReg 

Association of European Vehicle and Driver Registration Authorities 

EUCARIS 

European car and driving licence information system 

EV 

GSR 

Electric vehicle, including battery electric, hybrid electric, and fuel cell 
electric vehicles 

type-approval 
General  Safety  Regulation 
requirements to ensure the general safety of vehicles and the protection 
of vulnerable road users 

(EU)  2019/2144: 

III 

 
 
HDV 

HGV 

LDV 

Heavy-duty vehicle, vehicles above 3.5t maximum permissible laden 
mass, including trucks and buses/coaches 

Heavy goods vehicle, truck 

Light-duty vehicle (i.e., up to 3.5t maximum mass), including cars and 
vans (light commercial vehicles, LCVs) 

NO2, NOx 

Nitrogen dioxide, nitrogen oxides, including NO and NO2 

NH3 

OBD 

OBM 

Ammonia,  NH3  contributes  to  acid  deposition  and  eutrophication, 
which in turn, can lead to potential changes occurring in soil and water 
quality. 

A  vehicle  system  that  can  generate  on-board  diagnostics.  It  collects 
information from the network of sensors inside the vehicle, which the 
OBD can use to regulate car systems or alert the user to problems. A 
technician  can  plug  into  the  OBD  port  to  collect  vehicle  data  and 
diagnose  problems.  Recent  models  can  communicate  diagnostic 
information over the air. 

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, via the OBD port and over 
the air. 

Plume chasing 

A new emission testing method used to detect high-emitting vehicles. 
Also called mobile remote sensing where a chasing vehicle follows the 
target vehicle, typically a truck. 

PM(2.5) 

PN 

Particulate  matter  (with  a  diameter  smaller  than  2.5  micrometres 
(<2,5 µm)):  the  emission  limits  for  mass  of  particulate  matter  are 
regulated by type-approval legislation for light (Euro 5 and Euro 6) as 
well as heavy-duty vehicles (Euro VI) 

Particle number, another measure of air pollution, the emission limits 
for PN were introduced in the type-approval regulations from Euro 5b 
light vehicles (first registered from 1 January 2013) and from Euro VI 
HDVs (first registered from 1 January 2014) 

PTI (Directive) 

Periodic  technical  inspection  (Directive  2014/45/EU  on  periodic 
roadworthiness tests for motor vehicles and their trailers) 

IV 

 
PTI centre 

A PTI station, an authorised workshop or larger inspection centre with 
one or more PTI lanes 

PTI lane 

Test lanes along which the vehicle advances during the various stages 
of PTI 

Remote sensing 

A method that measures the various components of exhaust emissions 
of vehicles that pass by the remote sensing device using a light beam 
and detectors 

RSI (Directive) 

Roadside inspection (Directive 2014/47/EU on the technical roadside 
inspection of the roadworthiness of commercial vehicles circulating in 
the Union) 

RWP 

SCR 

2014/45/EU,  Directive 
Roadworthiness 
2014/46/EU  amending  Directive  1999/37/EC,  and  Directive 
2014/47/EU 

package:  Directive 

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  improves  fuel  economy  and  the 
performance of diesel engines. 

SDG (Regulation)  Single  Digital  Gateway  (Regulation  (EU)  2018/1724)  establishing  a 
single  digital  gateway  to  facilitate  online  access  to  information, 
administrative  procedures,  and  assistance  services  that  citizens  and 
businesses may need in another EU country  

UN SDG 

United Nations Sustainable Development Goals 

VRD (Directive)  Vehicle registration documents (Directive 1999/37/EC, as amended by 

Directive 2014/46/EU) 

V 

 
 
1.  INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

This Impact Assessment accompanies legislative proposals for the revision of three Directives, collectively 
called the Roadworthiness Package (hereinafter the “RWP”): 

•  Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers (hereinafter 

the "Periodic Technical Inspection” or “PTI” Directive)1; 

•  Council  Directive  1999/37/EC  on  the  registration  documents  for  vehicles  as  amended  by  Directive 

2014/46/EU (hereinafter the "Vehicle Registration Documents” or “VRD” Directive)2; 

•  Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles 

(hereinafter the “Technical Roadside Inspection” or “RSI” Directive)3. 

Road transport plays a vital role in connecting businesses and consumers across the EU, facilitating trade, 
and  supporting  economic  growth  and  employment.  It  facilitates mobility  of people  and supports many 
industries, such as manufacturing, construction and retail, by providing the means for the transport of goods. 
It also plays a critical role in emergency response. In 2021, road freight transport represented 54.3% (1,863 
billion tonne-kilometres) of all the goods transported within the EU and was responsible for 87% (4,174 
billion passenger-kilometres) of the total passenger transport activity4. The road transport sector employs 
more than 5 million people in the EU, of which 3.3 million work in freight and 1.8 million in passenger 
transport. At the same time, it is a source of certain negative impacts that are addressed by various EU and 
national transport policies, among which the Roadworthiness Package is a key building block.  

Safe vehicles are part of the so-called “Safe System approach”, as presented in the EU Road Safety 
Policy Framework 2021-2030 – Next steps towards “Vision Zero” (5). In this road safety strategy, 
the Commission proposed new interim targets of reducing the number of road deaths by 50% between 
2020 and 2030 as well as reducing the number of serious injuries by 50% over the same period. The 
UN  Global  Plan  for  the  Decade  of  Action (6)  released  in  October  2021,  also  applying  the  “Safe 
System approach”, promotes the same reduction targets already in place at EU level. 

The  Safe  System  approach  considers  death  and  serious  injury  in  road  collisions  as  being  largely 
preventable,  while  acknowledging  that  collisions  will  continue  to  occur.  It  takes  as  a  point  of 
departure the fact  that people make mistakes  and aims to  ensure that such mistakes do not  cause 
fatalities or serious injuries by acting on five pillars: safe roads and roadsides, safe speeds, safe road 
users, safe vehicles, and fast and effective post-crash care, which all contribute to reducing the impact 
of crashes. The Roadworthiness Package focuses on the safe vehicle part of this system.  

In its Sustainable and Smart Mobility Strategy (7) of 2020, the Commission reiterated the target of 
zero fatalities in all modes of transport by 2050 and announced the revision of the roadworthiness 
legislative  framework,  to  ensure  the  lifetime  compliance  of  vehicles  with  emission  and  safety 
standards, under Flagship 1 “Boosting the uptake of zero-emission vehicles, renewable & low-carbon 
fuels and related infrastructure”. In October 2021, the European Parliament adopted a resolution on 
the EU Road Safety Policy Framework 2021-2030 (8), calling on the Commission to consider, among 

1 https://eur-lex.europa.eu/eli/dir/2014/45/oj 
2 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A01999L0037-20220324  
3 https://eur-lex.europa.eu/eli/dir/2014/47/oj  
4 Statistical pocketbook 2023 (europa.eu) 
(5) SWD(2019) 283 final 
(6) Decade of Action - United Nations Sustainable Development 
(7) COM(2020) 789 final 
(8) P9_TA(2021)0407 https://www.europarl.europa.eu/doceo/document/TA-9-2021-0407_EN.pdf  

1 

 
 
others, tightening the roadworthiness test regime and to adapt it to the technical progress in vehicle 
safety features. 

Road crashes9 represent one of the most significant negative impacts of road transport. The external cost of 
crashes represents almost EUR 250 billion per year, i.e., roughly 2% of GDP10. There were around 20,600 
fatal crashes in the EU in 2022, a 3% increase on 2021 as traffic levels recovered after the pandemic. This 
represents however 2,200 fewer fatalities (-10%) compared with the pre-pandemic year 2019 (see Figure 
1). The EU and UN target is to halve the number of road deaths by 203011. The main causes of road crashes 
are speeding, alcohol/drugs, distracted driving, and various driver errors (such as errors of interpretation or 
fatigue). Other causes include the inadequate state or design of infrastructure (slippery surface, insufficient 
markings,  poor  maintenance),  and  vehicle  defects.  In  the  EU,  thanks  to  gradually  improving  vehicle 
technology  through  EU  type-approval  rules  and  a  well-developed  system  of  technical  inspections  to 
ascertain vehicle safety over the entire lifetime, the share of vehicle defects among the causes of road crashes 
is now limited to just a few percent12. However, this also means that avoidable crashes caused by vehicle 
defects are still taking place. The Safe System approach requires acting on all these fronts, recognising that 
the parts of the entire system – including users, vehicles, infrastructure and emergency response – work 
together as an entity13. 

Figure 1: Road fatalities in the EU (2001-2022 and the EU 2030 target) 

Air pollutant emissions from road transport have been decreasing ever since the introduction of the first 
Euro emission standard over 30 years ago. Although subsequent emission standards gradually reduced the 
limits and extended the scope of air pollutants measured, real-life emissions were significantly above the 
type-approval  limits  until  recently  (i.e.  when  RDE  limits  were  introduced)14.  Recent  remote  sensing 
campaigns indicate that even some of the newest vehicles exceed legal emission limits15. According to the 

9  In  this  document  we  use  the  term  ‘road  crash’  and  not  ‘road  accident’.  The  word accident implies  that  a  car  crash 
happened through the fault of nobody. On the other hand, the word crash indicates that someone caused the car wreck to 
happen, or that someone is at fault. The reality is that it is very rare for a car crash to be just an accident, while many 
studies point out the fact that most causes of the accidents are attributable to human error. 
10  COM(2020)  789  final,  https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020SC0331.  1.87% 
based on CE Delft et al. (2020), Handbook on the external costs of transport – Version 2019 – 1.1, Publications Office, 
https://data.europa.eu/doi/10.2832/51388 
11 https://transport.ec.europa.eu/news-events/news/road-safety-eu-fatalities-below-pre-pandemic-levels-progress-
remains-too-slow-2023-02-21_en  
12 See Section 2.1.1. 
13 European Commission (2020), Directorate-General for Mobility and Transport, Next steps towards ‘Vision Zero’  – 
EU road safety policy framework 2021-2030, Publications Office, 2020, https://data.europa.eu/doi/10.2832/391271  
14  Real-driving  emission  (RDE)  limits  were  introduced  following  the  “diesel-gate”  scandal:  https://single-market-
economy.ec.europa.eu/sectors/automotive-industry/environmental-protection/emissions-automotive-sector_en  
15 https://cares-project.eu/cares-open-letters/  

2 

 
 
 
European  Environment  Agency  (EEA),  despite  some  improvement,  air  pollution  remains  the  largest 
environmental health risk in Europe. Exposure to fine particulate matter (PM) and nitrogen dioxide (NO2) 
levels caused just under 300,000 premature deaths in 2020. Road transport is the principal source of nitrogen 
oxides, responsible for 35.5% of emissions in 2022, and accounts for a significant share of PM emissions 
(8.1% of the PM2.5 and 9.5% of the PM10 emissions)16. In 2022, the Commission proposed17 to revise the 
Ambient Air Quality Directives18 which aims to put the EU on a path to achieve zero pollution for air at the 
latest by 2050 and sets interim 2030 ambient air quality standards aligned more closely with the updated air 
quality  guidelines  issued  by  the  World  Health  Organization  (WHO)19  for  key  air  pollutants,  requiring 
enhanced measures to reduce emissions at source. 

For noise emissions, EEA indicates that road transport plays the most significant role20, with 70% of the EU 
population living in urban areas and 25% of the population living outside urban areas being exposed to road 
traffic noise with an equivalent sound pressure level exceeding 55 dB(A) during daytime21,22. While a large 
part of this  can  be  attributed to  the  volume  of traffic  and  a  few other factors, noise  emission levels of 
individual vehicles play a key role, too. The permissible sound level of various road vehicles is regulated 
by UNECE and EU type-approval legislation23. However, here again, regulatory limits are not necessarily 
respected in real life24. 

Legal context 

To address the safety- and nuisance-related defects of vehicles, roadworthiness testing has been in place in 
Europe for decades and subject to gradual harmonisation in the Union, with the first set of common rules 
adopted in 197625 and last revised in 2014 as part of the RWP. Consecutive revisions gradually extended 
the scope of vehicles to be tested, as well as the scope of harmonised rules, including requirements on 
roadside inspections and vehicle registration documents to improve enforcement. They further specified 
and updated the required test methods, procedures and related documents to reflect technological progress26. 

Today, the PTI Directive requires that Member States carry out periodic technical inspections (PTI) on 
most of the vehicles registered in their territory. This covers cars (M1), vans (N1), lorries (N2-N3), buses 
(M2-M3), as well as heavy trailers (O3-O4) and high-speed tractors (T with design speed over 40 km/h). It 
also covers heavy motorcycles, including tricycles and quadricycles (L3e, L4e, L5e and L7e), equipped 
with a combustion engine above 125 cm3, with certain possibilities for exemptions. The Directive sets out 
the minimum content27 and frequency of testing for each vehicle category, except for motorcycles, where 

16 National air pollutant emissions data viewer 2005-2022 | European Environment Agency's home page, EEA (2024), 
Air Pollution in Europe; 2024 reporting status, https://www.eea.europa.eu/publications/national-emission-reduction-
commitments-directive-2024 
17 COM/2022/542 final 
18 Directive 2004/107/EC relating to arsenic, cadmium, mercury, nickel and polycyclic aromatic hydrocarbons in ambient 
air; Directive 2008/50/EC on ambient air quality and cleaner air for Europe. 
19 WHO (2021) WHO Global Air Quality Guidelines.   
20 https://www.eea.europa.eu/en/topics/in-depth/noise  
21 During night-time, 49% of the EU population living in urban areas and 17% of the population living outside urban 
areas are exposed to road traffic noise with an equivalent sound pressure level exceeding 50 dB(A). 
22 Noise — European Environment Agency (europa.eu) 
23 https://environment.ec.europa.eu/topics/noise/noise-pollution-main-sources_en  
24 The UK and France have experimented with roadside trials to monitor excessive vehicle noise:   Décret n° 2022-1; 
https://www.gov.uk/government/publications/roadside-vehicle-noise-measurement-study-enforcement-and-technology  
25 Council Directive 77/143/EEC of 29 December 1976 on the approximation of the laws of the Member States relating 
to roadworthiness tests for motor vehicles and their trailers, OJ L 47, 18.2.1977, p. 47–51 
26 The evolution of the PTI legislation is illustrated in Annex 6. 
27 (0) Identification of the vehicle; (1) Braking equipment; (2) Steering; (3) Visibility; (4) Lighting equipment and parts 
of the electrical system; (5) Axles, wheels, tyres, suspension; (6) Chassis and chassis attachments; (7) Other equipment;  
(8) Nuisance; (9) Supplementary tests for passenger-carrying vehicles of categories M2 and M3. 

3 

 
 
Member States have a larger room for manoeuvre. Any deficiency found on a vehicle must be categorised 
as minor, major or dangerous, with the latter two leading to the suspension of the vehicle’s authorisation to 
be used in road traffic. The Directive also sets out minimum requirements as regards the independence of 
testing centres and training of inspectors, testing equipment, and the content of the roadworthiness (PTI) 
certificate. The validity of that certificate, as well as any other proof of test, must be recognised by Member 
States  for the  purposes of  free  circulation  and  re-registration of  a vehicle  already registered in another 
Member State.  

The  RSI  Directive  complements  the  PTI  Directive  by  requiring  Member  States  to  carry  out  roadside 
inspections (RSI) on heavy commercial vehicles, i.e., buses, lorries, and their trailers (above 3.5t), with a 
target of 5% of the fleet each year. Those inspections must include an initial roadside inspection and, if 
deemed  necessary  by  the  inspector,  a  more  detailed  technical  roadside  inspection.  The  scope  of  those 
detailed inspections are the items tested at PTI and it may also include the inspection of cargo securing. 
When a major or dangerous deficiency is found during a RSI, the Member State where the inspection took 
place must notify the Member State of registration, in order to enforce the repair of the vehicle that has been 
suspended from traffic. 

Vehicle registration itself is a national competence. The VRD Directive specifies that Member States must 
issue registration certificates for vehicles that are subject to registration under their national legislation. It 
requires that those certificates be issued in either paper or smart card format. The certificates must contain 
a  minimum  set  of  mandatory  data  elements,  may  contain  certain  optional  data  elements,  and  must  be 
recognised among Member States for the purpose of re-registration. The Directive requires certain vehicle 
data to be registered electronically, including the suspension from traffic following a failed PTI, and the 
cancellation of registration where a vehicle has been treated as an end-of-life vehicle in accordance with 
Directive 2000/53/EC28. 

The most recent act adopted by the Commission in the area of roadworthiness testing is a recommendation 
on particle number (PN) measurement at the periodic technical inspection of diesel vehicles29. Although 
non-binding,  the  recommendation  aims  at  harmonising  the  methods  of  such  measurements  and  the 
corresponding pass/fail limit instead of the introduction of various methods at national and regional level. 
Similar Commission recommendations on the assessment of defects during roadworthiness testing have 
served  as  basis  for  the  minimum  requirements  concerning  the  contents  and  recommended  methods  of 
testing under the current PTI Directive30. 

Political context 

Although the PTI and RSI Directives were marginally amended through delegated acts31, to align them with 
updated vehicle categories in type-approval legislation32 and introduce the testing of eCall33 at PTI, the main 
rules remained the same since 2014. Due to rapid technological progress, some of these rules are however 
already outdated. For this reason, the Sustainable and Smart Mobility Strategy34 called for adjustments to 
the  roadworthiness  legislative  framework  to  ensure  lifetime  compliance  of  vehicles  with  emission  and 

28 https://eur-lex.europa.eu/eli/dir/2000/53/oj  
29 https://eur-lex.europa.eu/eli/reco/2023/688/oj  
30 https://eur-lex.europa.eu/eli/reco/2010/378/oj  
31 https://eur-lex.europa.eu/eli/dir_del/2021/1717/oj and https://eur-lex.europa.eu/eli/dir_del/2021/1716/oj  
32 Regulation (EU) No 168/2013; Regulation (EU) No 167/2013; Regulation (EU) No 2018/858 
33 https://eur-lex.europa.eu/eli/reg/2015/758/oj  
34 COM(2020) 789 final 

4 

 
 
safety  standards,  thereby  contributing  to  the  EU  Road  Safety  policy  framework  2021  -  203035  and 
supporting the European Green Deal’s objectives. 

Roadworthiness inspections of vehicles are fundamental to road safety and to ensure the environmental 
performance of vehicles during their lifetime. As a result of stricter safety and emission legislation, vehicles 
in the EU have become technically ever more complex. To keep pace with this trend, certain adaptations to 
how vehicles are inspected are necessary. In addition, enhanced and more effective EU-wide exchange of 
roadworthiness-relevant vehicle data would help better enforcement of the rules, improving the functioning 
of the internal market and protecting citizens from fraudulent malpractices, such as odometer tampering36. 

During the  last  five  years, the  European  Parliament  published  a number of  related  reports  and  studies, 
including a resolution on the implementation of the Roadworthiness package in general37 and on the specific 
issue of odometer fraud38. In these documents, the Parliament pointed at the insufficient decrease in road 
fatalities and a massive divergence between Member States, highlighting the importance of independent 
inspections in the wake of emission scandal, the issue of odometer tampering, especially cross-border, as 
well as the need for further harmonisation of test  methods and updates  required by the introduction of 
advanced  driver  assistance  systems  and  automated  driving  features.  The  Parliament  called  on  the 
Commission to consider tightening the test regime by introducing the obligation of additional checks after 
reaching a specified mileage for cars used as a taxi or ambulance and for vans, ending the exemption of 
motorcycles  from PTI  and  introducing mandatory testing of  powered  two-  and three-wheelers  with  an 
engine  below  125  cm3  and  light  trailers.  In  the  resolution  on  the  specific  issue  of  odometer  fraud,  the 
Parliament drew the attention to the economic and legal significance of odometer fraud in the EU  and 
requested the Commission to submit a proposal for a legislative framework to prevent odometer fraud. 

Synergies with other EU policy instruments  

Roadworthiness testing relies on the technical specifications of the vehicles that are harmonised at EU level 
and  beyond  (UNECE39).  Vehicle  registration  remains  a  national  competence,  although  it  relies  on  the 
Certificate of Conformity also defined in type-approval legislation40. The most recent and relevant safety- 
and emissions-related type-approval regulations are the General Safety Regulation (GSR)41 and the Euro 
7 Regulation (EU) 2024/125742. The GSR requires that, from July 2022, new types of motor vehicles are 
equipped with advanced driver assistant systems aimed at reducing the number of fatalities and serious 
injuries; these will also be used in automated vehicles. At the time of preparing this impact assessment, it 
was expected that the co-legislators would adopt the Euro 7 standards replacing existing emission rules 

35 http://eur-lex.europa.eu/resource.html?uri=cellar%3A0e8b694e-59b5-11e8-ab41-
01aa75ed71a1.0003.02/DOC_2&format=PDF  
36  An  odometer  is  an  instrument  measuring  the  distance  travelled  by  a  vehicle.  Odometer  fraud  or  tampering  is  the 
disconnection,  resetting  or  alteration  of  a  vehicle’s  odometer  with  the  intention  to  change  the  number  of  kilometres 
indicated. Both digital and analogue odometers can be tampered with and changed. Many newer vehicles have digital 
control units or computers that may allow for the odometer to be replaced or re-programmed using fraudulent software. 
37  European  Parliament  resolution  of  27  April  2021  on  the  implementation  report  on  the  road  safety  aspects  of  the 
Roadworthiness Package (2019/2205(INI)), https://www.europarl.europa.eu/doceo/document/TA-9-2021-0122_EN.pdf 
and https://www.europarl.europa.eu/RegData/etudes/STUD/2020/654175/EPRS_STU(2020)654175_EN.pdf  
38 European Parliament resolution of 31 May 2018 with recommendations to the Commission on odometer manipulation 
in  motor  vehicles:  revision  of  the  EU  legal  framework:  https://www.europarl.europa.eu/doceo/document/TA-8-2018-
0235_EN.html, 
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf 
https://www.europarl.europa.eu/RegData/etudes/STUD/2017/602012/IPOL_STU(2017)602012_EN.pdf  
39 World Forum for Harmonization of Vehicle Regulations of the United Nations Economic Commission for Europe 
40 https://eur-lex.europa.eu/eli/reg/2018/858/oj  
41 https://eur-lex.europa.eu/eli/reg/2019/2144/oj  
42 Regulation - 2024/1257 - EN - EUR-Lex  

and 

5 

 
 
for cars and vans (Euro 6) and lorries and buses (Euro VI), thus ensuring that new vehicles are cleaner in 
real driving conditions and that they remain clean for longer than required by the existing (durability) rules. 
However, the actual gains in emissions reduction are likely to be significantly reduced due to the final text 
adopted by Council and by the European Parliament. In line with the Council position, the new rules keep 
the  Euro  6  standard  for  cars  and  vans  as  regards  exhaust  emissions43,44.  This  means  that  the  expected 
baseline emission reductions will not materialise, thus increasing the potential impact of roadworthiness 
testing in general, and this initiative in particular. 

The focus of the RWP is different from the market surveillance legislation mentioned above. Whereas 
market surveillance provisions aim to ensure that vehicles continue to meet their type-approval requirements 
when  placed  on  the  market  and  for  a  limited  period  thereafter,  and  so  are  effectively  focusing  on  the 
responsibilities of the manufacturer, the RWP focuses on ensuring that minimum standards are maintained 
by owners throughout the lifetime of the vehicle. Also, while market surveillance requires testing a limited 
number of vehicles per model, PTI applies to almost all registered vehicles. Thus, the RWP complements 
the market surveillance legislation in ensuring road safety and the environmental performance of vehicles 
during their lifetime. Applying the best available test methods will also help Member States reach the 
stricter  air  quality  standards  (limit  values  for  the  protection  of  human  health)  set  by  the  revised 
Ambient Air Quality Directive45, notably as regards fine particulate matter and nitrogen oxides. 

The Commission is also currently working on an initiative on fair and non-discriminatory access to in-
vehicle data46, which is crucial for technical inspection centres to be able to carry out their daily tasks. That 
initiative will include provisions on access to functions and resources, essential for the provision of data-
dependent services in the automotive sector. It will standardise the relevant datasets and ensure effective 
non-discriminatory and secure access for aftermarket and mobility services. A range of automotive service 
providers, including vehicle repair and inspection companies and authorities have called for an ambitious 
Commission proposal, to ensure a level-playing field and unhindered access to the relevant in-vehicle data47. 
The revision of the PTI Directive could complement the access to in-vehicle data proposal, through specific 
provisions facilitating access to the data necessary for technical inspections. More details on synergies with 
other EU policy instruments are provided in Annex 16. 

Evaluation of the Roadworthiness Package 

The Commission conducted an evaluation of the RWP ‘back-to-back’ with this impact assessment. The 
evaluation concluded that the RWP was partially successful in achieving its objectives, contributing to 
increased road safety, and helping reducing air pollutant emissions from road transport. Defective vehicles 
may still 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. The identified weaknesses in the current RWP require the Directives to be adapted, to 
address not only current needs but also future challenges. The links between the main conclusions of the 
ex-post evaluation and the impact assessment are summarised in Annex 11. The evaluation of the RWP is 
annexed to this impact assessment report (Annex 17). 

43 https://www.consilium.europa.eu/en/press/press-releases/2023/09/25/euro-7-council-adopts-position-on-emissions-
from-cars-vans-buses-and-trucks/  
44 https://eur-lex.europa.eu/eli/reg/2024/1257/oj 
45 Directive (EU) 2024/2881 of the European Parliament and of the Council of 23 October 2024 on ambient air quality 
and cleaner air for Europe (recast) 
46  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13180-Access-to-vehicle-data-functions-and-
resources_en  
47 See e.g. open letter from CITA: https://citainsp.org/wp-content/uploads/2023/03/L2023-006-Data-Act.pdf  

6 

 
 
Sustainable Development Goals 

The initiative contributes to Sustainable Development Goal (SDG) 3 (Ensure healthy lives and promote 
well-being for all at all ages), including targets 3.6 (halving the number of deaths and injuries from road 
traffic accidents) and 3.9 (substantially reduce the number of deaths and illnesses from hazardous chemicals 
and air, water and soil pollution and contamination). 

2.  PROBLEM DEFINITION 

The  problems,  underlying  problem  drivers  and  consequences  that  are  relevant  for  the  revision  of  the 
Roadworthiness Package are presented in Figure 2. The evidence underlying the problems and their drivers 
is based on the best available evidence, including multiple studies involving scientific research, as well as 
thorough consultation with experts. 

Figure 2: Problem tree 

2.1.  What is/are the problems? 

2.1.1.  Presence of unsafe vehicles on EU roads 

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 high costs to society. Despite the improvement in 
vehicle technology, including active safety and intelligent driver assistance systems in new vehicles, unsafe 
vehicles still contribute to crashes, either as the main cause or as a contributing factor. A part of unsafe 
vehicles is identified at PTI or RSI (i.e., vehicles with major or dangerous deficiencies). Others may not be 
detected either because PTI cannot detect them or because they are not subject to testing. These include 
vehicles with safety-related tampering and vehicles with incorrectly secured cargo. 

Comparable PTI data on vehicles with major and dangerous deficiencies are only available for ten Member 
States.  

7 

 
 
 
 
Table  1 shows the share of those vehicles by vehicle type and Member State, as well as the median by 
vehicle type. There is great variability between the PTI results of Member States for each vehicle type, 
which points to the need to interpret these data with care. A high share of vehicles with major and dangerous 
defects may also reflect variation in the stringency with which testing is applied in a particular country and 
not necessarily that vehicles are less roadworthy in that country. What is however clear is that the share of 
unsafe vehicles is significant in all Member States and for all vehicle types where such data is available.    

8 

 
 
 
Table 1: Share of vehicles with major and dangerous defects in the vehicle fleet, by vehicle type - averages over 
2018-2022  

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

While not even a well-developed roadworthiness testing system can detect every defective vehicle through 
PTI or RSI, not all defective vehicles will cause a crash either. Various studies48 indicate that their share as 
a contributing factor of the cause of crashes is between 3 and 19%, depending on the scope and methodology 
of the study; for motorcycles, it is 5% to 12% of crashes49. Since PTI has been in place in Europe for a long 
time, there are very few recent studies covering EU Member States50. There are similar studies from other 
parts of the world51, the most relevant of them being a recent US study52 that looked at the difference in 
crash rates between states with and without PTI. It shows that states with a safety inspection, even if only a 
very simple one for light vehicles, have 5.5% fewer fatalities on average.  

Naturally, older vehicles are prone to more frequent breakdowns, and studies have shown that older 
vehicles with defects contribute more to the causes of crashes53. The situation is not expected to improve 
by itself as the contribution of older vehicles is becoming an increasing concern with the gradual ageing of 
the vehicle fleet54. Since cars are responsible for by far the largest  share of fatalities (see collision 
matrix55 in Figure 3 below), and even if technical defects only represent a relatively small share among 
the causes of accidents, early detection of those defects can make a significant difference, especially 
in terms of road safety. 

48  Martín-delosReyes  L.M.  et  al.  (2021),  Effect  of  Periodic  Vehicle  Inspection  on  Road  Crashes  and  Injuries:  A 
Systematic Review, https://doi.org/10.3390/ijerph18126476  
49 Ricardo et al. (2023), Impact assessment support study on the directives of the roadworthiness package, Contract no. 
MOVE/C2/SER/2022-583/SI2.895928, under FWC no. MOVE/2022/OP/0001 
50 Hudec J. and Šarkan B. (2022), Effect of periodic technical inspections of vehicles on traffic accidents in the Slovak 
Republic. 
51 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  
52 https://ascelibrary.org/doi/10.1061/JTEPBS.TEENG-7320  
53  https://komunikacie.uniza.sk/artkey/csl-202203-0017_effect-of-periodic-technical-inspections-of-vehicles-on-traffic-
accidents-in-the-slovak-republic.php   
54  For  the  most  recent  report  on  the  vehicle  fleet,  see  e.g.:  https://www.acea.auto/publication/report-vehicles-in-use-
europe-2023/  
55 https://transport.ec.europa.eu/background/road-safety-statistics-2022-more-detail_en 

9 

TotalM1 (passenger cars)N1 (vans; <3.5 tonnes)N2 (small lorries;3.5-12 tonnes)N3 (large lorries ;>12 tonnes)M2 (buses/coaches <5 tonnes)M3 (buses/coaches >5 tonnes)O1 (trailers <0.75 tonnes)O2(trailers 0.75-3.5 tonnes)O3 (trailers 3.5-12 tonnes)O4 (trailers >12 tonnes)L3-L7 (motorcycles)AT11%8%11%11%10%3%4%8%10%5%DE21%25%26%26%16%16%14%14%14%14%8%DK19%15%15%16%16%8%8%20%20%ES18%24%30%30%26%26%26%26%26%26%18%FR20%24%15%15%14%15%16%13%HR22%28%33%22%35%25%14%11%13%16%10%LT48%50%52%43%55%48%24%24%34%34%35%LV38%44%55%44%29%22%12%22%44%42%17%SE25%SK12%17%23%18%22%23%4.70%31%21%8%Median20.7%24.3%25.5%23.6%22.0%22.0%12.9%13.7%20.0%20.0%10.0% 
 
 
Figure 3: Road traffic fatalities in the EU by road user and (other) ‘main vehicle’ involved in the crash 

Source: CARE database 

Since there is an element of uncertainty in the actual contribution of vehicle defects to road crashes, 
a sensitivity analysis was justified.56 The shares used in this impact assessment (4% for cars, vans, 
HDVs and 6% for motorcycles) are relatively conservative, e.g., compared to the range based on the 
literature review presented above. This approach was used to avoid overestimating the benefits. 

Secondly, there is an issue related to safety-related tampering, which includes the manipulation of engine 
performance,  torque,  maximum  speed  and  improved  acceleration,  representing  an  obvious  safety  risk. 
According to experts, the chip-tuning of electric vehicles is as easy as in the case of those equipped with 
internal combustion engines, with the added risk of an overheated battery, which can cause fire e.g., in the 
case of faster charging or faster discharging (higher performance). According to others, while the share of 
tampered cars in the entire fleet remains relatively low, their share is higher among those involved in crashes. 
Due to the nature of the problem, available data  on it is rather limited. The European Transport Safety 
Council, among other stakeholders, has highlighted the issue of safety-related tampering, notably in the case 
of powered two- and three-wheelers57. A survey carried out for the Austrian Ministry of Climate Protection, 
based on police inspections, found that roughly every second moped was manipulated (tuned) in Austria58.  

In addition, incorrectly stowed or secured cargo can slide, roll, tip over and fall off a vehicle, potentially 
causing it to overturn and lead to crashes with other vehicles59. To address this problem, the 2014 revision 
of  the  RSI  Directive  introduced  detailed  provisions  on  the  inspection  of  cargo  securing,  including  its 
principles, applicable standards, and the assessment of specific deficiencies (as an optional measure). This 
was  complemented  by  best  practice  guidelines60  prepared  by  a  Commission  expert  group  to  provide 
practical advice to anyone involved in loading/unloading and securing cargo, as well as to enforcers. The 
guidelines and the corresponding provision of the Directive are non-binding, however. In spite of existing 
rules, according to a major operation of Roadpol in Italy in 2019, 22% of the 40,500 inspected heavy goods 

56 Cf. section 6.2.1 and further details in section  6 of Annex 4. 
57 https://etsc.eu/wp-content/uploads/2020-09-ETSC-Briefing-on-Roadworthiness-Package-Implementation-
Reports_update16Oct.pdf  
58 https://www.bmk.gv.at/themen/verkehr/strasse/verkehrssicherheit/vsf/forschungsarbeiten/82_tune-it.html  
59 See e.g., Königsberger Ladungssicherungskreis: https://www.klsk.de/en/  
60 https://road-safety.transport.ec.europa.eu/eu-road-safety-policy/priorities/safe-vehicles/cargo-securing-and-abnormal-
loads_en  

10 

 
 
 
vehicles (HGVs) did not comply with cargo securing requirements61. 

The problem of unsafe vehicles affects not only the owners/users of the defective or tampered vehicles, but 
also  other  road  users,  especially  vulnerable  ones.  Such  example  of  vulnerable  road  users  are 
motorcyclists and while several factors play a role in motorcycle crashes, such as motorcycles’ and 
other  vehicles’  design  (motorcyclists  are  often  overlooked  in  traffic)  and  road  environment 
shortcomings (poor road surfaces, poor road alignment, obstacles, limited line of sight),  motorcycle 
design elements such as tyres, brakes, frame, suspensions are nonetheless very relevant for the safety 
of motorcyclists, and regular control  of their  technical  condition  is  considered important  for their 
road safety62. 

Society as a whole is affected by the external cost of crashes through human and medical costs, production 
losses, the cost of police, emergency services, congestion, etc.63 

More systematic and targeted testing of vehicles, using improved and updated test methods, could reduce 
the number of such avoidable crashes. 54 out of the 65 stakeholders who replied to the targeted survey 
agreed  with  the  problem  identified,  while  only  6  disagreed  and  5  were  neutral.  In  the  OPC,  78%  of 
respondents  (123 out  of  158)  agreed  that the issue  of vehicles  circulating on  the  roads with  defects  or 
tampered components needs to be addressed. 

2.1.2.  Insufficient control of vehicle air pollutant and noise emissions64 

Air pollution remains an important cause of poor health in Europe and contributes in particular to 
respiratory and cardiovascular diseases.65  

Road transport has significantly  reduced its pollutant  emissions since 1990, with  the exception of 
compounds  NH3 and  N2O.  Their  recent  increase  is  mainly  due  to  new  catalytic  systems  for  the 
reduction of NOx in diesel engines and the use of enriched fuel mixtures to control NOx at high load 
in petrol engines. While a significant reduction can be seen for both PM10 and PM2.5, the non-exhaust 
fraction of these emissions (i.e. from brake and tyre wear or road abrasion) is increasing66. 

 The  development  of  sophisticated  emission  control  technologies  has  allowed  to  gradually  reduce  air 
pollutant  emissions  from  road  vehicles  well  (orders  of  magnitude)  below  pre-Euro  standard  levels. 
However,  overall  emissions  from  road  transport  are  still  too  high  –  they  alone  are  responsible  for 
approximately  40.6%  of  the  total  NOx  and  10.5%  of  PM2.5  emitted  in  Europe67,  and  this  has  serious 
implications on human health, the natural environment, and affects the lives of millions, especially in urban 

61 https://etsc.eu/wp-content/uploads/PIN-FLASH39_FINAL.pdf  
62 ERSO Road Safety Thematic Report – Motorcycles, 2023, https://road-safety.transport.ec.europa.eu/european-road-
safety-observatory 
63  CE  Delft  et  al.  (2020),  Handbook  on  the  external  costs  of  transport  –  Version  2019  –  1.1,  Publications  Office, 
https://data.europa.eu/doi/10.2832/51388  
64 The problem analysis focuses on NOx and PM as the main air pollutants from road transport with the highest impact 
on environment and health. Other pollutants have not been considered although it is plausible that targeting these two 
pollutants will also affect other air pollutants (e.g. CO, HC, SO2). 
65  In 2021  in  the EU-27, 253,000 deaths  were  attributable  to  exposure  to PM2.5 concentrations  above  WHO’s  guideline  level of 5 
µg/m3 (micrograms per cubic metre of air), 52,000 deaths were attributable to exposure to NO2 concentrations above WHO’s guideline 
level of 10 µg/m3 and 22,000 deaths were attributable to short-term exposure to O3 concentrations above 70 µg/m3, EEA, Europe's Air 
Quality Status, 2023, Europe’s air quality status 2023 — European Environment Agency.  
66 EEA, Emissions of air pollutants from transport,  October 2024 Emissions of air pollutants from transport in Europe | European 
Environment Agency's home page 
67  EEA  (2023),  Air  Pollution  in  Europe;  2023  reporting  status,  https://www.eea.europa.eu/publications/national-
emission-reduction-commitments-directive-2023  

11 

 
 
areas. Various studies have shown that real-world NOx emissions of modern vehicles were above type-
approval limits68. Such exceedances can in some instances (due to tampering, for example) be as high as 
older Euro Standards or even pre-Euro NOx emission levels69. Other studies have shown that in the absence 
of the appropriate emission reducing technology (selective catalytic reduction (SCR) and diesel particulate 
filter (DPF)) on Euro VI HDVs, vehicles can emit up to a factor of 100 more NOx, CO, and PM than the 
legal requirements70. 

The findings of the RWP evaluation show that some of the tests used in PTI are no longer sufficiently 
sensitive to detect emission failures and the current testing procedures are not fit to meet the EU policy goals 
as regards air pollution. 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 able to measure 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. The measurement of nitrogen oxide 
emissions or PM/PN values for new cars are still not covered by the current RWP and there are currently 
no  EU  provisions  for  testing  vehicles  for  NOx  manipulation/defect  or  manipulation/defect  of  diesel 
particulate  filters.  The  share  of  vehicles  found  with  defective  emission  control  equipment  or  exhaust 
emissions above the limits specified in the PTI and RSI Directives ranges from around 1-3% to up to 45% 
depending on the Member State and the way checks are conducted. Targeted inspections identify higher 
shares of over-emitting vehicles. Periodic testing has demonstrated that older vehicles can be much more 
polluting than newer ones, as the effectiveness of emissions reduction systems declines with age. Since 
some of the defective vehicles emit multiple times over the regulatory limit, even a relatively limited share 
of such vehicles  can  be  responsible  for  a large  part of overall  road transport  emissions. This  has been 
demonstrated by various studies71. 

In addition, there is evidence72 that the emission control equipment of a non-negligible number of modern 
vehicles are tampered with, either to avoid immediate replacement of filters or the cost of consumables, 
such  as  diesel  exhaust  fluid  (DEF)73  required  for  the  proper  functioning  of  SCR74.  Various  tampering 
techniques  have been  developed  to  alter on-board diagnostic  information  and to  avoid that  the vehicle 
automatically switches to low-power (or limp) mode, e.g., after it has run out of DEF for a long time. This 
is consistent with the observation that a small number of “high emitters” are generally responsible for a 
disproportionate  fraction  of  the  overall  emissions  (e.g.,  a  TNO  study75  indicates  that  6%  of  vehicles 
defective emission control systems caused 36% of road transport NOx emissions). A recent study involving 
remote  sensing  technology  screening  a  large  number  of  vehicles  in  Flanders,  Belgium  showed  similar 
results for particle emissions due to DPF failures76. 

68 see e.g., TNO report on NOx emissions of eighteen diesel light commercial vehicles: 
http://resolver.tudelft.nl/uuid:21191e19-2dc7-4468-8559-1075ed6279f7  
69 Giechaskiel, F. et al. (2022), Effect of tampering on on-road and off-road diesel vehicle emissions. 
70 Ricardo et al. (2023), Impact assessment support study on the directives of the roadworthiness package, Contract no. 
MOVE/C2/SER/2022-583/SI2.895928, under FWC no. MOVE/2022/OP/0001Ricardo et al. (2023), Impact assessment 
support study 
71  Such  as  TNO  (2022),  http://resolver.tudelft.nl/uuid:b5d127c3-303c-4013-b1ac-c9ac01f66e2d  and  CARES  (2023), 
https://cares-project.eu/emission-factors-lez-impact/  
72 Notably from roadside checks reported by inspectors of national authorities, including with the use of plume chasing 
technology: https://citainsp.org/wp-content/uploads/2021/11/5-CITA-17-11-2021-for-upload.pdf  
73 Diesel exhaust fluid (DEF), also known as AUS 32 (aqueous urea solution 32%) and marketed as AdBlue. 
74 A basic illustration of the main components of an exhaust aftertreatment system is available at: 
https://www.autoserviceworld.com/understanding-diesel-exhaust-aftertreatment-systems/  
75 TNO report on NOx emissions of eighteen diesel light commercial vehicles: http://resolver.tudelft.nl/uuid:21191e19-
2dc7-4468-8559-1075ed6279f7 
76  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.  

12 

 
 
As regards the impacts of the problems on pollutant emissions, the links between cause and effect 
are  more  straightforward  than  in  the  case  of  road  safety.  Even  though  in  the  absence  of  accurate 
emission testing available on a wide scale, the share of high-emitting vehicles and their contribution 
to  total  emissions  can  only  be  estimated,  the  available  studies  applying  portable  emission 
measurement  systems  (PEMS),  recent  remote  sensing  campaigns  and  the  first  results  of  newly 
introduced particle number (PN) testing in three Member States provide a high level of confidence 
as regards the scale of the problem, and the calculations of the impacts.77 

As outlined in section 1, road transport is by far the largest source of noise pollution in Europe and is the 
second most harmful environmental stressor after air pollution78. Modified or defective exhaust systems 
can also contribute to noise pollution. The threshold of noise above which it is considered a nuisance can 
vary. In the OPC, 91 out of 149 respondents expressed the view that it is very important to address the 
problem of noise-related tampering/non-compliance in vehicles and 13 had no opinion. Most respondents 
to the survey and interviews conducted as part of the evaluation believed that technological and market 
developments had had a low impact on reducing the number of vehicles with tampered or defective noise 
control  systems  (46  of  75  respondents;  15  did  not  know  or  did  not  respond).  Representatives  of  the 
automobile  as  well  as  motorcycle  manufacturers  (ACEA  and  ACEM)  agree  that  illegal  modifications 
leading to single-event noise peaks need to be addressed through consistent control79. 

While these vehicles are supposed to be repaired or taken out of circulation, there are still many vehicles 
with defective or tampered emission control systems that go undetected and continue to cause avoidable 
damage. Noise tampering mainly affects powered two-wheelers, which are not subject to roadworthiness 
testing in every Member State. The problem of air pollution and noise generated by vehicles mainly affects 
people living in the vicinity of major roads, in particular in urban areas, and especially the most vulnerable. 
Lower income groups tend to be exposed to higher levels of air pollution, while older people, children, 
adolescents, and those with pre-existing health conditions are more susceptible to negative effects of air 
pollution80.  56  out  of  the  67  stakeholders  who  replied  to  the  targeted  survey  agreed  with  the  problem 
identified, while only 4 disagreed and 7 were neutral. 

2.1.3.  Roadworthiness Directives are not effective in enforcing rules in EU cross-border 

traffic and trade of vehicles 

One of the objectives of the RWP was to facilitate free movement for EU citizens and ensure the smooth 
functioning of the internal market81. This is reflected in different elements of the RWP, including the mutual 
recognition  of  roadworthiness  certificates  among  EU  Member  States  (as  part  of  the  PTI  Directive),  in 
combination with the provisions of the VRD Directive aiming to ensure the authenticity, accuracy, and 
mutual recognition of vehicle registration documents across EU Member States. Brought together, these 
should facilitate the enforcement of the rules, efficient cross-border transport, and prevention of fraudulent 
practices, eventually contributing to better road safety and less polluting vehicles on the roads. 

According to the findings of the evaluation, communication between authorities across national borders 
improved  following  the  adoption  of  the  RWP.  The  PTI  and  RSI  Directives  established  contact  points 
through  which  information  can  be  more  swiftly  exchanged  between  Member  States.  However,  the 

77 see e.g. DIAS (2022), D6.5 Impact assessment and guidelines for future anti-tampering regulations, or TNO (2022), 
Approaches for detecting high NOx emissions of aged petrol cars during the periodic technical inspection. R10659v2 
78  https://www.eea.europa.eu/publications/managing-exposure-to-noise-in-europe/noise-in-europe-updated-population-
exposure  
79 https://www.acea.auto/files/ACEA-position-paper-Vehicle-noise-setting-appropriate-limits.pdf and 
https://acem.eu/images/publiq/2021/ACEM_Position_Paper_Sound_Emissions_2021.pdf  
80  https://www.eea.europa.eu/en/topics/in-depth/air-pollution  
81 Cf. recitals 1 and 3 of the Directive 1999/37/EC (VRD) and recital 24 of Directive 2014/45/EU (PTI) 

13 

 
 
evaluation also highlighted that Member States still report difficulties in effectively enforcing road safety 
measures  in  EU  cross-border  traffic  and  vehicle  trade.  These  have  their  origin  in:  (a)  Member  States 
registering different sets of vehicle data, and (b) difficulties for competent authorities in accessing vehicle 
register data and other safety-relevant information of vehicles, notably when these are registered in another 
Member State. These difficulties make the re-registration of vehicles less efficient and more cumbersome 
for  citizens82.  Related  to  cross-border  trade  of  vehicles,  the  evaluation  of  the  RWP  found  some 
incoherencies between the VRD Directive and Regulation (EU) 2018/858 on type-approval requirements83: 
in some cases, in the VRD Directive, definitions of the vehicle registration data and terminology do not 
correspond to those in the type-approval legislation. This leads to confusion and potential errors in recording 
vehicle information at the time of re-registration. Furthermore, difficulties in the cross-border exchange of 
information between Member States’ authorities can also negatively impact the fight against the widespread 
malpractice of odometer tampering which, by itself, can negatively affect road safety and the environment 
(due to poorer maintenance).  It is  also directly  affecting  consumers  given that mileage is an important 
determinant of used vehicles’ market value.  

Odometer tampering rates were estimated at 20 to 40% for cars imported in EU15 countries and 30 to 80% 
in EU12, according to a study commissioned by the European Parliament84, while other studies indicate the 
share of tampered vehicles to be between 5 and 12% of used cars in national sales and much more, between 
30 and 50%, of cross-border sales85. According to the support study of the European Parliament’s 2018 
resolution on odometer manipulation in motor vehicles in the EU, the total economic costs of odometer 
fraud in second-hand cars traded cross-border in the EU could be estimated at around EUR 8.77 billion per 
year86. This was found mainly due to the lack of effective cooperation between Member States' authorities 
and an insufficient exchange of information on mileage readings of odometers in vehicles traded across the 
Member States' borders. More recent estimates provided by CarVertical87, based on analysis of vehicle 
history reports, suggest overall lower odometer fraud rates for most of the countries reported that those in 
the European Parliament study.  Drawing on CarVertical and other assumptions, the impact assessment 
support study88 shows however that fraud rates are still estimated to be significant (i.e., 2.2 to 10% of used 
cars in national sales and 4.4 to 25.7% of cross-border sales)89. 

Even though odometer manipulation is a punishable offence under the PTI Directive, the fact that odometer 
readings are recorded only at PTI does not prevent fraud since most cars and vans are not tested before they 
are four years old and, in most Member States, only every two years thereafter. Furthermore, the evaluation 
of the RWP also reported that regarding the obligation to introduce effective and dissuasive penalties when 
an odometer is found to have been manipulated, the national measures appear in many cases rather generic, 
not specifically aimed at odometer fraud. 39 out of the 60 stakeholders who replied to the targeted survey 
agreed with the problem identified, while only 5 disagreed and 16 were neutral. 

82 As illustrated by various complaints and SOLVIT requests received by the Commission. 
83 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018R0858  
84 TRT (2017), Research for TRAN Committee (European Parliament) - Odometer tampering: measures to prevent it. 
85 https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf   
86 https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf   
87  Overall  mileage  fraud  analysis  is  available  at:  https://www.carvertical.com/blog/research-what-countries-have-the-
index: 
in 
highest-percentage-of-cars-with-a-fake-mileage, 
https://www.carvertical.com/transparency-index. Specific analysis of the share of odometer tampering for national and 
imported second hand vehicles is available at: https://www.carvertical.com/blog/research-local-or-imported-cars-have-
more-mileage-rollbacks.  
88 Ricardo et al. (2023), Impact assessment support study on the directives of the roadworthiness package, Contract no. 
MOVE/C2/SER/2022-583/SI2.895928, under FWC no. MOVE/2022/OP/0001 
89 See Annex 4 (section 2) for more detailed explanations on the estimations, and an overview by Member State.  

the  CarVertical  Market 

transparency 

and 

14 

 
 
2.2.  What are the problem drivers? 

2.2.1.  PTI-methods  not  available  to  test  electric  vehicles,  electronic  safety  &  driver 

assistance systems (PD1) 

This problem driver links to problem 1 (Presence of unsafe vehicles on EU roads). The existing rules on 
roadworthiness testing were designed more than 10 years ago, with the Commission’s proposal made in 
2012. At the time, the share and expected development of the electric vehicle (EV) market was significantly 
lower than today90, which explains why there are no EV-specific requirements in the PTI Directive. The 
same applies to electronic safety and driver assistance systems. 

The General Safety Regulation91 requires that, from  6 July 2022, new vehicle types are equipped with 
certain  advanced  driver  assistance  systems  (ADAS),  including  intelligent  speed  assistance,  reversing 
detection with camera or sensors, attention warning in case of driver drowsiness or distraction, event data 
recorders, an emergency stop signal (in all road vehicles), as well as lane keeping systems and automated 
braking in cars and vans. These features will be mandatory on all vehicles registered from  7 July 2024 
onwards. Thanks to the requirements of the GSR, new car and van models sold since July 2022 and every 
new vehicle sold from July 2024 will be due for PTI between 2026 and 2028. Trucks and buses featuring 
technologies helping to recognise blind spots, warnings to prevent collisions with pedestrians or cyclists 
and  tyre  pressure  monitoring  systems  will  have  to  undergo  their  first  roadworthiness  tests  even  earlier 
(usually one year after the first registration).  

The RWP evaluation found that systems introduced by the revision of the GSR increases the relevance of 
vehicle  roadworthiness  testing  to  verifying  the  operation  of  these  mandated  electronic  systems.  These 
systems may malfunction, require software updates to ensure intended performance, and they could be the 
target of tampering. In terms of keeping up of the RWP with the technological and scientific progress, most 
of the stakeholders interviewed in the context of the evaluation considered that it is essential to update the 
directives to include the functioning of ADAS and advanced lighting, which have been fitted in cars for 
around a decade but are not tested by standard PTIs. Similarly, the survey respondents, especially ministries, 
road safety authorities and PTI bodies, considered that the current RWP directives and their objectives 
follow technological advancement only to a limited extent. The technology used in vehicles has surpassed 
what the current directives cover and new rules for inspection of new safety systems, such as ADAS, are 
needed.  Although  both  EVs  and  ADAS  bring  about  significant  benefits  by  reducing  emissions  and 
improving road safety, they also come with new risks to be mitigated. In the case of EVs, including plug-in 
hybrids, the high voltage systems can be a source of such risks, which, if damaged, can overheat and cause 
fire. While a few Member States have introduced national requirements (e.g., FR, NL) in relation to the 
inspection of EVs, these are not generally applied in the EU. For ADAS, it is the possible malfunctioning 
of the systems themselves that may create safety hazards. However, none of these are currently tested during 
periodic technical inspections. 

Next to the research and development efforts needed to define the appropriate test methods, an important 
barrier to their application is the difficulty for inspection centres to access the necessary in-vehicle data. 
Although  the  Commission  Implementing  Regulation  (EU)  2019/621  requires  that  manufacturers  make 
certain vehicle data available to facilitate PTI tests, it does not apply to the data related to items/components 
that are not part of the current minimum requirements on items to be tested. According to the findings of 
the evaluation, there is data incoherence between the RWP and relevant type-approval legislation due to 

90 While there were only about 200,000 EVs, including PHEVs, in Europe in 2014 (and much fewer in 2012 when the 
proposal  was  made),  in  2022,  there  were  7.8  million  EVs  on  European  roads,  https://www.iea.org/reports/global-ev-
outlook-2023/trends-in-electric-light-duty-vehicles   
91 https://eur-lex.europa.eu/eli/reg/2019/2144/oj 

15 

 
 
divergence of safety-relevant vehicle data.  The  interview  respondents  considered there  was  a  common 
problem with the RWP regarding 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 use of reference data very difficult and time-consuming. 74% of the OPC 
responses (116 out of 156) were in favour of the need to address this problem driver; a similar percentage 
of support was expressed by industry representatives during the targeted survey (58 out of 76 responses). 

2.2.2.  Current PTI & RSI-methods not suited to measuring the emission performance of 

modern vehicles (PD2) 

This problem driver affects problem 2 (Insufficient control of vehicle air pollutant and noise emissions). 
The existing Directives require exhaust gas emission testing of diesel vehicles using opacity measurement, 
or, in the case of Euro 5/V and Euro 6/VI vehicles, by reading the vehicle’s on-board diagnostic (OBD) 
system. While exhaust gas opacity testing may detect a defective emission control system without a particle 
filter in an older vehicle (pre-Euro 5/V) and has thus been considered sufficient to test the compliance of 
those  vehicles,  multiple  laboratory  tests92  have  proved  that  it  cannot  detect  a  malfunctioning  or  even 
tampered diesel particle filter (DPF). DPFs were introduced to comply with significantly stricter limits than 
before Euro 5/V and the emissions without a DPF could be about an order of magnitude (or two) higher93. 
Even in a Euro 4 vehicle equipped with a defective DPF, the exhaust’s opacity may be lower than the 
instruments’ resolution. Studies have also shown that even when high smoke emissions are measured, in 
most cases the OBD does not indicate any failure. 

Furthermore, while the newly developed method of particle number (PN) counting94 has demonstrated high 
levels of particle emissions in vehicles with defective DPFs, e.g., close to 10% of Euro 5 and 6 vehicles 
tested in Belgium in 2022, the OBD showed malfunctioning in only 0.72% of the cases95. This illustrates 
the extent to which the current emission test requirements of the PTI and RSI Directives are obsolete and 
inadequate concerning modern diesel vehicles. Concerns about the ineffectiveness of smoke opacity tests 
were also expressed by stakeholders surveyed during the evaluation. The applicability of PN measurement 
has not yet been sufficiently tested for vehicles equipped with positive ignition engines, but relevant research 
is ongoing. To address the issue of high NOx emissions, various methods have been studied to measure 
them96. However, while NOx emission limits are set by type-approval, and RDE (Real Driving Emissions) 
tests have significantly tightened the requirements on new vehicles, the monitoring of NOx emissions from 
road vehicles is currently not part of PTI. 

92 Such as those carried out by the Commission’s Joint Research Centre: Comparisons of Laboratory and On-Road Type-
Approval  Cycles  with  Idling  Emissions.  Implications  for  Periodical  Technical  Inspection  (PTI)  Sensors, 
https://doi.org/10.3390/s20205790  and  Evaluation  of  Measurement  Procedures  for  Solid  Particle  Number  (SPN) 
Measurements during the Periodic Technical Inspection (PTI) of Vehicles, https://doi.org/10.3390/ijerph19137602. 
93 See e.g., https://environnement.brussels/media/1883/download?inline  
94 Already applied by Belgium, the Netherlands, Germany as well as Switzerland, and referred to in the Commission’s 
recommendation on particle number measurement, https://eur-lex.europa.eu/eli/reco/2023/688/oj. 
95 Figures reported by GOCA Vlaanderen for July 2022-April 2023: 12.4% of Euro 5 and 2.8% of Euro 6 vehicles failed 
with  the  current  1.000.000  1/cm3  limit;  16.8%  and  4.8%,  respectively,  would  have  failed  the  recommended  limit  of 
250.000 1/cm3. 
96  E.g.,  Fernández  (2022),  Suitability  Assessment  of  NOx  Emissions  Measurements  with  PTI  Equipment, 
https://doi.org/10.3390/vehicles4040050;  CITA  (2022),  Monitoring  of  NOx  emissions  as  part  of  the  PTI  –  CITA 
International  Motor  Vehicle  Inspection  Committee  (citainsp.org);  Franzetti  et  al.  (2023),  Assessment  of  a  NOx 
Measurement  Procedure 
(PTI)  of  Light-Duty  Diesel  Vehicles, 
https://doi.org/10.3390/en16145520.  

for  Periodic  Technical 

Inspection 

16 

 
 
2.2.3.  Limited  technical  possibilities  to  detect  vehicles  with  defective  or  tampered 

components (PD3) 

This problem driver is linked to all three problems. Firstly, together with PD1 (PTI-methods not available 
to test electric vehicles, electronic safety & driver assistance systems), it is one of the reasons why there are 
still, and will continue to be, unsafe vehicles on the roads. While new vehicle technology may require new 
ways of testing (PD1), there are vehicles on the roads today with defects that carry a potential safety risk 
and that PTI cannot detect, notably due to the limited vehicle data available to testing centres (or repair 
shops). For example, where a windscreen of a vehicle equipped with cameras is replaced, precise calibration 
requires not only the manufacturer’s specifications, but also the vehicle’s relevant data history (which for 
some vehicles can provide details of the last time the vehicle underwent a recalibration). Such information 
is currently not available to PTI. 

Similarly, unauthorised modifications to the vehicle’s engine management system to increase its power may 
not be  detected  without  access to the relevant in-vehicle  data97. Such tampering is relatively  easy,  and 
devices are widely available, for internal combustion engines as well as for electric vehicles (a simple web 
search would deliver multiple results). The situation is similar in the case of motorcycles98. The ongoing 
electrification of powered two-wheelers, especially mopeds, has apparently led to an increase in the same 
kind of tampering of those vehicles, with multiple tutorials available online. Since manipulation is so easy 
in the case of these vehicles, it is difficult to detect it even where such vehicles are subject to periodic testing 
as  the  modifications  can  also  be  easily  reversed.  These  vehicles  represent  an  increased  safety  risk,  in 
particular in urban areas. 

Secondly, tampering with emission control systems is equally easy with various solutions offered online99, 
even explaining why it is “good” for the user to disable the selective catalytic reduction (SCR) system, 
which requires diesel exhaust fluid (DEF, or AdBlue). While DEF is a necessary consumable for the SCR 
to significantly reduce the amount of NOx emissions, since running out of DEF may cause the vehicle not 
to start, it is a convenient (and often significantly cheaper) solution to deactivate the entire system. It can be 
especially viable in the case of commercial vehicles, where entire fleets may be tampered to decrease repair 
and maintenance costs100. Together with PD2 (Current PTI & RSI-methods not suited to measuring the 
emission  performance  of  modern  vehicles),  this  contributes  to  the  insufficient  control  of  vehicle  air 
pollutant and noise emissions. Noise-related tampering, i.e., removing the exhaust silencer (or dB killer) 
of a motorcycle is similarly easy with abundant instructions available online. According to ACEM and some 
experts in vehicle testing, PTI is not sufficiently effective when it comes to such tampering. 

Thirdly, tampering with odometers is also a lucrative business and detecting it has been a challenge across 
the EU, which negatively affects the effectiveness of the RWP in enforcing rules in EU cross-border 
traffic and trade of vehicles. Recording odometer readings at PTI may have somewhat improved the 
traceability of odometer history, or helped detect fraud (likely too late, when the vehicle is due for PTI with 
its new owner). However, with PTI being a pre-announced inspection, it is not difficult to readjust the 
mileage of the vehicle just before or after. Thus, in the absence of a better way to trace odometer history, 

97 Before a recent fatal crash in Budapest, the maximum power of the vehicle causing the crash was increased from 612 
to 690hp without it being noticed at PTI. 
98 See e.g. https://buy-tuning-files.com/chiptuning/why-modify-your-motorcyles-rev-limiter-and-how-to-do-it/  
99 See e.g., https://117speed.co.uk/adblue-removal-everything-you-need-to-know/; 
https://www.canbusemulator.com/en/  
100 See e.g., a case uncovered in Spain: https://www.guardiacivil.es/es/prensa/noticias/6944.html and 
https://www.europol.europa.eu/media-press/newsroom/news/haulier-in-spain-caught-cheating-emission-regulations-
designed-to-prevent-air-pollution  

17 

 
 
mileage tampering remains largely possible in most Member States, and especially across borders101. 

2.2.4.  Vehicle identification &  status data not sufficiently available to, and recognised 

among, enforcing authorities (PD4) 

This problem driver links to problem 3 (Roadworthiness Directives are not effective in enforcing rules in 
EU cross-border traffic and trade of vehicles). In addition to the issues mentioned under PD3, the inefficient 
exchange  of  information  among  Member  States  further  contributes  to  limiting  the  effectiveness  of  the 
Directives. While most stakeholders consider that the RWP has contributed to facilitating communication 
among Member States, they agree that vehicle identification and status data are still not sufficiently available 
to enforcing authorities. As mentioned in Section 2.1.3, there are sometimes significant differences in the 
data  elements  recorded  in  national  vehicle  registers,  largely  due  to  the  high  number  of  optional  data 
elements, including those that are not even specified in the VRD Directive. Table 2 summarises the diversity 
in the registration of various data elements. 224 data elements are stored by only some of the Member States 
(i.e., not by all, and not by any of them). 

Table 2: Summary of the registration of various data elements 

Number of data elements M1  Percentage of the MS that stores the item 

11 
23 
135 
66 
38 

11 data elements were stored by all of the MS (100%) 
23 data elements were stored by a clear majority of the MS (80% – 99 %) 
135 data items were stored by a substantial number of MS (30% – 79 %) 
66 data elements were stored by a minority of the MS (1% – 29 %) 
38 data elements were stored by none of the MS (0%) 

Source: EReg/EUCARIS102 

In addition to the regulatory framework provided by the VRD Directive, EReg, the Association of European 
Vehicle and Driver Registration Authorities, has worked on the voluntary harmonisation of registration 
procedures and data quality, including on the scope of data that should be stored in vehicle registers  to 
facilitate cross-border trade (re-registrations) and issued various reports on the topic103.  

Although the VRD Directive requires Member States to assist one another in the implementation of the 
Directive, it merely allows exchange of information and only hints at the possibility that this could be done 
electronically. This has led to a situation where several Member States use EUCARIS104 for the exchange 
of vehicle registration data, mileage data, PTI data or roadside inspection (RSI) reports. However, while 
many  Member  States  use  EUCARIS  for  various  services,  not  all  of  them  use  it  systematically  for  the 
relevant exchange of data. The lack of clear rules as regards the exchange of vehicle related information 
among Member States therefore further complicates smooth communication between authorities. 

To implement requirements of the RSI Directive to notify the Member State of registration of any major or 
dangerous deficiencies found at RSI, since June 2020, the notifications must be sent using the RSI system105, 
built on the functionalities of the European Register of Road Transport Undertakings (ERRU). ERRU and 

101 While Belgium and the Netherlands have introduced dedicated systems with databases keeping much more frequent 
odometer readings than what PTI can offer, and thus significantly reducing odometer fraud in both countries and between 
them, such systems do not exist elsewhere and detecting odometer fraud, especially in imported vehicles, is less likely. 
102 https://www.ereg-association.eu/media/2742/final-report-topic-group-xxi-proposal-on-the-registration-of-vehicle-
data.pdf  
103 https://www.ereg-association.eu/topic-groups/topic-group-xxi/  
104 EUCARIS (European Car and Driving Licence Information System) is a system developed by and for governmental 
authorities  to  help  fighting  car  theft  and  registration  fraud.  It  enables  the  sharing  of  vehicle  and  driving  licence 
information between EU and non-EU countries: https://www.eucaris.net/  
105  Commission  Implementing  Regulation  (EU)  2017/2205  on  detailed  rules  concerning  the  procedures  for  the 
notification  of  commercial  vehicles  with  major  or  dangerous  deficiencies  identified  during  a  technical  roadside 
inspection: https://eur-lex.europa.eu/eli/reg_impl/2017/2205/oj  

18 

 
 
RSI  messaging  system,  as  well  as  several  other  road  transport-related  applications  are  hosted  by  the 
Commission  and  use  a  central  hub  (MOVEHUB)  to  interconnect  national  registers.  While  certain  EU 
legislation  requires  the  use  of  EUCARIS106,  and  others,  including  the  RSI  Directive,  refer  to  the 
MOVEHUB  for  data  exchange,  there  is  no  legal  requirement  to  use  such  systems  to  facilitate  the  re-
registration of vehicles and the implementation of the PTI and VRD Directives. The inability to effectively 
exchange a real-time data on the vehicle (de)registration status, including the information on cases when a 
vehicle  is  temporary  de-registered  or  its  ownership  has  changed,  contribute  to  the  problem  of  a  low 
traceability of vehicles across the EU. Such administrative and regulatory failures hinder the uncovering of 
illegal activities such as the illegal trade or illegal dismantling of vehicles, leading to the problem known as 
“missing vehicles”107. 

Certain optional data registered in one Member State are not recognised by another EU country for re-
registration. The reason is that the second Member State registers a different set of data. This may concern 
data related to the owner, the mass, the category, or the exhaust emissions of the vehicle. Moreover, even 
though there is significant level of harmonisation in roadworthiness testing, there are very few cases where 
the Member State of registration recognises the validity of a PTI certificate issued in another Member State 
(one example is the Netherlands accepting PTI conducted in certain PTI centres in Spain). Such lack of 
recognition of registration data and PTI reports lead to inefficiencies in administrative processes and cause 
avoidable administrative burden for vehicle owners. 

Stakeholders consulted during the evaluation 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. 67% of the OPC responses (100 out of 149) were in 
favour of the need to address this problem driver; a similar percentage of support was expressed by industry 
representatives during the targeted survey (47 out of 72 responses). 

2.2.5.  Certain vehicles are not (sufficiently) tested for their roadworthiness (PD5) 

Problem driver 5 relates to the fact that certain vehicle categories are not covered by or not necessarily tested 
under the PTI/RSI Directives and, as a result, PTI/RSI is only required for such vehicles in a few Member 
States. Furthermore, frequency or scope of testing of certain vehicles is not adapted to the higher safety and 
environmental risk associated with them (very frequent use or vehicle age). This directly affects the first 
two problems, i.e., the presence of unsafe vehicles on EU roads and insufficient control of air pollutant 
and noise emissions. Indirectly, it also has an influence on the third problem, in that testing light vehicles 
annually from the date of their first registration (as is the case for HDVs), and at the roadside, could also 
increase the effectiveness of the directives, notably in preventing odometer fraud. 

In 2014, the scope of the PTI Directive was extended to faster tractors (design speed >40km/h) and larger 
two- and three-wheel vehicles and quadricycles (equipped with internal combustion engines >125cm3), 
effective from January 2022. However, the Directive allows for exempting motorcycles, tricycles and heavy 
quadricycles  (L3e,  L4e,  L5e  and  L7e)  from  PTI  “where  the  Member  State  has  put  in  place  effective 
alternative road safety measures” and on condition that the Commission is notified. At the end of 2023, 

106 Such as https://eur-lex.europa.eu/eli/reg_impl/2021/133/oj and the Commission proposal on the revision of Directive 
2015/413 on facilitating cross-border exchange of information on road-safety-related traffic offences. 
107 This problem and its drivers are discussed in the Impact Assessment Report accompanying the proposal for an ELV 
Regulation (SWD (2023)256 final) mentioned in section 1. 

19 

 
 
eight Member States108 made use of this possibility. France introduced PTI for powered two- and three-
wheelers  and  quadricycles  in  April  2024.  As  such,  the  scale  of  the  problem  is  expected  to  reduce 
significantly, especially thanks to the introduction of PTI in France. 

Agriculture and forestry tractors may also be exempted. Since they are not covered by the PTI Directive, 
mopeds are only subject to periodic roadworthiness testing in some Member States (e.g., Austria, Croatia, 
Spain). Although not in the scope of the PTI Directive, more than half of the EU Member States (16) have 
provisions for mandatory PTI for light trailers (3 Member States have provided this only for the larger O2-
category, i.e., with maximum mass above 750 kg and up to 3500 kg), while others exempt them under 
certain characteristics or conditions of operation109. 

With regards to the RSI Directive, the requirements on technical roadside inspections currently only apply 
to commercial vehicles of more than 3.5 tonnes, while vehicles below this weight and their trailers are 
exempted from inspections in most Member States.  

Finally, and most importantly, only 16 Member States apply more frequent (yearly) roadworthiness tests to 
older cars (>10 years)110, that is, eleven, including the Member States with the largest fleets111, do not, 
which represent an increased safety and environmental risk. Since the car and van fleets of these Member 
States represent roughly half of the EU fleet, and the vehicles older than 10 years among them are 
about half of that, annual testing of vehicles older than 10 years would affect around 25% of the EU 
light duty vehicle fleet.112 

2.2.6.  Interlinkages between the problem drivers 

Some of the problem drivers are interlinked with each other. This is the case in particular with PD3 (Limited 
possibilities to detect vehicles with defective or tampered components), which is influencing or influenced 
by all the other problem drivers. EVs and ADAS represent new technologies and test methods for such 
systems  are  very  recent  or just  being developed  and  are not  widely  used  yet  (PD1).  The lack of legal 
requirement to test such systems during PTI and RSI for their potential defects may also present a safety 
risk.  PD3  is  also  linked  to  PD2  (Current  PTI  &  RSI-methods  not  suited to  measuring  the  emission 
performance of modern vehicles) in a similar way as to PD1. Emission control systems have also evolved 
considerably and developing adequate test methods to verify their functioning in a PTI-environment (i.e., 
requiring a quick, simple, and cheap method) has taken some time, which partly explains why the current 
PTI and RSI emission test requirements are outdated. While for the purpose of detecting tampered vehicles, 
RSI has the advantage of the drivers not knowing that they would be tested, it has the limitation that it is 
only organised in campaigns and can therefore only screen a small subset of the vehicle fleet. PD3 is linked 
to PD4 (Vehicle identification & status data not sufficiently available to, and recognised among, enforcing 
authorities) in that in most Member States it is currently not possible to verify whether the odometer reading 
of a vehicle is correct or not. Finally, it is linked to PD5 (Certain vehicles are not (sufficiently) tested for 
their roadworthiness) since it is not possible to detect defective or tampered vehicles that are not tested. 

2.3.  How likely is the problem to persist? 

Problem 1 - Presence of unsafe vehicles on EU roads. While technological development is likely to further 
improve vehicle safety, the uptake of new technologies in the EU vehicle fleet would take some time, and 

108 BE (testing is only required before selling or after a crash), DK (requiring roadside checks instead), FI, FR, IE, MT, 
NL, PT (PTI only above 250 cm3). FR introduced PTI for powered two- and three-wheelers and quadricycles in 2024. 
109 DK, EL, FI, FR, NL, IE, PT exempt all light trailers, while PL, SK, BE and ES exempt O1. 
110 Cf. section 2 of Annex 6. 
111 Those eleven are DE, FR, IT, CY, CZ, DK, EL, HU, LT, MT, and SK. 
112 Sections 4.1.9, 4.2.10 and  5 of Annex 4. 

20 

 
 
some of the new features may also bring about new risks. Similarly, while tampering may be made more 
difficult by technical solutions, it is unlikely that it would disappear without  enabling vehicle testing to 
detect illegal modifications, notably of the engine management software e.g., through securing better access 
to in-vehicle data. Thus, in the absence of EU level intervention, the problem is likely to persist. Member 
States may take unilateral measures (e.g., introducing PTI for specific vehicle categories, specific methods 
for the testing of EVs or ADAS). However, these measures cannot replace the coordinating and harmonising 
effect of the three Directives, with the risk of possible distortions of the internal market and only partially 
addressing the problem. 

Problem 2 - Insufficient control of vehicle air pollutant and noise emissions. The problem of insufficient 
control  of  vehicle  air  pollutant  emissions  would  persist  as  long  as  vehicles  equipped  with  internal 
combustion  engines  (ICE)  are  on  the  roads.  Although  with  stricter  emission  standards  and  gradual 
electrification  the  number  of  vehicles  generating  tailpipe  emissions  will  decrease,  they  will  still  be 
circulating in the EU decades from now. While the proposed Euro 7 standard should address tampering and 
durability more effectively than its predecessors, vehicle aging and defects are unlikely to be completely 
overcome  and  vehicle  inspection  will  continue  to  be  key.  Without  updating  the  current  emission  test 
requirements at EU level however, Member States may not introduce the most effective and efficient test 
methods already available based on Commission recommendations. Similarly, while more Member States 
may start experimenting with roadside noise testing e.g., as mentioned in section 1, it is unlikely that the 
problem of noise vehicles would reduce significantly without a more systematic and coordinated approach. 

Problem 3 - Roadworthiness Directives are not effective in enforcing rules in EU cross-border traffic and 
trade of vehicles. Without EU level intervention, certain Member States may take unilateral or bilateral 
measures,  such  as  systematic  recording  (and  possibly  exchanging)  of  odometer  readings,  or  develop 
agreements  to  recognise  each  other’s  roadworthiness  certificates.  However,  the  systemic  problem  of 
insufficient  and  inefficient  exchange  of  roadworthiness-related  vehicle  data  would  remain,  hindering 
effective implementation and enforcement of existing rules. 

Foresight tools. The analysis incorporates throughout all its dimensions relevant foresight tools. It does so 
to anticipate trends and issues that may affect the initiative and build a robust, future-proof evidence base 
for its likely impact. The megatrend “Accelerating technological change and hyperconnectivity” will have 
a significant impact on the road transport sector and is relevant for the problems related to the presence of 
unsafe  vehicles on  EU  roads  and  the  insufficient  control  of  vehicle  air  pollutant  and  noise  emissions. 
However, as explained above, technological change on its own would not be able to address these problems, 
or at least not for decades from now. The 2022 Strategic Foresight Report113 points to the potential of 
digitalisation and artificial intelligence to boost the emergence of more efficient mobility solutions, with a 
new  generation  of  digital  technologies  enabling  a  major  shift  towards  more  sustainable  mobility  for 
passengers as well as heavy-duty freight transport. This trend will have an impact on all three problems 
mentioned above. For example, while digital solutions play a crucial role in innovative safety features and 
highly sophisticated emission control systems, the trend has also led to new tampering techniques in both 
areas. The trend will also play a key role in addressing the third problem, however, in itself, it will not be 
sufficient to resolve regulatory failures. The megatrend “climate change and environmental degradation”114 
is directly related to the insufficient control of vehicle emissions, identified as one of the main issues to be 
addressed in line with the air quality legislation referred to in section 1. The same foresight report identified 
“enabling a greener transport sector with digital technologies” as one of the areas where the twinning of the 
green and digital transitions is expected to have a major effect. As regards the expected transformation of 
the vehicle fleet over the next decade, certain automakers (e.g., Volvo) plan to sell only EVs as of 2030. 

113https://commission.europa.eu/strategy-and-policy/strategic-planning/strategic-foresight/2022-strategic-foresight-
report_en  
114 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en 

21 

 
 
Those cars will also be connected and featuring the ADAS required by the General Safety Regulation.  

3.  WHY SHOULD THE EU ACT? 

3.1.  Legal basis 

The legal basis giving the EU the right to act is Article 91 of the Treaty on the Functioning of the European 
Union (TFEU. In particular, Article 91(1)(c) provides that the Union has competence in the field of transport 
to lay down measures to improve transport safety.  

3.2.  Subsidiarity: Necessity of EU action 

In  the  absence  of  the  EU  level  intervention,  Member  States  would  continue  to  carry  out  periodic  and 
roadside inspections, but it is very unlikely that test methods and the scope of inspections required by the 
EU acquis (e.g. testing brakes, suspension and emissions reduction equipment, etc.) would be applied in a 
harmonised or coordinated manner. Different and piecemeal solutions would be applied, which would lead 
to even larger differences in the safety and environmental performance of vehicles than today, with the risk 
of distorting the internal market, and creating further barriers to free movement. The initiative therefore 
addresses safety and environmental protection needs with “Union relevance”.  

Road transport, especially freight, is an international sector, with vehicle approval regulated at the EU and 
international (UNECE) level. Therefore, it has by nature a strong cross-border dimension. According to the 
evaluation and the various targeted stakeholder consultations carried out as part of the revision process, the 
RWP has been considered to have contributed to road safety and environmental protection in the EU and 
has even had positive spill-over effects in neighbouring countries. 

The identified problems apply across the entire Union and have the same underlying causes. At the same 
time,  there  is  widespread  agreement  among  national  authorities  and  industry  experts  that  the  current 
Directives are no longer aligned with the latest regulatory and technological developments in vehicle safety 
and emission control. In the absence of EU action, EU Member States may implement national solutions 
and will work in an uncoordinated and non-harmonised way. This could undermine the harmonised safety 
and emission standards.  

3.3.  Subsidiarity: Added value of EU action 

As  road  transport  and  the  automotive  industry  are  international  sectors,  it  is  much  more  efficient  and 
effective to address the issues at the EU level than at the level of Member States. While national practices 
differ  historically,  a  certain  minimum  level  of  harmonisation  in  vehicle  testing  and  commonly  agreed 
solutions to exchange vehicle data between Member States is more effective than multiple uncoordinated 
national solutions. With common rules applied to testing modern vehicle technologies (EVs, ADAS, and 
the most recent emission control equipment), Member States will realise economies of scale and testing 
equipment  manufacturers  can  operate  on  a  more  homogenous  market.  The  functioning  of  the  internal 
market would also be improved by vehicles being subject to similar tests under similar conditions, and 
transport operators facing similar costs. Coordinating the conditions of access and exchange of vehicle data 
at the EU level will not only be more efficient than bilateral agreements and negotiations with individual 
manufacturers,  but  also  level  the  playing  field  among  Member  States  and  put  them,  collectively,  in  a 
stronger position vis-à-vis the automotive industry. 

22 

 
4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1.  General objectives 

To address the problems identified in section 2 and in line with the overall logic of the Roadworthiness 
Package on the one hand, and with the Commission’s strategic priorities on the other hand (‘Vision Zero’ 
road safety policy framework, the European Green Deal, the Sustainable and Smart Mobility Strategy, the 
Zero Pollution Action Plan) and Treaty principles, the general objectives of this revision are to: (i) improve 
road safety in the EU; (ii) contribute to sustainable mobility; and (iii) facilitate the free movement of persons 
and goods in the EU. Stakeholders were consulted on these objectives as part of public as well as targeted 
consultations,  including  through  the  Roadworthiness  Committee  and  the  Expert  Group  representing 
Member States and industry experts, and a large majority of them agreed with the identified general and 
specific objectives (see Annex 2). Improving road safety in the EU and contributing to sustainable mobility 
are in line with UN Sustainable Development Goal (SDG) 3 (Ensure healthy lives and promote well-being 
for  all  at  all  ages),  including  targets  3.6  (halving  the  number  of  deaths  and  injuries  from  road  traffic 
accidents)  and  3.9  (by  2030,  substantially  reduce  the  number  of  deaths  and  illnesses  from  hazardous 
chemicals and air, water and soil pollution and contamination), notably through specific objectives 1 and 2 
mentioned below.  

4.2.  Specific objectives 

The specific objectives of the initiative are designed to address the problems and problem drivers described 
above (Figure 4). As each of the specific objectives address two or three problem drivers, they complement 
each other to help achieve the general objectives. Both SO1 and SO3 contribute to SO2, while there are no 
trade-offs between them. 

Figure 4: Correspondence between problem drivers and the objectives 

SO1: Ensure the adequacy, consistency, objectivity, and quality of roadworthiness testing of today's and 
tomorrow's vehicles. This objective aims to address the challenges presented by the need to test the latest 
and emerging vehicle technologies in a coherent manner. More specifically, the testing of EVs and ADAS 
must be ensured before most of the new vehicles equipped with such systems are due for their first PTI 
(PD1)115. To correct for the inability of existing emission tests to identify high-emitting vehicles (PD2), 

115 While many electric vehicles are already on the roads, many more new vehicles equipped with ADAS will be due for 
PTI in 2026. 

23 

 
 
 
 
newly developed test methods need to be incorporated in the minimum requirements. Similarly, measures 
need to be taken to improve the detection rate of defective or tampered, thus polluting, excessively noisy 
and potentially dangerous vehicles (PD3). Some of those vehicles are not tested today, or not frequently 
enough  to  detect  those  deficiencies  (PD5).  The  majority  of  stakeholders  participating  in  the  targeted 
consultation (64 out of 67) agreed with this specific objective. Adapting testing to today's and tomorrow's 
vehicles (SO1) will also help achieve SO2. 

SO2:  Significantly  reduce  fraud  and  tampering,  and  improve  the  detection  of  defective  vehicles.  This 
objective aims to significantly reduce tampering and improve the detection of vehicles with deficiencies, to 
allow for the detection of defective/tampered safety and emission (i.e., air pollution and noise emission) 
control  systems,  as  well  as  of  odometer  fraud,  by  improving  the  suitability  of  emission  testing  (PD2), 
providing for better tools to detect safety-related modifications, notably of vehicle software (PD3), and by 
more and targeted inspections (PD5). Most stakeholders participating in the targeted consultation (60 out of 
66) agreed with this specific objective.  

SO3:  Improve  electronic  storage  and  exchange  of  relevant  vehicle  identification  and  status  data.  This 
objective aims at improving electronic storage and exchange of specific vehicle data, therefore addressing 
the  problem  of  insufficient  availability  of  such  data  and  mutual  recognition  by  enforcing  authorities 
(registration,  PTI,  RSI)  (PD4).  More  accurate  status  data  (such  as  mileage)  and  efficient  exchange  of 
information among Member States will also help identify vehicles with tampered odometer (PD3). As such, 
SO3 also complements SO2. The majority of stakeholders participating in the targeted consultation (54 out 
of 61) agreed with this specific objective. 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1.  What is the baseline from which options are assessed? 

The  EU  Reference  scenario  2020  is  the  starting  point  for  the  impact  assessment  of  this  initiative.  The 
REF2020 takes into account the impacts of the COVID-19 pandemic that had a significant impact on the 
transport  sector.  More  detailed  information  about  the  preparation  process,  assumptions,  and  results  are 
included in the Reference scenario publication116. Building on REF2020, the baseline has been designed to 
include the initiatives of the ‘Fit for 55’ package proposed by the Commission on 14 July 2021117 and the 
initiatives of  the RePowerEU package proposed by  the  Commission on  18 May  2022118.  The baseline 
scenario factors in the revision of the HDV CO2 standards Regulation119 and the new Euro 7 standards120, 
the  proposed  end-of-life  vehicles  (ELV)  Regulation121 and  the  forthcoming  initiative  on  fair  and  non-
discriminatory access to in-vehicle data122, as well as other initiatives part of the Road Safety package123 
and the Greening Freight package124.  

116 EU Reference Scenario 2020 (europa.eu)  
117 https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/delivering-european-green-deal_en 
118  https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131 
119 Regulation (EU) 2024/1610  
120 COM(2022) 586 final   
121 The  proposed ELV Regulation calls for data related to the reasons of deregistering vehicles to be recorded in the 
national vehicle registers. See: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52023PC0451  
122 According to current plans, the proposal on access to in-vehicle data would provide for non-discriminatory access to 
such  data  in  a  harmonised,  machine-readable  format.  This  will  be  key  for  vehicle  inspection  too,  without,  however, 
specifying the means of data access, which will continue to allow manufacturers to set their own (often cumbersome) 
rules. 
123  Proposal for a Directive amending the Driving Licence Directive, proposal for a Directive amending the Cross-Border 
Enforcement Directive and proposal for a Directive on the Union-wide effect of certain driving disqualifications. 
124 Green Deal: Greening freight for more economic gain with less environmental impact (europa.eu) 

24 

 
 
The baseline scenario assumes no further EU level intervention beyond the current Roadworthiness Package 
(i.e., the PTI and the RSI Directives as amended by the delegated Regulations to align with the evolution of 
type-approval legislation125 and to introduce the testing of eCall at PTI126, and the VRD Directive as last 
amended by the revision of the Eurovignette Directive127). As some of the provisions of the RWP allowed 
for a very long transition period128, certain Member States are still notifying transposition measures to the 
Commission. The baseline scenario assumes full transposition of the current Roadworthiness Package. In 
addition, the baseline reflects the introduction of PN measurement by three Member States129.  

The  baseline  also  incorporates  foresight  megatrends  and  developments  captured  in  the  2022  Strategic 
Foresight Report130, as explained in section 2.3. Among others, it captures the trend of increasing demand 
for transport as population and living standards grow, as well as the links between the digital and green 
transition, and the accelerating technological  change  and  hyperconnectivity.  In particular, the projected 
transport activity draws on the long-term population projections from Eurostat and GDP growth from the 
Ageing Report 2021131 by the Directorate General for Economic and Financial Affairs.  

In the baseline scenario, EU transport activity is projected to grow post-2020, following the recovery from 
the COVID-19 pandemic. Road transport would maintain its dominant role within the EU by 2050. Road 
passenger transport activity (expressed in passenger-kilometres)132 is projected to grow by 10% between 
2015 and 2030 (27% for 2015-2050), while road freight transport activity (expressed in tonne-kilometres)133 
by 27% during 2015-2030 (52% for 2015-2050). Rail transport activity is projected to grow significantly 
faster than for road, driven in particular by the completion of the TEN-T core network by 2030 and of the 
comprehensive network by 2050, supported by the CEF, Cohesion Fund and ERDF funding, but also by 
measures of the ‘Fit for 55’ package134 and the Greening Freight package. Passenger rail activity is projected 
to go up by 37% by 2030 relative to 2015 (86% for 2015-2050). Freight rail traffic would increase by 50% 
by 2030 relative to 2015 (107% for 2015-2050).  

The share of zero-emission vehicles in the light duty vehicle fleet (passenger cars and light commercial 
vehicles) is projected at 15% in 2030, going up to 95% in 2050 in the baseline scenario, while for heavy 
duty vehicle fleet (buses and coaches, and heavy goods vehicles) at 6% in 2030 and 72% in 2050. These 
developments  are  driven  by  the  CO2  standards  Regulations,  supported  by  the  Alternative  Fuels 
Infrastructure Regulation. The current limitations of the emission testing methods applied under the PTI and 
RSI Directives are expected to persist in the baseline scenario, with the shares of high-emitting vehicles135 
in the Euro 5/V and Euro 6/VI fleet remaining largely the same. On the other hand, the share of high-
emitting vehicles in the Euro 7 fleet is expected to be lower than for Euro 5/V and Euro 6/VI. The uptake 
of zero-emission vehicles, the penetration of Euro 7 vehicles in the fleet and the related introduction of on-

125 https://eur-lex.europa.eu/eli/dir_del/2021/1717/oj and https://eur-lex.europa.eu/eli/dir_del/2021/1716/oj  
126 https://eur-lex.europa.eu/eli/reg/2015/758/oj  
127 Directive (EU) 2022/362 amending Directives 1999/62/EC, 1999/37/EC and (EU) 2019/520, as regards the charging 
of vehicles for the use of certain infrastructures, https://eur-lex.europa.eu/eli/dir/2022/362/oj  
128 For example, PTI for motorcycles (with a possibility for exemptions) since January 2022; the deadline to equip all test 
centres with all the required equipment was 20 May 2023 (five years after the date of application). 
129 Belgium, Germany and the Netherlands. 
130 COM(2022) 289 final. 
131 The 2021 Ageing Report. Economic and Budgetary Projections for the EU Member States (2019-2070) (europa.eu) 
132 Covering passenger cars, buses and coaches, and power-two wheelers.  
133 Covering heavy goods vehicles and light commercial vehicles.  
134 These measures increase to some extent the competitiveness of rail relative to road and air transport. 
135 High emitters are vehicles with defective emission or noise control systems or vehicles with tampered emissions/noise 
control systems. 

25 

 
 
board emissions monitoring systems136, combined, are expected to result in significant reductions of air 
pollution emissions from road transport in the baseline scenario. NOx emissions are projected to reduce by 
52% in 2030 relative to 2015 (98% reduction for 2015-2050), while particulate matter (PM2.5) emissions 
would decrease by 43% in 2030 relative to 2015 (98% reduction for 2015-2050). CO2 emissions from road 
transport are projected to decrease by 32% by 2030 relative to 2015, and be close to zero by 2050, thanks 
to the large-scale uptake of zero-emission vehicles and some use of renewable and low-emission fuels. 

In the baseline scenario, the number of fatalities is projected to decrease by 24% by 2030 relative to 2015 
and by 31% by 2050 relative to 2015137. The number of serious and slight injuries is projected to decrease 
by 19% between 2015 and 2030 and by 26% for 2015-2050. This is despite the increase in traffic over time. 
Relative to 2019, the number of fatalities would decrease by 15% by 2030 and 23% by 2050, and the number 
of serious injuries by 10% by 2030 and 18% by 2050. Thus, the targets of the EU Road Safety Policy 
Framework 2021-2030 – Next steps towards “Vision Zero”, of reducing the number of road deaths and the 
number of serious injuries by 50% between 2019 and 2030, would not be met. In addition, this is still far 
from the goal of the Sustainable and Smart Mobility Strategy of a close to zero death toll for all modes of 
transport in the EU by 2050. The external costs of noise emissions are projected to increase by 7% by 2030 
relative  to  2015  and  to  remain  relatively  stable  post-2030.  The  uptake  of  zero-emission  vehicles 
compensates to some extent the increase in noise due to the higher traffic138.   

In the baseline scenario, the number of periodic technical inspections (PTI) for cars, vans, buses, trucks and 
motorcycles is projected to increase from 151.5 million in 2015 to 168.9 million in 2030 and 192.3 million 
in 2050139. For O1 and O2 vehicles the number of inspections is projected at 7.9 million in 2030 and 8.7 
million  in  2050.  Most  of  the  technologies  required  for  more  advanced  testing  included  in  the  policy 
measures are available and part of the baseline; however certain test methods need to be developed. More 
detailed explanations are provided in Annex 4 (section 8).   

The number of national second-hand vehicle sales with mileage fraud at EU level is projected at 1.71 million 
in 2030 and 1.90 million in 2050, and that of cross border vehicle sales with mileage fraud at 3.35 million 
in 2030 and 3.64 million in 2050. The national and cross-border odometer fraud is estimated to lead to 
damages for European consumers estimated at EUR 10.7 billion in 2030 and EUR 11.7 billion in 2050140. 
Expressed as present value over 2026-2050 this amounts to EUR 194.6 billion. More details on the baseline 
scenario are provided in Annex 4 (section 2). 

136 Considering the expected effects of the Euro 7 based on the Commission’s proposal, the currently dominant Euro 5/V 
and 6/VI vehicles should be gradually replaced by new ones complying with the Euro 7 standard. This  would result in 
reduced levels of tampering and lower emissions, in particular for heavy-duty vehicles. A limitation to mention here is 
that the baseline reflects the Commission proposal. Following the changes agreed by the co-legislators, the baseline likely 
overestimates the reduction in the air pollution emissions over time and thus slightly underestimates the contribution of 
this initiative to the air pollution emissions reduction. This is particularly relevant in the short to medium term. In the 
medium to long term this is less relevant due to the expected large-scale penetration of the zero-emission vehicles in the 
fleet.  
137 Projections refer to injuries in accidents in which a car, a van, a bus or a truck, or a motorcycle is involved. 
138 It should however be noted that the reduction in noise due to zero-emission vehicles is only linked to the powertrain. 
The noise from tyres still remains.    
139 They are derived based on the ‘testing frequency’ and the average number of PTIs in the statistical life of a vehicle. 
140 The average cost of mileage fraud, due to higher purchase price and maintenance costs incurred, is estimated at EUR 
(https://www.car-
2,119 
pass.be/files/article_files/file/7/crm%2520study%2520final%2520report.pdf). More explanations are provided in section 
2 of Annex 4. 

a  Belgian  Car-Pass 

drawing 

vehicle 

prices 

study 

2022 

per 

on 

in 

26 

 
 
5.2.  Description of the policy options 

As  a  first  step,  a  comprehensive  list  of  possible  policy  measures  was  established  after  extensive 
consultations with stakeholders, expert meetings, and independent research in the context of the impact 
assessment support study and the Commission’s own analysis. This list was subsequently screened based 
on the likely effectiveness, efficiency and proportionality of the proposed measures in relation to the given 
objectives, as well as their legal, political and technical feasibility. 

Discarded policy measures and policy options  

The possibility to adopt further recommendations or a communication from the Commission was discarded 
at early stage as non-regulatory measures could not be sufficiently effective in addressing the problems 
identified and would have limited effect on harmonisation. Most stakeholders, including public authorities 
participating in the open public consultation, agree that a legislative review of the RWP would be more 
effective (see Annex 2). Out of the more than 40 policy measures discussed at five meetings with the Expert 
Group on Roadworthiness and vehicle registration documents (RWEG), 13 measures have been discarded. 
A more detailed list with all discarded measures can be found in Annex 8. 

Retained policy measures and policy options 

A  list  of  26  policy  measures  has  been  retained.  Table  3  presents  an  overview  of  the  policy  measures 
included in the policy options and their links with the specific objectives. A detailed description of the policy 
measures is provided in Annex 7.  

The policy options offer choices with focus on different aspects such as means of  testing (e.g., PTI vs 
roadside inspections, tailpipe testing only vs its combination with remote sensing) or different levels of 
harmonisation in the exchange of vehicle data, the scope and methods of testing and the mutual recognition 
of PTI certificates. 

Four policy options have been identified (PO1a, PO1b, PO2 and PO3), and each of the four policy options 
includes a set of policy measures that are common for all options, as well as additional measures that are 
included in one or more options. The common set of policy measures (from PMC1 to PMC9) are considered 
as the minimum necessary to correct the  shortcomings of the existing  RWP Directives and to adapt to 
technological  and  regulatory  developments  over  the  last  ten  years,  and  are  supported  by  most 
stakeholders. Beyond the common measures, PO1a and PO1b differ in their focus, while compared 
to them PO2 and PO3 represent an increasing level of ambition and harmonisation. This reflects the 
preferences of various stakeholder groups and genuine options for more or less convergence in the 
areas covered by the three Directives. 

Table 3: Policy measures and policy options 

PM# 

Policy Measure 

Specific 
objective 

PO1a  PO1b  PO2  PO3 

Measures common to all policy options 

New PTI and RSI tests 

PMC1 

PMC2 

Adapt  PTI  to  electric  and  hybrid  vehicles  (safety, 
environmental performance, standardised data), including 
training of inspectors 

Update  PTI  and  RSI  due  to  new  requirements  in  the 
General  Safety  Regulation  and  checking  emission 
reduction  systems  (new  test  items,  including  checks  of 
software status/integrity), by reading on-board diagnostics 

SO1 

X 

X 

X 

X 

SO1 

X 

X 

X 

X 

27 

 
 
 
 
 
 
 
PMC3 

PMC4 

PMC5 

PMC6 

PMC7 

PMC8 

PMC9 

PM1 

PM2 

PM3 

PM4 

PM5 

PM6 

PM7 

PM8 

PM9 

PM# 

Policy Measure 

Mandatory PN testing of LDVs and HDVs equipped with 
particle filter, at PTI, and of HDVs at technical roadside 
inspections of commercial vehicles  

Specific 
objective 

SO1, 
SO2 

PO1a  PO1b  PO2  PO3 

X 

X 

X 

X 

Mandatory  NOx  testing  of  LDV  and  HDV  at  PTI,  and 
HDVs at roadside inspections 

SO1, 
SO2 

X 

X 

X 

X 

Frequency of testing 

Mandatory  roadworthiness  testing  following  significant 
modifications  of  the  vehicle  (e.g.  change  of  class, 
propulsion system) 

Facilitating exchange of PTI and registration data 

Require  roadworthiness  certificate  in  electronic  format 
only 

Provide  electronic  access  to  relevant  data,  including  on 
PTI reports stored in national databases, to the registration 
authorities  of  other  Member  States  using  a  common 
interface 

Harmonisation and regular update of the technical data in 
the vehicle registration documents (of currently optional 
content) 

Tackling odometer tampering 

SO2 

X 

X 

X 

X 

SO3 

SO3 

X 

X 

X 

X 

X 

X 

X 

X 

SO3 

X 

X 

X 

X 

Member States to record odometer readings in a national 
database and make the records available to other MSs in 
the case of re-registration 

SO2, 
SO3 

Measures not included in all policy options 

X 

X 

X 

X 

SO2 

X 

X 

Scope of vehicles subject to PTI/RSI 

RSI  for  heavy/powerful  motorcycles  (L  category  > 
125cm3)  as  an  alternative  measure,  in  Member  States 
where they are not subject to PTI (i.e., using the available 
opt-out) 
Mandatory  PTI  for  motorcycles  above  125cm3  (remove 
opt-out) 

Extend PTI to all motorcycles (incl. from 50cm3 = all L3e, 
L4e), plus tricycles (L5e) and heavy quadricycles (L7e) 

SO2 

SO2 

Mandatory PTI for light trailers (O1 and O2 categories) 

SO2 

Frequency of testing 

Annual  emission  testing  for  light  commercial  vehicles 
(N1) instead of the currently required 4-2-2- frequency 

Mandatory yearly testing for vehicles that are 10-year-old 
or older  

Recognition of PTIs conducted in another Member 
State 
PTI certificate issued in any EU MS is recognised by the 
MS of registration + further harmonisation of test methods 

PTI certificate issued in any EU MS is recognised by the 
MS  of  registration  for  a  period  of  up  to  6  months  (for 
passenger cars only), on the condition that the next PTI is 
conducted in the MS of registration 

SO2 

SO2 

SO1, 
SO3 

SO3 

PTI in another EU MS recognised by MS of registration 
based on bilateral agreement (voluntary recognition) 

SO3 

X 

Improve current PTI tests and procedures 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

PM10 

More advanced testing of noise for motorcycles 

SO2 

X 

X 

X 

28 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
PM# 

PM11 

Policy Measure 

Data  governance:  further  define  the  procedures  and  the 
means  of  access  to  vehicle  technical  information  by 
testing centres free of charge   

RSI methods 

PM12 

NOx,  PM, and noise measurement by remote sensing in 
RSI  of  all  vehicles  (with  option  for  simplified  PTI  if 
vehicle passed recent RSI)  

PM13 

Mandatory inspection of cargo securing  

PM14 

PM15 

PM16 

PM17 

Scope of vehicles subject to RSI 

Extend the scope of application of roadside inspections to 
light commercial (N1) vehicles 

Extend the scope of application of roadside inspections to 
2- and 3-wheeled vehicles (L-vehicles from L3) 

Registration certificate and registered data 

Introduce  issuing  the  registration  certificates  in  digital 
format to gradually replace current paper (and smart card) 
documents 

Add  new  data  to  the  vehicle  register  –  minimum 
mandatory  set  (including  among  others:  country  of  1st 
registration, registration status, PTI status, changes due to 
transformation) 

Specific 
objective 

SO1, 
SO3 

PO1a  PO1b  PO2  PO3 

X 

X 

SO1, 
SO2 

SO1, 
SO2 

SO2 

SO2 

X 

X 

X 

X 

X 

X 

X 

X 

X 

SO3 

X 

X 

X 

SO3 

X 

X 

X 

Adapting PTI to EVs (PMC1) and including new test items through the ePTI (PMC2, including the testing 
of  software  integrity  of  safety-  and  emission-relevant  systems)  will  help  align  the  PTI  rules  with 
technological and regulatory developments and hence contribute to SO1 (Ensure the adequacy, consistency, 
objectivity,  and  quality  of  roadworthiness  testing  of  today's  and  tomorrow's  vehicles).  Similarly,  new 
emission test methods for both particles and NOx (PMC3 and PMC4) are necessary to adapt to more recent 
emission  control  technologies  (contributing  to  SO1)  and  to  capture  high  emitting  vehicles,  including 
tampered ones (contributing to SO2). PMC5 will also contribute to SO2 (Significantly reduce fraud and 
tampering,  and  improve  the  detection  of  defective  vehicles)  by  requiring  that  vehicles  undergo  a 
roadworthiness  test following any significant modification  involving  e.g., the  change  of the  propulsion 
system or the emission class. PMC6, PMC7 and PMC8 contribute to SO3 (Improve electronic storage and 
facilitating  exchange  of  relevant  vehicle  identification  and  status  data)  through  digitalisation  of  the 
roadworthiness certificate, linking national vehicle registers and extending the set of harmonised vehicle 
data in those registers. PMC9 introduces a requirement for Member States to record odometer readings in 
national databases and make those records available to other Member States in the case of re-registration. 
Garages (including car manufacturers), tyre and other repair services, in addition to PTI bodies would have 
to provide such readings for cars and vans following every visit. PMC9 contributes to SO2 and SO3. 

Reasoning behind the packaging of options 

PO1a and PO1b are designed rather conservatively as regards the scope of vehicles to be tested and 
are limited to the measures that are indispensable to address each of the problem drivers and to meet 
all specific objectives, while each of these two options has a specific focus: PO1a focuses primarily 
on  enhancing  the  exchange  of  vehicle  data  and  enhancing  digitisation.  PO1b  on  the  other  hand 
focuses more on improving the testing of vehicles and introducing additional and more ambitious 
measures regarding emission testing and recognition of PTI.  

29 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
PO2 is designed to provide a more integrated approach. It builds on the measures already included 
in  PO1a  and  PO1b  and  adds  more  ambition  with  additional  measures  such  as  the  extension  of 
roadside  inspections  to  vans.  It  also  improves  access  to  relevant  technical  and  registration  data 
through specific measures, such as better access to vehicle data necessary for testing notably modern 
electronic safety systems. 

PO3 builds on PO2 and takes its integrated approach, but compared to PO2 it further extends the 
scope of vehicles and items to be tested. It further extends the scope of PTIs to cover light trailers 
and  motorcycles  with  smaller  engine  size,  combined  with  mandatory  roadside  inspection  for 
motorcycles. It also provides a wider recognition of PTI inspections taking place in other Member 
States. Overall, it represents the most ambitious option. 

Policy option 1a (PO1a)  

This policy option  aims primarily  at more efficient use of vehicle  (registration  and status) data, further 
focusing on addressing SO3. In addition to the common measures, PO1a would require adding certain new 
data elements to national vehicle registers, notably related to the registration and roadworthiness status of 
the vehicle, thus facilitating the implementation and enforcement of the RWP as well as that of the ELV 
legislation  (PM17).  Issuing  registration  certificates  in  digital  format  (PM16)  will  further  enhance  the 
efficiency of data exchange. Furthermore, PO1a would allow Member States to sign bilateral agreements 
to enable the cross-border recognition of PTIs and thus facilitate the free movement of people and goods 
(PM9). PM9, PM16 and PM17 contribute to addressing SO3.  

Beyond the common measures, PO1a applies a relatively light touch approach to addressing SO2. To reduce 
the  number  of  tampered  and  defective  motorcycles  due  to  their  lack  of  testing,  it  would  require  those 
Member State which exempt these vehicles from PTI to apply as alternative measure, testing a share of 
them  at  the  roadside  (PM1).  Most  stakeholders,  including  Member  States  authorities  and  especially 
EReg/EUCARIS  support  this  policy  option,  while  the  PTI  sector  (CITA  and  others)  and  motorcycle 
manufacturers (ACEM) would prefer stricter PTI and RSI requirements. 

Policy option 1b (PO1b) 

Beyond the common measures, PO1b further focuses on addressing SO2 through more effective technical 
inspections. The most important measure in this respect is the use of remote sensing technology141 (PM12), 
which allows targeted and thus much more effective and efficient emission testing at the roadside. Remote 
sensing,  using  laser  technology  (LiDAR)  to  detect  critical  pollutants,  has  been  demonstrated  to  be  an 
effective method to screen very large numbers of vehicles at relatively low cost142. This measure will allow 
monitoring the emissions of virtually the entire vehicle fleet, including older vehicles, depending on the 
scale  of  its  implementation.  Remote  sensing  using  microphones  is  able  to  single  out  unusually  noisy 
vehicles even in dense traffic143. This allows the identification of potentially high-emitting vehicles that can 
be  either  inspected  at  a  subsequent  roadside  check  immediately  after  being  identified  or  invited  to  a 
roadworthiness centre for an emission test.  

In addition, to address specific groups of vehicles that are more prone to tampering or defects than the 
average, PO1b introduces specific measures: it would remove the possibility to exempt motorcycles from 
PTI (PM2) and require yearly emission testing of light commercial vehicles (PM5). Furthermore, it would 

141 https://cares-project.eu/about/  
142  See  e.g.,  https://publications.tno.nl/publication/34638150/2gBdxC/hooftman-2020-analysis.pdf  and  https://nemo-
cities.eu/remote-sensing/  
143 https://nemo-cities.eu/remote-sensing-device-for-noise/  

30 

 
 
introduce  mandatory  annual  PTIs  for  vehicles  older  than  10  years  (PM6),  an  improved  noise  test  for 
motorcycles  based  on  type-approval  requirements  (PM10)  and  make  the  inspection  of  cargo  securing 
mandatory  (PM13).  As  such,  all  these  measures  go  further  in  addressing  SO2  (beyond  the  common 
measures included in all options). PO1b would further facilitate the free movement of people, and further 
address SO3, by requiring that the Member State of registration recognises the PTI certificate issued by 
another Member State for a period of up to six months, provided that the next PTI is conducted in the 
Member State of registration (PM8). This policy option enjoys the support of the PTI industry (CITA, FSD 
and  others)  as  well  as  automobile  manufacturers  (ACEA),  testing  equipment  (EGEA)  and  motorcycle 
manufacturers (ACEM), while certain Member States and motorcycle users find it too demanding. Stricter 
cargo securing requirements are strongly supported by the logistics industry (in particular by EUMOS). 

Policy option 2 (PO2) 

PO2  combines  most  of  the  measures  of  PO1a  and  PO1b.  As  regards  the  testing  of  motorcycles,  PO2 
includes a measure of PO1a (PM1), while for the recognition of PTIs conducted in another Member State, 
it uses PM8 (temporary recognition), like in PO1b. To further improve the consistency and quality of testing 
of modern vehicles (SO1) and the availability of relevant technical data to testing centres (SO3), it includes 
an additional measure on data governance (PM11), aiming to define the procedures and the means of access 
to vehicle technical information (including in-vehicle data). The measure would complement an existing 
Implementing Regulation144 and build on the upcoming proposal on access to in-vehicle data145.  

To further reduce the number of tampered and defective vehicles and contribute towards SO2, in addition 
to  the measures  of PO1b  and PO1a, it  would  also introduce  roadside inspections  for  light  commercial 
vehicles (PM14). RSI complements PTI and is arguably better suited to detect and reduce fraud thanks to 
the vehicle users having no prior notice of roadside tests, in comparison to pre-planned periodical technical 
inspections,  where  pre-  and  post-tempering  of  vehicles  cannot  be  excluded.  In  addition  to  being  a 
combination of PO1a and PO1b, PM11 on data governance makes this policy option more favoured by the 
PTI  industry  (CITA,  FSD  and  others)  as  well  as  FIA,  testing  equipment  (EGEA)  and  motorcycle 
manufacturers (ACEM). It is supported also by some Member States, notably those that rely on thousands 
of smaller roadworthiness testing centres. On the other hand, the issue of access to vehicle data is considered 
less important by automobile manufacturers. Stricter cargo securing requirements included in this option 
are strongly supported by the logistics industry (EUMOS).  

Policy option 3 (PO3) 

PO3  goes  further  on  harmonising  the  scope  and  methods  of  roadworthiness  testing  and  the  mutual 
recognition of PTI certificates. As such, it aims to further address SO2, as well as SO1 and contributes to 
facilitating  the  free  movement  of  people  and  goods  more  comprehensively  than  the  other  options  also 
further addresses SO3. To the measures of PO2, PO3 adds further extension of scope of PTI to cover all 
motorcycles without exception (PM3) and light trailers (PM4), and it extends RSI to motorcycles (PM15). 
All  these  measures  further  contribute  to  addressing  SO2.  PO3  is  the  only  option  to  include  PM7,  a 
requirement that PTI certificates issued in any other EU Member States are recognised by the Member State 
of registration without limitations, further addressing SO1 and SO3. This necessitates further harmonisation 
of test methods where the PTI Directive currently offers various options. It would thus mean less room for 
manoeuvre for Member States, and fewer choices for inspection centres. This being the most ambitious 

144 https://eur-lex.europa.eu/eli/reg_impl/2019/621/oj  
145 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13180-Access-to-vehicle-data-functions-
and-resources_en 

31 

 
 
option, it is mainly supported by the PTI sector, including equipment manufacturers as well as by ACEM 
and a few Member States that apply stricter requirements than the current RWP Directives. 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

This section summarises the main expected economic, social and environmental impacts of each policy 
option  (PO)146.  The  proposed  measures  are  assumed  to  be  implemented  from  2026  onwards,  so  the 
assessment  has  been  undertaken  for  the  2026-2050  period  and  refers  to  EU27.  Costs  and  benefits  are 
expressed as present value over the 2026-2050 period, using a 3% discount rate, in constant prices of the 
year  2022.  Further  details  on  the  methodological  approach  are  provided  in  Annex  4.  The  evidence 
underlying the assessment of impacts is based on the best available evidence, including multiple studies 
involving scientific research, as well as thorough consultation with experts. 

6.1.  Economic impacts 

This section focuses on the economic impacts of the policy options on national public authorities, businesses 
and citizens. It also provides an assessment of impacts on competitiveness, on innovation and technological 
developments, on small and medium enterprises (SMEs), on the functioning of the internal market and 
competition, and looks at territorial impacts and digital by default. The assessment of economic impacts 
draws on multiple data sources, including the targeted stakeholders’ consultation (interviews and survey) 
and OPC, and findings from desk research in the context of the impact assessment support study. The costs 
and benefits of each policy measure by stakeholder group are described in detail in Annex 4 (sections 3 and 
4), including the assumptions used to estimate them. In addition, the cost-benefit analysis for some key 
policy measures is provided in Annex 4 (section 6).  

6.1.1.  Impacts on national public authorities 

All  policy  options  are  expected  to  result  in  adjustment  and  administrative  costs  for  national  public 
authorities, while PO1b and PO3 would also lead to additional enforcement costs. At the same time, all 
policy options are expected to result in significant administrative costs savings for the national authorities 
(see Table 4 to Table 6). The costs and costs savings by policy option are discussed below, while the detailed 
calculations by policy measure are provided in Annex 4 (section 3).  

Adjustment costs. All policy options include adjustment costs related to three common measures (PMC2, 
PMC3 and PMC4). They cover one-off adjustment costs (see Table 6) for: the acquisition of on-board 
diagnostic (OBD) scanning tools for RSI and the training of inspectors to use the OBD tools147 (PMC2), 
estimated at EUR 0.2 million in 2026 relative to the baseline; the purchase of PN measurement devices for 
RIS and the training of inspectors to use them148 (PMC3), estimated at EUR 0.7 million in 2026; and, the 
acquisition of NOx measurement devices for RIS and the training of inspectors149 (PMC4), amounting to 
EUR 2 million. In addition, recurrent adjustment costs (i.e., maintenance and calibration costs) for the PN 
and NOx measurement devices are assumed at 5% of the capital costs, based on stakeholders’ feedback, 
and are estimated at EUR 32,750 per year from 2026 onwards in PMC3 and at EUR 98,250 per year in 

146 The analysis in this section is based on Ricardo et al. (2024), Impact assessment support study on the directives of the 
roadworthiness  package,  Contract  no.  MOVE/C2/SER/2022-583/SI2.895928,  under  FWC  no.  MOVE/2022/OP/0001, 
and on the analysis of stakeholders' feedback. 
147 The costs are estimated at EUR 1,000 per tool. One tool is required per RSI unit, and the number of RSI units total 
131 at EU level. Two hours of training are assumed for each of the 393 RSI inspectors across EU27.  
148  One  PN  measurement  device  is  needed  per  RSI  unit,  at  a  cost  of  EUR  5,000  each. 131  RSI  units  would  need  to 
purchase  PN  testing  equipment.  An  additional  half-day  of  training  related  to  the  use  of  PN  measurement  devices  is 
assumed for the estimated 393 RSI inspectors across the EU in 2026. 
149 One NOx measurement device is assumed per RSI unit, at a cost of EUR 15,000 each. 131 RSI units would need to 
purchase the equipment. An additional half-day of training is assumed for the 393 RSI inspectors. 

32 

 
 
PMC4 (see Table 5). Expressed as present value over 2026-2050, the total one-off and recurrent adjustment 
costs are estimated at EUR 0.2 million for PMC2, EUR 1.3 million for PMC3 and EUR 3.8 million for 
PMC4 (see Table 4). Thus, the adjustment costs due to the common set of measures (PMC2, PMC3 and 
PMC4) are estimated at around EUR 5.2 million, of which EUR 2.9 million one-off costs. In addition to the 
common measures, the most significant one-off adjustment costs in PO1a are due to PM9, concerning the 
recognition  of  PTIs  conducted  in  another  Member  State  than  that  of  registration  based  on  bilateral 
agreements. National authorities are expected to incur expenses for establishing bilateral agreements and 
implementing procedures to facilitate inspections in another Member State. Assuming each Member State 
establishes three bilateral agreements, the total costs for 41 such agreements have been estimated at around 
EUR 1.4 million in 2026 (EUR 53,550 per Member State). In addition, PM1 will require that those Member 
States150  that  do  not  have  a  PTI  requirement  for  motorcycles  to  introduce  roadside  inspections  for 
motorcycles  over  125cm3  as  an  alternative, leading to  the need  of  purchasing  additional  equipment  to 
support these inspections (one-off adjustment costs) and of maintaining it (recurrent adjustment costs). The 
one-off adjustment costs due to PM1 are estimated at EUR 0.1 million in 2026 and the recurrent adjustment 
costs at EUR 12,000 per year from 2026 onwards151 (see Table 5 and Table  6).  The total one-off and 
recurrent adjustment costs for national public authorities due to PO1a are thus estimated at EUR 7 million 
(see Table 4), expressed as present value over 2026-2050, of which EUR 4.4 million one-off costs.   

In PO1b, in addition to the costs of the common measures (PMC2, PMC3 and PMC4), the most significant 
additional adjustment costs for authorities arise due to the introduction of remote sensing, and the option to 
use plume chasing to measure NOx emissions from trucks, as well as the installation of noise cameras 
(PM12). PM12 involves one-off costs for the purchase of the necessary equipment, the setting up of the 
corresponding  IT  infrastructure  and  related  training  of  inspectors,  as  well  as  recurrent  costs  for  the 
maintenance of the equipment and data management, and labour costs for the inspectors performing the 
plume chasing152. The one-off adjustment costs due to PM12 amount to EUR 23.6 million in 2026, and the 
recurrent adjustment costs to EUR 9.4 million per year (see Table 5 and Table 6). Total adjustment costs 
due to this measure are thus estimated at EUR 192.9 million, expressed as present value over 2026-2050 
relative to the baseline. In addition, PM13 is expected to lead to one-off adjustment costs for national public 
authorities for training on cargo securing in the 14 Member States153 that currently do not require minimum 
training of inspectors (EUR 26,916 in 2026), and recurrent adjustment costs for the retraining of inspectors 
on a biennial basis (EUR 26,916 per year every second year after 2026)154. Total adjustment costs for PO1b 
are thus estimated at EUR 198.3 million (see Table 4), expressed as present value over the 2026-2050 
period relative to the baseline, of which EUR 26.5 million one-off costs. 

PO2 includes the  adjustment  costs related to the common measures (PMC2, PMC3, PMC4), the costs 

150 These are: BE, FI, IE, NL, MT and PT. FR will introduce PTI for powered two- and three-wheelers and quadricycles in 
2024. DK does not have mandatory PTI but since 1 January 2022 it has introduced roadside inspections. In the case of 
PT, current requirements cover only motorcycles over 250cc.  
151 For a 5% share of the motorcycles fleet one extra RSI unit per Member State is expected to be sufficient. The capital 
costs are estimated at EUR 20,000 per unit and maintenance costs are assumed at around 10% of the capital costs. 
152 For remote sensing, 250 devices would be needed in EU27 to be able to analyse at least 30% of the road fleet. The 
capital cost of a remote sensing equipment is estimated at EUR 85,000. Maintenance and calibration costs are around 5% 
of the capital costs, and the cost for the processing and data management EUR 24,000 per year per device. In addition, 
one day of training for the use of NOx and PM remote sensing equipment is assumed for the 393 RSI inspectors. For 
plume chasing, the capital costs are estimated at EUR 32,500 per equipment. On average, two vehicles are assumed per 
Member State, for 26 Member States (DK has already implemented the system). The maintenance and calibration costs 
are around 5% of the capital cost. Labour costs are estimated assuming one inspector per plume chasing vehicle and four 
days per week of plume chasing. Two days of training on plume chasing are assumed for the 52 inspectors. For acoustic 
cameras, the capital costs are estimated at EUR 2,000 per device, and the maintenance cost at 5% of the capital cost. A 
half-day training would be needed for 393 RSI inspectors, for using the acoustic cameras. 
153 BE, DK, DE, EE, FR, IE, LV, LU, BG, FI, IT, NL, PL and PT.  
154 Training for cargo securing is assumed to take 3 hours, with 264 roadside inspectors requiring training. 

33 

 
 
related to PM1 as in PO1a, and the costs related to PM12 and PM13 as in PO1b. To this, PO2 adds one-off 
costs  for  additional  roadside  equipment  and  training  of  inspectors  due  to  the  introduction  of  roadside 
inspections for light commercial vehicles (PM14)155, estimated at EUR 3.1 million in 2026, and recurrent 
costs for the maintenance of equipment, estimated at EUR 0.3 million per year156 (see Table 5 and Table 
6). Expressed as present value over 2026-2050, the total costs of PM14 are estimated at EUR 8.6 million. 
Total adjustment costs for PO2 are thus estimated at EUR 207.2 million, expressed as present value over 
2026-2050 relative to the baseline, of which EUR 29.7 million one-off costs. 

PO3 includes the adjustment costs related to the common measures (PMC2, PMC3, PMC4) and the costs 
related to PM12, PM13 and PM14 as in PO2. Moreover, it adds one-off adjustment costs for the purchase 
of additional mobile inspection units due to the introduction of roadside checks for motorcycles (PM15)157, 
estimated at EUR 0.4 million in 2026, and recurrent costs for the maintenance of the inspection units (EUR 
40,000 per year from 2026 onwards)158. Expressed as present value over 2026-2050, the total costs of PM15 
are estimated at EUR 1.1 million. Thus, the total adjustment costs for authorities for PO3 are estimated at 
EUR 208 million, expressed as present value over 2026-2050 relative to the baseline, of which EUR 30 
million one-off costs.  

Administrative costs. All policy options include administrative costs for public authorities related to four 
common measures (PMC6, PMC7, PMC8 and PMC9). The digitalisation of the roadworthiness certificate 
(PMC6) is expected to lead to one-off administrative costs for the development of the software for electronic 
certificates,  estimated  at  EUR  17.8  million  in  2026159,  and  recurrent  administrative  costs  for  the 
maintenance  and  update  of  the  system  (EUR  0.9  million  per  year  from  2026  onwards)160.  The 
interconnection  of  national  vehicle  registers  (PMC7)  would  result  in  one-off  administrative  costs  for 
developing the common interfaces for accessing the data, estimated at EUR 8.1 million in 2026 (EUR 
300,000 per Member State), and recurrent administrative costs for providing access to the relevant data 
(EUR 0.4 million per year from 2026 onwards). Further harmonisation and regular update of technical data 
in the registration documents (PMC8) is expected to lead to one-off administrative costs for redesigning 
and setting up the new template for the registration documents, estimated at EUR 0.7 million in 2026 and 
recurrent administrative costs for the regular update of the vehicle registration documents with new items 
that may be found relevant in the future (EUR 0.5 million per year from 2026 onwards). The most significant 
administrative costs in all policy options arise from PMC9, under which authorities (except Belgium and 
the Netherlands that have already implemented the system) will need to develop a system for the recording 
of odometer readings of vehicles at garages and other repair stations. Based on the information provided by 
CAR-Pass161, the one-off cost per database that will be collecting the odometer readings at Member State 

155 Few Member States (ES, HU, SE, SK and FI) already conduct roadside inspections for  light commercial vehicles. 
This measure is thus relevant for 22 MS.  
156 The extra inspections will be delivered by an estimated total of 182 inspectors in around 61 roadside inspection units. 
These units will need to be equipped with relevant equipment. The one-off cost of the roadside equipment is around EUR 
50,000, and the maintenance cost is estimated at 10% of the capital cost. One-day training per inspector is assumed. 
157 Few Member States (SE, SI, AT, FI, DK, HU, RO) already perform such inspections and are thus part of the baseline.  
158 On the basis of the additional number of inspections to be conducted it is estimated that a total of 32 inspectors will 
be needed for the 20 Member States. With an average of 3 inspectors per unit, each Member State will need a minimum 
of one additional set of roadside equipment for testing of motorcycles. The one-off cost per equipment is estimated at 
EUR 20,000, and the recurrent maintenance cost at 10% of the initial cost. In addition, a one-day training is assumed per 
inspector in 2026 for the 32 inspectors. 
159 Assuming one-off costs of EUR 500,000 per IT system for each of the 15 Member States with smaller volumes of 
inspections (BG, CY, EE, FI, HR, HU, IE, LT, LV, LU, MT, SI, SK, DK and CZ ), EUR 750,000 per IT system for each 
of the 7 Member States with medium volumes of inspections (AT, BE, EL, NL, PT, RO and SE) and EUR 1,000,000 per 
IT system for each of the 5 Member States with higher volumes of inspections (DE, FR, IT, PL and ES). More details are 
provided in Annex 4 (section 3). 
160 Assumed at 5% of the capital costs. 
161 https://www.car-pass.be/en/  

34 

 
 
level is  estimated  at  around  EUR  1 million.  Furthermore, the  annual  cost  of  operating  the  system was 
estimated at around EUR 0.42 per vehicle (in 2022 prices)162. In total, one-off administrative costs for 
authorities are estimated at around EUR 25 million in 2026, and recurrent costs at EUR 111.4 million in 
2030 and EUR 125.6 million in 2050 relative to the baseline163. Expressed as present value over 2026-2050, 
the total one-off and recurrent administrative costs are estimated at EUR 33.7 million for PMC6, EUR 15.4 
million for PMC7, EUR 9.4 million for PMC8 and EUR 2.12 billion for PMC9 (see Table 4). Thus, the 
administrative costs due to the common set of measures (PMC6, PMC7, PMC8 and PMC9) are estimated 
at around EUR 2.18 billion, expressed as present value over 2026-2050, of which EUR 51.6 million one-
off costs.  

In  PO1a,  beyond  the  costs  of  the  common  measures  (PMC6,  PMC7,  PMC8  and  PMC9),  additional 
administrative costs are expected from the introduction of RSI for motorcycles not covered by PTI in six 
Member States (PM1), from the digitalisation of the registration certificates (PM16), and from adding new 
data elements to the vehicle registers (PM17). The recurrent administrative costs (i.e., labour costs for the 
additional inspections) due to PM1 are estimated at EUR 0.5 million in 2030 and EUR 0.6 million in 2050 
relative to the baseline164. For PM16, the one-off costs for the adaptation of the IT system are estimated at 
EUR 12.8 million in 2026, while the recurrent costs for maintenance are estimated at EUR 1.3 million per 
year165. The one-off costs for harmonising the dataset in PM17 are estimated at EUR 0.5 million in 2026 
and the recurrent costs for continuous data updates and broader maintenance of the dataset at EUR 0.4 
million per year. Expressed as present value over 2026-2050, total administrative costs are estimated at 
EUR 9.1 million for PM1, EUR 35.8 million for PM16 and EUR 8.4 million for PM17. Altogether, the 
administrative costs for authorities under PO1a amount to EUR 2.23 billion expressed as present value over 
2026-2050 relative to the baseline. 

On top of the common measures, PO1b includes only one measure that generates administrative costs for 
authorities, namely the mandatory inspection of cargo securing (PM13). The recurrent administrative costs 
relate to labour  costs  for  the  additional  cargo  securing  inspections  and  are  estimated  at  EUR  0.5 
million in 2030 and EUR 0.6 million in 2050 relative to the baseline166 (EUR 9.8 million expressed as 
present value over 2026-2050). The total administrative costs for authorities under PO1b are thus estimated 
at EUR 2.19 billion, expressed as present value over 2026-2050. 

PO2 includes the administrative costs related to the common measures, the costs related to PM1, PM16 and 
PM17 as in PO1a, and the costs related to PM13 as in PO1b. In addition, it includes administrative costs 
related  to  two  other  measures  (PM11  and  PM14).  In  the  case  of  PM11  (adaptations  related  to  data 
governance ensuring access to vehicle data for PTI centres), total one-off costs for the adaptation of the IT 
system are estimated at EUR 13 million in 2026167, and recurrent administrative costs at EUR 1.3 million 
per year168. This is equivalent to total one-off and recurrent costs of EUR 36.3 million, expressed as present 
value  over  2026-2050.  In  addition,  the  roadside  testing  of  vans  (PM14)  will  also  generate  recurrent 
administrative costs (i.e., labour costs for the additional inspections), estimated at EUR 5.6 million in 2030 

162 European Parliament (2018), Odometer Manipulation in motor vehicles in Europe, 
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf  
163 The number of cars and vans relevant for PMC9 are projected at 262.4 million in 2030 and 295.8 million in 2050. 
164 The average cost per inspection is estimated at EUR 5.7 and the number of roadside inspections for motorcycles in 
PM1 at 82,566 in 2030 and 104,321 in 2050 for the 6 Member States concerned (BE, FI, IE, NL, MT and PT). 
165  The  one-off  costs  for  the  adaptation  of  the  IT  system  are  estimated  at  EUR  300,000  to  EUR  1,000,000  per  MS, 
depending on the volume of new registrations, and costs for maintenance at 10% of the capital costs. 
166 A cargo securing inspection takes on average 20 minutes. Cargo securing inspections are expected to cover 5% of the 
N2/N3 fleet in the Member States affected by the measure (EE, FR, IE, LV and LU). 
167 Inputs from stakeholders (NL and SI authorities) suggest one-off costs for the adaptation of IT systems in the range of EUR 
300,000 to EUR 1,000,000 per country, depending on the volume of PTI inspections per country.  
168 Recurrent administrative costs for maintenance are estimated at around 10% of the capital costs. 

35 

 
 
and EUR 6.7 million in 2050169 relative to the baseline (EUR 107.5 million, expressed as present value over 
2026-2050). All in all, the one-off and recurrent administrative costs for authorities under PO2 are expected 
to amount to EUR 2.39 billion, expressed as present value over 2026-2050. 

PO3 includes the administrative costs related to the common measures and the costs related to the additional 
measures under PO2 (except for PM1). In addition, the introduction of RSI for motorcycles (PM15) is 
expected to lead to recurrent administrative costs (i.e., labour costs for the additional inspections), estimated 
at EUR 1 million in 2030 and EUR 1.3 million in 2050170 (EUR 19.5 million expressed as present value 
over 2026-2050). Thus, the total one-off and recurrent administrative costs for authorities due to PO3 would 
be close to EUR 2.40 billion, expressed as present value over 2026-2050 relative to the baseline. 

Enforcement costs. No enforcement costs for national authorities are expected in PO1a and PO2. In PO1b 
recurrent enforcement costs are due to the introduction of mandatory PTI for motorcycles above 125cm3 
(PM2) that will imply some extra costs for the authorities that are responsible for monitoring the operation 
of the system, for evaluating the quality and impartiality of the additional tests. Recurrent enforcement costs 
in PO1b are estimated at EUR 1.7 million in 2030 and EUR 2.1 million in 2050171 (see Table 5), or EUR 
32.9 million expressed as present value over 2026-2050 relative to the baseline. Similarly, in PO3, the 
extended scope of PTI to all motorcycles (PM3) is expected to result in monitoring costs of EUR 2 million 
in 2030 and EUR 2.5 million in 2050 (EUR 38.1 million expressed as present value over 2026-2050) and 
the mandatory PTI for light trailers (PM4) will lead to monitoring costs of EUR 2.1 million in 2030 and 
EUR 2.3 million in 2050172 (EUR 39.2 million expressed as present value over 2026-2050). Total recurrent 
enforcement costs for PO3 are thus estimated at EUR 77.4 million, expressed as present value over 2026-
2050 (see Table 4). 

Administrative cost savings. Recurrent cost savings for national administrations arise from the common 
measures PMC6 (roadworthiness certificate in electronic format) and PMC7 (the interlinking of national 
vehicle  registers)  in  all  policy  options,  as  well  as  from  PM16  (issuing  digital  registration  certificates) 
included in PO1a, PO2 and PO3. The savings are expected to be significant in all options, and especially 
under PO1a, PO2 and PO3, reaching EUR 5.23 billion, expressed as present value over 2026-2050 (see 
Table 4). In PO1b they are estimated to be lower, at EUR 3.80 billion. The largest potential savings are 
expected from PMC6, due to issuing the roadworthiness certificates in electronic format only, estimated at 
EUR 167.3 million in 2030 and EUR 190.6 million in 2050 (EUR 3.16 billion expressed as present value 
over 2026-2050)173. Cost savings related to PMC7, due to the time saved for the re-registration of a vehicle 
in another Member State, are estimated at EUR 35.8 million per year from 2026 onwards (EUR 641.8 
million  expressed  as  present  value  over  2026-2050)174.  In  addition,  PM16  will  bring  further  recurrent 
administrative costs savings for national public authorities, by avoiding the costs of printing, distribution 
and handling of paper/plastic registration certificates, estimated at EUR 79.3 million in 2030 and EUR 86.3 

169 The additional number of inspections due to the measures is estimated at 497,627 in 2030 and 588,721 in 2050. The 
cost per inspection is estimated at EUR 11.3. 
170 For the 20 Member States concerned (excluding SE, SI, AT, FI, DK, HU, RO that already perform such inspections) 
the number of additional inspections is estimated at 176,228 in 2030 and 227,291 in 2050 relative to the baseline. The 
cost per inspection is estimated at EUR 5.7. 
171 An average monitoring cost of EUR 2.25 per PTI for motorcycles. 
172 An average monitoring cost of EUR 1.5 per PTI for light trailers. 
173  The  cost  of  a  paper  roadworthiness  (RW)  certificate  is  estimated  at  1  EUR  per  certificate.  The  number  of  RW 
certificates issued in paper format in the baseline is estimated at 167.3 million in 2030 and 190.6 million in 2050. 
174 PMC7 is expected to lead to time savings of around 15 minutes per re-registration of a vehicle in another Member 
State because of less need of reaching out to other National Contact Points by phone/mail.  

36 

 
 
million in 2050 (EUR 1.43 billion expressed as present value over 2026-2050)175.  

Net benefits. All policy options are expected to lead to net benefits for national public authorities. Net 
benefits, expressed as present value over 2026-2050 relative to the baseline, are estimated to be the highest 
in PO1a (EUR 2.99 billion), followed by PO2 (EUR 2.63 billion), PO3 (EUR 2.54 billion) and PO1b (EUR 
1.38 billion). 

Table  4:  Recurrent  and  one-off  costs,  and  costs  savings  for  national  public  authorities  in  the  policy  options, 
expressed as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices) 

Adjustment costs 

PMC2 
PMC3 
PMC4 
PM1 
PM9 
PM12 
PM13 
PM14 
PM15 

Administrative costs 

PMC6 
PMC7 
PMC8 
PMC9 
PM1 
PM11 
PM13 
PM14 
PM15 
PM16 
PM17 

Enforcement costs 

PM2 
PM3 
PM4 

Administrative costs savings 

PMC6 
PMC7 
PM16 
Net benefits 

PO1a 

Difference to the baseline 
PO1b 

PO2 

7.0 
0.2 
1.3 
3.8 
0.3 
1.4 

2,233.8 
33.7 
15.4 
9.4 
2,122.1 
9.1 

35.8 
8.4 
0.0 

5,226.3 

3,155.0 
641.8 
1,429.5 
2,985.5 

198.3 
0.2 
1.3 
3.8 

192.9 
0.3 

2,190.4 
33.7 
15.4 
9.4 
2,122.1 

9.8 

32.9 
32.9 

3,796.8 

3,155.0 
641.8 

1,375.2 

207.2 
0.2 
1.3 
3.8 
0.3 

192.9 
0.3 
8.6 

2,387.5 
33.7 
15.4 
9.4 
2,122.1 
9.1 
36.3 
9.8 
107.5 

35.8 
8.4 
0.0 

5,226.3 

3,155.0 
641.8 
1,429.5 
2,631.6 

PO3 

208.0 
0.2 
1.3 
3.8 

192.9 
0.3 
8.6 
1.1 
2,397.9 
33.7 
15.4 
9.4 
2,122.1 

36.3 
9.8 
107.5 
19.5 
35.8 
8.4 
77.4 

38.1 
39.2 
5,226.3 

3,155.0 
641.8 
1,429.5 
2,543.1 

Source: Ricardo et al. (2024), Impact assessment support study 

175 The costs savings due to PM16 are limited to the time spent for preparing and printing the documents and the costs of 
delivering the documents. It is assumed that around 2 minutes of work per document could be saved, at an average cost 
per hour for technicians and associate professionals (ISCO level 3) of EUR 34, plus EUR 2 per document for paper and 
mail cost. 

37 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
Table 5: Recurrent and one-off costs, and costs savings for national public authorities in the policy options, in 
2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices) 

Difference to the baseline 

PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

Adjustment 
costs 

PMC2 

PMC3 

PMC4 

PM1 

PM9 

PM12 

PM13 

PM14 

PM15 

Administrative 
costs 

PMC6 

PMC7 

PMC8 

PMC9 

PM1 

PM11 

PM13 

PM14 

PM15 

PM16 

PM17 

Enforcement 
costs 

PM2 

PM3 

PM4 

Administrative 
costs savings 
PMC6 

PMC7 

PM16 

Net benefits 

4.6 

0.2 

0.7 

2.1 

0.1 

1.4 

0.1 

0.1 

36.1 

9.6 

9.6 

39.6 

9.9 

9.9 

39.9 

9.9 

9.9 

0.2 

0.7 

2.1 

0.03 

0.1 

0.03 

0.1 

0.03 

0.1 

0.01 

0.03 

0.1 

0.01 

33.0 

0.03 

9.4 

0.03 

9.4 

0.03 

0.2 

0.7 

2.1 

0.1 

33.0 

0.03 

3.4 

0.03 

0.1 

0.01 

9.4 

0.03 

0.3 

0.03 

0.1 

0.01 

9.4 

0.03 

0.3 

0.2 

0.7 

2.1 

33.0 

0.03 

3.4 

0.45 

0.03 

0.1 

0.03 

0.1 

9.4 

0.03 

0.3 

0.04 

9.4 

0.03 

0.3 

0.04 

176.9 

115.3 

129.7 

161.9 

113.7 

128.0 

197.1 

122.8 

138.3 

197.6 

123.3 

139.0 

18.6 

8.5 

1.2 

0.9 

0.4 

0.5 

0.9 

0.4 

0.5 

18.6 

8.5 

1.2 

0.9 

0.4 

0.5 

0.9 

0.4 

0.5 

18.6 

8.5 

1.2 

0.9 

0.4 

0.5 

0.9 

0.4 

0.5 

18.6 

8.5 

1.2 

0.9 

0.4 

0.5 

0.9 

0.4 

0.5 

133.1 

111.4 

125.6 

133.1 

111.4 

125.6 

133.1 

111.4 

125.6 

133.1 

111.4 

125.6 

0.5 

0.5 

0.6 

14.1 

0.9 

0.0 

1.3 

0.4 

0.0 

1.3 

0.4 

0.0 

0.5 

14.3 

0.5 

5.4 

14.1 

0.9 

0.0 

0.5 

1.3 

0.5 

5.6 

1.3 

0.4 

0.0 

0.6 

1.3 

0.6 

6.7 

1.3 

0.4 

0.0 

0.5 

0.5 

0.6 

1.6 

1.6 

1.7 

1.7 

2.1 

2.1 

14.3 

0.5 

5.4 

1.0 

14.1 

0.9 

3.9 

1.9 

2.0 

1.3 

0.5 

5.6 

1.0 

1.3 

0.4 

4.0 

2.0 

2.1 

1.3 

0.6 

6.7 

1.3 

1.3 

0.4 

4.8 

2.5 

2.3 

272.7 

282.3 

312.7 

197.3 

203.0 

226.4 

272.7 

282.3 

312.7 

272.7 

282.3 

312.7 

161.5 

167.3 

190.6 

161.5 

167.3 

190.6 

161.5 

167.3 

190.6 

161.5 

167.3 

190.6 

35.8 

75.4 

91.2 

35.8 

79.3 

35.8 

86.3 

35.8 

35.8 

35.8 

166.8 

182.9 

-2.4 

78.1 

86.7 

35.8 

75.4 

35.9 

35.8 

79.3 

35.8 

86.3 

149.6 

164.5 

35.8 

75.4 

31.2 

35.8 

79.3 

35.8 

86.3 

145.0 

159.0 

Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs. 

Table 6: One-off costs for national public authorities in the policy options, in 2026, 2030 and 2050, relative to the 
baseline, in million EUR (2022 prices) 

Difference to the baseline 

PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

Adjustment 
costs 

PMC2 

PMC3 

PMC4 

PM1 

PM9 

PM12 

PM13 

4.4 

0.2 

0.7 

2.0 

0.1 

1.4 

0.0 

0.0 

26.5 

0.0 

0.0 

29.7 

0.0 

0.0 

30.0 

0.0 

0.0 

0.2 

0.7 

2.0 

0.1 

23.6 

0.03 

0.2 

0.7 

2.0 

23.6 

0.03 

38 

0.2 

0.7 

2.0 

23.6 

0.03 

 
  
 
 
 
 
 
 
 
 
  
  
  
  
  
  
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
  
 
 
 
 
  
 
 
  
 
 
  
 
 
  
  
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

Difference to the baseline 

64.9 

0.0 

0.0 

51.6 

0.0 

0.0 

77.9 

0.0 

0.0 

77.9 

0.0 

0.0 

3.1 

3.1 

0.4 

17.8 

8.1 

0.7 

25.0 

12.8 

0.5 

69.3 

17.8 

8.1 

0.7 

25.0 

17.8 

8.1 

0.7 

25.0 

13.0 

12.8 

0.5 

17.8 

8.1 

0.7 

25.0 

13.0 

12.8 

0.5 

0.0 

0.0 

78.1 

0.0 

0.0 

107.6 

0.0 

0.0 

107.9 

0.0 

0.0 

PM14 

PM15 

Administrative 
costs 

PMC6 

PMC7 

PMC8 

PMC9 

PM11 

PM16 

PM17 

Net costs 

Source: Ricardo et al. (2024), Impact assessment support study 

6.1.2.  Impacts on businesses 

This section describes the impacts on affected businesses, primarily PTI stations, but also garage equipment 
manufacturers, garages, motor vehicle dealers, various repair workshops, vehicle manufacturers and other 
businesses (i.e., vehicle owners). The costs, costs savings and other benefits by policy option are discussed 
below, while the detailed calculations by policy measure are provided in Annex 4 (section 3). 

6.1.2.1. 

Impacts on PTI centres 

The vast majority of periodic technical inspections are conducted by businesses. In some Member 
States  periodic  technical  inspections  can  be  performed  by  the  central  licencing  authority  in  the 
country and/or public inspection centres (i.e., governmental owned vehicle inspection centres), in 
addition (e.g. EL, ES, HU, LV, RO) or instead (e.g. LU) of private inspection centres. On the other 
hand, in AT and NL, they are performed by  thousands of commercial garages. Annex 6 provides 
more details on this point. Given the diversity at Member State level and the fact that in most Member 
States PTIs are mostly performed by private inspection centres (e.g., in RO, less than 5% of the tests 
are performed by public authorities), the PTI centres were classified under businesses for the purpose 
of this impact assessment. The precise share of periodic technical inspections carried out by private 
entities is not available. 

All policy options result in adjustment costs for PTI centres, while PO2 and PO3 also lead to administrative 
costs. On the other hand, all policy options are expected to generate benefits for PTI centres due to the 
increased number of inspections, and PO2 and PO3 will also lead to administrative costs savings (see Table 
7 to Table 10).   

Depending  on  the  Member  State,  the  additional  costs  for  the  PTI  centres  due  to  the  additional 
requirements per PTI may be passed through to vehicle owners (i.e. citizens and businesses). This 
will depend on how PTI charges are set by the Member State: where prices are not regulated, it is 
likely that PTI centres will seek to recover investment costs, possibly on a relatively short term. On 
the other hand, in Member States that regulate the level of PTI charges, the evolution of those charges 
will  depend  on  the  public  contract  agreed  with  the  PTI  service  provider,  potentially  subject  to 
renegotiation, or on the price-setting policy of the authority that is itself responsible for PTI. In these 
cases,  costs  may  either  be  borne  by  the  service  provider/authority  or  be  recovered  over  a  longer 
period. Considering the complexity of the process, and the uncertainty related to the degree of pass-
through  of  the  costs  as  well  as  the  time  horizon  for  passing-through  the  costs,  in  this  impact 
assessment it has been assumed that the additional costs for the PTI centres are partly borne by them 

39 

 
  
  
  
  
  
  
  
 
 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
  
  
  
 
 
 
 
(i.e. for those measures that would increase the cost per PTI). On the other hand, the higher costs due 
to the increased number of inspections (i.e. due to the extended scope) are fully passed through to the 
vehicle owners, and represent benefits for the PTI centres.  

Adjustment costs. In PO1a, adjustment costs for PTI centres are only due to common measures included 
in all options, namely PMC1, PMC2, PMC3, and PMC4. They cover one-off adjustment costs (see Table 
10) for: the acquisition of tools adapted to the PTI of electric and hybrid vehicles and training of inspectors176 
(PMC1), estimated at EUR 119.8 million in 2026 and EUR 24.4 million in 2030; the software update for 
reading on-board diagnostics and training of inspectors177 (PMC2), estimated at EUR 96.1 million in 2026; 
the purchase of devices for the PN counting and training of inspectors178 (PMC3), estimated at EUR 372.7 
million in 2026; and, the acquisition of NOx measurement equipment and training of inspectors (PMC4)179, 
estimated  at  EUR  1.48  billion  in  2026.  In  addition,  recurrent  adjustment  costs  (i.e.,  maintenance  and 
calibration costs) for the PN and NOx measurement equipment are assumed at 5% of the capital costs, based 
on stakeholders’ feedback, and are estimated at EUR 18.1 million per year from 2026 onwards in PMC3 
and at EUR 73.3 million per year in PMC4 (see Table 9). Expressed as present value over 2026-2050, the 
total  one-off  and  recurrent adjustment  costs are  estimated  at  EUR  143.6  million  for PMC1,  EUR  96.1 
million for PMC2, EUR 697.1 million for PMC3 and EUR 2.80 billion for PMC4 (see Table 7). Thus, 
PO1a results in total one-off and recurrent adjustment costs of around  EUR 3.73 billion, expressed as 
present value over 2026-2050 relative to the baseline, of which EUR 2.09 billion one-off costs. The largest 
share of total adjustment costs in PO1a is due to PMC4 (75% of the costs), followed by PMC3 (19%). 

In PO1b, in addition to the costs entailed by the common measures (same as under PO1a), the mandatory 
PTI  for  motorcycles  above  125cm3  (PM2),  the  annual  emission  testing  for  light  commercial  vehicles 
(PM5), the mandatory yearly testing of vehicles that are 10-year-old or older (PM6), the more advanced 
testing of noise for motorcycles (PM10), and the additional emission tests for vehicles that are found as 
high emitters during remote sensing or plume chasing and are sent for emission tests in a PTI centre 
(PM12) will also lead to one-off and recurrent adjustment costs. For PM2, the one-off adjustment costs are 
driven by the additional PTI lanes needed to deliver the inspections and the training of inspectors in the 
seven  Member  States  where  PTI  is  currently  not  in  place  for  motorcycles  above  125cm3180  and  are 
estimated at EUR 3.3 million in 2026 and up to EUR 40,000 per year post-2026 (see Table 10)181, while 
the  recurrent  costs  (i.e.,  maintenance  costs  for  the  PTI  lanes  and  labour  costs  for  the  additional 
inspections)182 are estimated at EUR 8.9 million in 2030 and EUR 11.1 million in 2050 relative to the 
baseline.  For  PM5,  the  one-off  adjustment  costs  are  due  to  the  additional  PN  and  NOx  measurement 

176  One  stakeholder  (FSD  –  the  German  PTI  agency)  provided  a  cost  estimate  of  EUR  500  per  tool  for  measuring 
insulation resistance and equipotential bonding. One such tool per PTI centre would need to be acquired in 2026 by the 
48,880 PTI centres in the EU, with a second one added in 2030. A three-day training per PTI inspector would be needed 
for the 128,536 inspectors across EU. 
177 The cost for the software update is estimated at EUR 500 per PTI tool and 128,536 PTI tools in the EU would need to 
be updated. A one-day training per inspector would be needed. 
178  For  the  36,173  PTI  centres  in  the  EU  affected  by  this  measure  (excluding  BE,  DE  and  NL,  which  have  already 
introduced such testing and are thus part of the baseline), two PN measurement devices per PTI inspection centre would 
be needed. The price per PN measurement equipment is estimated at EUR 5,000. An additional half day of training related 
to the use of PN-testing for 88,776 inspectors (excluding BE, DE and NL) is assumed to take place in 2026. 
179 The cost per NOx measurement equipment is estimated at EUR 15,000 and each of the 48,880 PTI centres in the EU 
is assumed to be equipped with two devices. An additional half day training related to the use of NOx testing is assumed 
to take place for the 128,536 inspectors across EU. 
180 BE, FI, IE, NL, MT, PT and DK.  
181 The additional number of inspections in the 7 MS is estimated at 751,660 in 2030 and 941,911 in 2050. 204 additional 
PTI lanes would be needed in total over 2026-2050 relative to the baseline. The cost per PTI lane is estimated at EUR 
20,000. A two-day training for the additional inspectors is assumed. 
182 Recurrent maintenance costs for the PTI lanes are assumed at 10% of the capital costs (i.e. EUR 2,000 per lane). The 
labour costs per inspection are estimated at EUR 11.3. 

40 

 
 
equipment needed for the annual emission testing of light commercial vehicles and training of inspectors in 
all Member States, and are estimated at EUR 20.1 million. At the same time, the recurrent costs associated 
with PM5 cover the maintenance costs for the equipment and the labour costs for the additional PN and 
NOx testing, and they are estimated at EUR 49.2 million in 2030 and EUR 4.9 million in 2050 relative to 
the baseline183. For PM6, 11 Member States that do not require annual PTI testing of cars and vans after 10 
years of their registration would be affected184. The additional number of PTIs for cars due to PM6 is 
estimated at 42.1 million in 2030 and 47.5 million in 2050 and for vans at 4.5 million in 2030 and 5.2 million 
in 2050. Thus, this measure would require a very significant increase in the number of PTI lanes and trained 
inspectors over time, with one-off adjustment costs estimated at EUR 1.01 billion in 2026, EUR 4.9 million 
in  2030  and  EUR  1.7  million  in  2050185  (see  Table  10).  It  would  also  lead  to  significantly  higher 
maintenance costs for the PTI lanes and labour costs for performing the inspections, with total recurrent 
costs estimated at EUR 886 million in 2030 and EUR 995.7 million in 2050 relative to the baseline. PM10 
would result in one-off adjustment costs for the acquisition of noise measurement devices and training of 
inspectors in the 23 Member States that currently do not measure L-vehicles noise emissions at PTI186, 
estimated at EUR 4.7 million (see Table 10)187, and in recurrent costs (i.e., maintenance costs for the devices 
and labour costs for the additional testing time)188 of EUR 61.8 million in 2030 and EUR 73.7 million in 
2050 relative to the baseline. For PM12, the additional number of emission tests for internal combustion 
engine  vehicles  (i.e.  for  vehicles  that  are  found  as  high  emitters  during  remote  sensing  or  plume 
chasing and are sent for emission test in a PTI centre) is estimated at 2.4 million in 2030 and 174,609 
in 2050 relative to the baseline189. PM12 is expected to lead to additional labour costs for performing 
the tests, estimated at EUR 8 million in 2030 and EUR 0.6 million in 2050 relative to the baseline190. 
Expressed as present value over 2026-2050, the costs of PM2 are estimated at EUR 175.7 million, those of 
PM5 at EUR 647.7 million, the costs of PM6 at EUR 17.68 billion, those of PM10 at EUR 1.17 billion and 
the costs of PM12 at EUR 99 million. Thus, PO1b results in total one-off and recurrent adjustment costs of 
around EUR 23.51 billion, expressed as present value over 2026-2050 relative to the baseline, of which 
EUR 3.22 billion one-off costs (see Table 7 and Table 8). The largest share of the total adjustment costs in 
PO1b is by far due to PM6 (75% of the costs), followed by PMC4 (12% of the costs), PM10 (5% of the 
costs) and PMC3 (3% of the costs). The common measures, together, represent only 16% of the costs. 

Total one-off and recurrent adjustment costs of PO2 are very similar to those of PO1b, without however 
including the costs due to PM2. They are estimated at EUR 23.33 billion, expressed as present value over 
2026-2050 relative to the baseline, of which EUR 3.22 billion one-off costs (see Table 7 and Table 8). The 
most significant policy measures in terms of costs in PO2 are similar to those in PO1b.  

PO3 includes the same adjustment costs as in PO2, but leads to additional one-off and recurrent adjustment 
costs for extending the PTI to all motorcycles (PM3), for making PTI mandatory for light trailers (PM4) 

183 The recurrent costs decrease over time due to the decreasing number of internal combustion light commercial vehicles 
that require PN and NOx testing. 
184 CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT and SK. 
185 Based on an interview with TUV Rheinland, the cost of a new PTI lane is assumed at EUR 50,000. Each new lane for 
cars in 2026 will also require one set of PN and NOx testing equipment. Additional PN testing and NOx testing equipment 
is assumed only for cars as the costs for such equipment related to vans is already reflected in PM5.  
186 Few MSs (DE, ES, HR and SK) are already measuring L-vehicles noise emissions at PTI. 
187 The cost for purchasing a noise measurement device is estimated at EUR 800 per device, and 2 devices are assumed 
to be needed for each PTI centre with a test track. A half a day of training is assumed per inspector. 
188 Recurrent adjustment costs for the maintenance and calibration of devices are assumed at 5% of the capital cost. The 
additional noise testing is estimated to take around 15 minutes per PTI. 
189 The decrease in the number of emission tests is driven by the increase in the number of zero-emission vehicles over 
time in the baseline. 
190 Due to the small share of the fleet affected it is assessed that no additional emission testing equipment will be needed 
and that the available PTI lanes will be able to serve the additional demand. 

41 

 
 
and for further harmonisation of test methods (PM7). For PM3, the one-off adjustment costs for extending 
the PTI to motorcycles from 50cm3 in the eight Member States where such requirement is currently not in 
place191 are estimated at EUR 3.8 million in 2026 and up to EUR 60,000 per year post-2026192, while the 
recurrent  adjustment  costs  at  EUR  10.2  million  in  2030  and  EUR  13  million  in  2050  relative  to  the 
baseline193. For PM4194, the one-off costs for the additional PTI lanes and the training of inspectors are 
estimated at EUR 1 million in 2026 and up to EUR 20,000 per year post-2026195, and the recurrent costs 
(i.e., for the maintenance of the PTI lanes and the labour costs for the additional inspections) at EUR 11.9 
million in 2030 and EUR 13.4 million in 2050. In PM7, PTI centres in the Member States with lower-
stringency roadworthiness systems will need to acquire new equipment to enhance their capacity, including 
an advanced brake testing device and a suspension tester. One-off costs for equipment and training due to 
PM7 are estimated at EUR 367 million in 2026 and EUR 122.2 million in 2030196, and recurrent costs for 
maintenance  at  EUR  48  million  in 2030  and in 2050. Thus,  PO3  results in total  one-off  and  recurrent 
adjustment costs of EUR 25.06 billion, expressed as present value over 2026-2050 relative to the baseline, 
of which EUR 3.71 billion one-off costs (see Table 7 and Table 8). The largest share of the total adjustment 
costs in PO3 is by far due to PM6 (71% of the costs), followed by PMC4 (11% of the costs), and PM7 and 
PM10 (5% of the costs each). The common measures, together, represent only 15% of the costs in PO3.  

Garage equipment manufacturers will benefit from the measures that require the acquisition of new 
or more testing equipment by PTI centres197.  

Administrative costs. No administrative costs are expected for PTI centres under PO1a and PO1b. In PO2 
and PO3, administrative costs would result from the data governance (PM11), related to the need of the PTI 
centres to adapt their IT systems. The one-off administrative costs for the adaptation of the IT systems is 
estimated at EUR 1,000 per centre. Total one-off administrative costs would therefore amount to EUR 48.9 
million in 2026 for the 48,880 PTI centres across the EU (see Table 10). In addition, recurrent administrative 
costs for the maintenance of the IT systems are estimated at 10% of the capital costs, or EUR 100 per PTI 
centre.  Total  recurrent  administrative  costs  are  thus  estimated  at  EUR  4.9  million  per  year  from  2026 
onwards  (see  Table  9).  Overall,  PO2  and  PO3  are  estimated  to  result  in  total  one-off  and  recurrent 
administrative costs of EUR 136.5 million, expressed as present value over 2026-2050 (see Table 7). 

Administrative costs savings. The data governance (PM11), included in PO2 and PO3, is also expected to 
lead to administrative costs savings for the PTI centres. The access to relevant technical information would 

191 BE, FI, IE, NL, MT, PT, DK and CY (in CY motorcycles above 125cm3 are already covered).  
192 As in PM2, the one-off adjustment costs cover the additional PTI lanes needed to deliver the inspections and the training of 
inspectors. The cost per PTI lane is the same as in PM2. This is also the case of the time required for the training of inspectors.  
193 The recurrent adjustment costs, as in PM2, cover the maintenance costs for the PTI lanes and labour costs for the additional 
inspections. More details are available in Annex 4 (section 3). 
194 Eleven MS would be affected by PM4: 7 MS where there is currently no requirement for PTI for either O1 or O2 (DK, 
EL, FI, FR, NL, IE, PT) and 4 MS where there is currently only a requirement for PTI for O2 (PL, SK, BE and ES). 
195 The cost of an additional PTI lane for trailers is estimated at EUR 10,000 per lane. 
196 For HDV brake testing using extrapolation methods, an average one-off cost of EUR 2,500 is assumed per PTI centre. 
The purchase cost of a suspension tester for light vehicles is around EUR 10,000. Considering the 11 Member States with 
lower-stringency roadworthiness systems, 29,922 of the 48,880 PTI centres would have to invest into advanced brake 
testing equipment and 28,322 into suspension testers. An average of 4 hours of training is assumed per inspector. 
197  Among  the  common  measures  and  thus  in  PO1a,  the  most  important  in  this  respect  are  those  related  to  the  new 
emission tests (PMC3 and PMC4). In PO1b, PO2 and PO3, these businesses would also benefit from additional demand 
for  testing  equipment  generated  mainly  by  annual  emission  testing  of  vans  (PM5),  the  noise  testing  of  motorcycles 
(PM10), and especially due to the annual PTI for cars and vans above 10 years of age (PM6). The benefits from mandatory 
PTI for heavy motorcycles (PM2 in PO1b) would be limited since only a few Member States would be affected. PO3 
would bring additional benefits to garage equipment manufacturers through testing all motorcycles and trailers (PM3 and 
PM4). Furthermore, PM7 would increase the need for more advanced testing equipment. 

42 

 
 
bring some limited time savings for PTI centres for performing the PTIs198, with recurrent administrative 
costs savings estimated at EUR 87.1 million in 2030 and EUR 99.3 million in 2050 (see Table 9). This is 
equivalent to EUR 1.64 billion, expressed as present value over 2026-2050 relative to the baseline (see 
Table 7). No administrative costs savings are expected for PO1a and PO1b.  

Benefits from additional periodic technical inspections. PTI centres will benefit from the extension of the 
scope of PTI and more frequent testing of certain vehicle categories199. In PO1a, the benefits stemming 
from the mandatory roadworthiness testing following significant modifications of the vehicle (PMC5) are 
estimated at EUR 45.5 million in 2030 and EUR 52.3 million in 2050, relative to the baseline (EUR 860.5 
million expressed as present value over 2026-2050). PO1b includes the same benefits as PO1a, due to the 
common measure (PMC5), and adds additional benefits for the PTI centres due to the mandatory PTI for 
motorcycles above 125cm3 (PM2), the annual emission testing of light commercial vehicles (PM5), the 
mandatory yearly testing of vehicles that are 10-year-old or older (PM6) and the additional emission tests 
for vehicles that are found as high emitters during remote sensing or plume chasing and are sent for 
emission tests in a PTI centre (PM12). Of these measures, the highest benefits are estimated for PM6 
(1.94 billion in 2030 and EUR 2.19 billion in 2050; EUR 36.54 billion expressed as present value over 
2026-2050), followed by PM5 (EUR 115 million in 2030 and EUR 9.4 million in 2050; EUR 1.46 billion 
expressed as present value over 2026-2050), PM2 (EUR 15.1 million in 2030 and EUR 19 million in 2050; 
EUR 294.1 million expressed as present value over 2026-2050) and PM12 (EUR 19.7 million in 2030 and 
EUR 1.6 million in 2050; EUR 247.2 million expressed as present value over 2026-2050). Thus, PO1b 
results in total benefits of 2.14 billion in 2030 and EUR 2.27 billion in 2050, relative to the baseline (EUR 
39.39 billion expressed as present value over 2026-2050). In PO2 the total benefits are slightly lower than 
in PO1b as it includes the same measures except for the mandatory PTI for motorcycles above 125cm3 
(PM2). They are estimated in total at EUR 2.12 billion in 2030 and EUR 2.26 billion in 2050. Expressed as 
present value over 2026-2050, the benefits for PTI centres due to PO2 amount to EUR 39.10 billion. The 
highest benefits would be realised under PO3, which in addition to the measures of PO2, adds the extension 
of PTI to all motorcycles (PM3) and the mandatory PTI for light trailers (PM4). They are estimated at EUR 
2.17 billion in 2030 and EUR 2.31 billion in 2050, relative to the baseline (EUR 39.97 billion expressed as 
present value over 2026-2050). PM6 generates around 93% of the total benefits for PTI centres in PO1b 
and PO2 and 91% of the total benefits in PO3. 

Net costs/benefits for PTI centres. PO1a results in net costs for the PTI centres estimated at EUR 2.87 
billion, expressed as present value over 2026-2050 relative to the baseline. On the other hand, PO1b, PO2 
and PO3 result in net benefits for the PTI centres, mainly driven by the measure on the yearly testing of 
older vehicles. The highest net benefits are estimated for PO2 (EUR 17.27 billion, expressed as present 
value over 2026-2050 relative to the baseline), followed by PO3 (EUR 16.41 billion) and PO1b (EUR 15.89 
billion). 

Table 7: Recurrent and one-off costs, costs savings and benefits for PTI centres in the policy options, expressed as 
present value over 2026-2050 relative to the baseline, in million EUR (2022 prices) 

Adjustment costs 

PMC1 
PMC2 

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 

3,734.1 
143.6 
96.1 

23,507.9 
143.6 
96.1 

23,332.2 
143.6 
96.1 

25,061.7 
143.6 
96.1 

198 Time savings of 3 minutes are assumed per PTI. This represents 10% of the average of 30 minutes per PTI for a car. 
Not all PTI centres are expected to benefit of this measure, as access to relevant information is often already available. It 
is expected that only 30% of PTIs would benefit of PM11.  
199 The benefits (i.e. revenues) for the PTI centres are derived based on the number of additional inspections performed 
relative to the baseline, depending on the policy measure, and the PTI charges per vehicle category. More details are 
provided in Annex 4 (section 3). 

43 

 
  
 
PMC3 
PMC4 
PM2 
PM3 
PM4 
PM5 
PM6 
PM7 
PM10 
PM12 

Administrative costs 

PM11 

Administrative costs 
savings 
PM11 
Benefits 
PMC5 
PM2 
PM3 
PM4 
PM5 
PM6 
PM12 
Net benefits 

PO1a 

PO1b 

PO2 

PO3 

Difference to the baseline 

697.1 
2,797.3 

0.0 

0.0 

860.5 
860.5 

-2,873.6 

697.1 
2,797.3 
175.7 

647.7 
17,680.8 

1,170.6 
99.0 
0.0 

0.0 

39,394.2 
860.5 
294.1 

1,454.8 
36,537.6 
247.2 
15,886.2 

697.1 
2,797.3 

647.7 
17,680.8 

1,170.6 
99.0 
136.5 
136.5 
1,643.4 

1,643.4 
39,100.1 
860.5 

1,454.8 
36,537.6 
247.2 
17,274.7 

697.1 
2,797.3 

203.9 
225.4 
647.7 
17,680.8 
1,300.2 
1,170.6 
99.0 
136.5 
136.5 
1,643.4 

1,643.4 
39,968.0 
860.5 

341.3 
526.6 
1,454.8 
36,537.6 
247.2 
16,413.2 

Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs. 

Table 8: One-off costs for PTI centres in the policy options, expressed as present value over 2026-2050 relative to 
the baseline, in million EUR (2022 prices) 

PO1a 

PO1b 

PO2 

PO3 

Difference to the baseline 

2,094.7 
143.6 
96.1 
372.7 
1,482.3 

Adjustment costs 

PMC1 
PMC2 
PMC3 
PMC4 
PM2 
PM3 
PM4 
PM5 
PM6 
PM7 
PM10 

Administrative costs 

0.0 

3,221.3 
143.6 
96.1 
372.7 
1,482.3 
3.9 

20.1 
1,097.9 

4.7 
0.0 

PM11 
Net costs 

2,094.7 

3,221.3 

Source: Ricardo et al. (2024), Impact assessment support study 

3,217.4 
143.6 
96.1 
372.7 
1,482.3 

20.1 
1,097.9 

4.7 
48.9 
48.9 
3,266.3 

3,708.7 
143.6 
96.1 
372.7 
1,482.3 

4.5 
1.1 
20.1 
1,097.9 
485.6 
4.7 
48.9 
48.9 
3,757.6 

44 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 9: Recurrent and one-off costs, costs savings and benefits for PTI centres in the policy options, in 2026, 2030 
and 2050, relative to the baseline, in million EUR (2022 prices) 

PO1a 
2030 
115.8 

24.4 
0.0 
18.1 
73.3 

2026 
2,162 

119.8 
96.1 
390.8 
1,556 

Difference to the baseline 

2050 
91.4 

2026 
4,186 

0.0 
0.0 
18.1 
73.3 

119.8 
96.1 
390.8 
1,556 
11.9 

PO1b 
2030 
1,130 

24.4 
0.0 
18.1 
73.3 
8.9 

2050 
1,177 

2026 
4,175 

119.8 
96.1 
390.8 
1,556 

0.0 
0.0 
18.1 
73.3 
11.1 

PO2 
2030 
1,121 

24.4 
0.0 
18.1 
73.3 

2050 
1,166 

2026 
4,603 

0.0 
0.0 
18.1 
73.3 

69.6 
1,870 

49.2 
886.0 

4.9 
995.7 

69.6 
1,870 

49.2 
886.0 

4.9 
995.7 

Admin costs 

0.0 

0.0 

0.0 

63.6 
8.6 

0.0 

61.8 
8.0 

0.0 

73.7 
0.6 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

44.1 
44.1 

45.5 
45.5 

52.3 
52.3 

2,086 
44.1 
14.8 

2,135 
45.5 
15.1 

2,275 
52.3 
19.0 

63.6 
8.6 

53.8 

53.8 
84.1 

61.8 
8.0 

4.9 

4.9 
87.1 

73.7 
0.6 

4.9 

4.9 
99.3 

84.1 
2,071 
44.1 

87.1 
2,120 
45.5 

99.3 
2,256 
52.3 

PO3 
2030 
1,313 

24.4 
0.0 
18.1 
73.3 

10.2 
11.9 
49.2 
886.0 
170.2 
61.8 
8.0 

4.9 

4.9 
87.1 

87.1 
2,166 
45.5 

17.5 
28.0 
115.0 
1,940 
19.7 
934.7 

2050 
1,241 

0.0 
0.0 
18.1 
73.3 

13.0 
13.4 
4.9 
995.7 
48.0 
73.7 
0.6 

4.9 

4.9 
99.3 

99.3 
2,309 
52.3 

22.1 
31.5 
9.4 
2,192 
1.6 
1,163 

119.8 
96.1 
390.8 
1,556 

13.7 
12.3 
69.6 
1,870 
402.8 
63.6 
8.6 

53.8 

53.8 
84.1 

84.1 
2,115 
44.1 

17.0 
26.6 
115.8 
1,890 
21.4 
-2,458 

115.8 
1,890 
21.4 
-2,100 

115.0 
1,940 
19.7 
1,006 

9.4 
2,192 
1.6 
1,097 

115.8 
1,890 
21.4 
-2,073 

115.0 
1,940 
19.7 
1,082 

9.4 
2,192 
1.6 
1,184 

-2,118 

-70.3 

-39.1 

Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs. 

Table 10: One-off costs for PTI centres in the policy options, in 2026, 2030 and 2050, relative to the baseline, in 
million EUR (2022 prices) 

Difference to the baseline 

PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

2,071 

24.4 

0.0 

3,111 

29.4 

1.7 

3,107 

29.3 

1.7 

3,479 

151.6 

119.8 

96.1 

372.7 

1,482 

24.4 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

119.8 

96.1 

372.7 

1,482 

24.4 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

119.8 

96.1 

372.7 

1,482 

24.4 

0.0 

0.0 

0.0 

3.3 

0.02 

0.04 

Administrative 
costs 

0.0 

0.0 

0.0 

20.1 

1,012 

4.7 

0.0 

0.0 

4.9 

0.0 

0.0 

0.0 

1.7 

0.0 

0.0 

20.1 

1,012 

4.7 

48.9 

0.0 

4.9 

0.0 

0.0 

45 

0.0 

0.0 

0.0 

0.0 

0.0 

1.7 

0.0 

0.0 

119.8 

96.1 

372.7 

1,482 

3.8 

1.0 

20.1 

1,012 

367.0 

4.7 

48.9 

24.4 

0.0 

0.0 

0.0 

0.02 

0.02 

0.0 

4.9 

122.2 

0.0 

0.0 

1.7 

0.0 

0.0 

0.0 

0.0 

0.06 

0.00 

0.0 

1.7 

0.0 

0.0 

0.0 

Adjustment 
costs 

PMC1 
PMC2 
PMC3 
PMC4 
PM2 
PM3 
PM4 
PM5 
PM6 
PM7 
PM10 
PM12 

PM11 
Admin costs 
savings 
PM11 
Benefits 
PMC5 
PM2 
PM3 
PM4 
PM5 
PM6 
PM12 
Net benefits 

Adjustment 
costs 

PMC1 

PMC2 

PMC3 

PMC4 

PM2 

PM3 

PM4 

PM5 

PM6 

PM7 

PM10 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Difference to the baseline 

PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PM11 

Net costs 

2,071 

24.4 

0.0 

3,111 

29.4 

1.7 

3,156 

48.9 

Source: Ricardo et al. (2024), Impact assessment support study 

PO2 

2030 

0.0 

29.3 

2050 

2026 

PO3 

2030 

0.0 

1.7 

48.9 

0.0 

3,528 

151.6 

2050 

0.0 

1.7 

Net costs/benefits per PTI centre. Looking at the costs and benefits per PTI centre (see Table 11), expressed 
as present value over 2026-2050, reveals that the highest total costs per PTI centre are expected in PO3 
(EUR 516 thousand), followed by PO1b (EUR 481 thousand), PO2 (EUR 480 thousand) and PO1a (EUR 
76 thousand). The highest benefits (including costs savings) are however also projected for PO3 (EUR 851 
thousand),  followed  by  PO2  (EUR  834  thousand),  PO1b  (EUR  806  thousand)  and  PO1a  (EUR  18 
thousand). The highest net benefits are however estimated for PO2 at EUR 353 thousand, followed by PO3 
at EUR 336 thousand and PO1b at EUR 325 thousand, while PO1a results in net costs of around EUR 59 
thousand. Net benefits in PO2 represent around 6.3% of the turnover per PTI centre, in PO3 around 6% of 
the turnover, in PO1b around 5.8% of the turnover per PTI centre, while the net costs in PO1a around 1.1% 
of the turnover.  

Table 11: Recurrent and one-off costs, costs savings and benefits per PTI centre in the policy options, expressed 
as present value over 2026-2050 relative to the baseline, in thousand EUR (2022 prices) and share of the turnover 

Adjustment costs  

Administrative costs  

Administrative costs savings 

Benefits from additional periodic technical inspections 

Net benefits 

Share of turnover (%) 

Adjustment costs  

Administrative costs  

Administrative costs savings 

Benefits from additional periodic technical inspections 

Net benefits 

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 

76.4 

0.0 

0.0 

17.6 

-58.8 

1.4% 

0.0% 

0.0% 

0.3% 

-1.1% 

480.9 

0.0 

0.0 

805.9 

325.0 

8.6% 

0.0% 

0.0% 

14.5% 

5.8% 

477.3 

2.8 

33.6 

799.9 

353.4 

8.6% 

0.1% 

0.6% 

14.4% 

6.3% 

512.7 

2.8 

33.6 

817.7 

335.8 

9.2% 

0.1% 

0.6% 

14.7% 

6.0% 

Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs. 

6.1.2.2.  Garages, motor vehicle dealers, tyre and repair stations, etc. 

Administrative costs. In all policy options, the requirement for Member States to set up a system to record 
odometer readings from the cars and vans registered in their territory (PMC9), is expected to generate one-
off and recurrent administrative costs for vehicle repair shops (including tyre, windscreen service, etc.), 
motor vehicle dealers and other garages. One-off costs for software updates, to allow them to transfer their 
data to the central national database, are estimated at EUR 229 per company (in 2022 prices)200. These costs 
are  relevant  for  651,351  companies  (470,765  repair  shops  and  garages  and  180,586  motor  vehicle 
dealers)201, excluding those in Belgium and the Netherlands, which implemented the measure already and 
are part of the baseline. Total one-off administrative costs are thus estimated at EUR 149.2 million in 2026. 
In addition, recurrent administrative costs (i.e., for the maintenance of the software and the time spent for 

200 European Parliament (2018), Odometer Manipulation in motor vehicles in Europe, 
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf 
201 Eurostat, Structural business statistics, Enterprise statistics by size class and NACE Rev.2 activity. 

46 

 
  
  
  
  
  
  
  
 
  
  
  
  
 
recording the odometer readings) are estimated at EUR 19.4 million in 2030 and 14.9 million in 2050 
relative to the baseline202. Thus, total one-off and recurrent administrative costs would amount to EUR 460 
million (EUR 706 per company), expressed as present value over 2026-2050. For the purpose of the ‘one 
in one out approach’, the average annual recurrent administrative costs over 2026-2035 are estimated at 
EUR 19.5 million per year203. Considering the 651,351 companies relevant for PMC9, the average annual 
cost per company is estimated at EUR 29.9. In addition, as explained above, the one-off administrative costs 
are estimated at EUR 149.2 million in 2026.  

6.1.2.3.  Vehicle manufacturers  

Administrative costs. In PO2 and PO3, automobile manufacturers will face administrative costs related to 
the setting up of a governance framework for providing access to in-vehicle data necessary to carry out PTI 
and  RSI  to  inspection  centres  and  competent  authorities  (PM11).  According  to  one  manufacturer,  the 
adjustments to their IT systems to ensure access to the relevant data are estimated at EUR 1 million. For the 
20 manufacturers, the total one-off administrative costs are estimated at EUR 20 million in 2026. Recurrent 
administrative costs (i.e., maintenance costs) are estimated at 10% of the capital costs or EUR 100,000 per 
vehicle manufacturer. Total recurrent costs would amount to EUR 2 million per year from 2026 onwards. 
Expressed as present value over 2026-2050, one-off and recurrent administrative costs are estimated at EUR 
55.9 million relative to the baseline (EUR 2.8 million per vehicle manufacturer). No administrative costs 
are expected for vehicle manufacturers in PO1a and PO1b. 

6.1.2.4.  Other businesses (vehicle owners) 

In all policy options, transport operators and various other businesses that own vehicles will face some 
administrative  costs  linked  to  additional  inspections.  In  all  policy  options  they  will  benefit  due  to  the 
reduction in odometer fraud, while in PO1b, PO2 and PO3 they will also enjoy additional cost savings.  

Administrative  costs.  In  PO1a,  the  recurrent  administrative  costs  are  linked  to  one  common  measure 
(PMC5), which requires that vehicles undergo a roadworthiness test following any significant modification 
that could affect safety or the environmental performance of the vehicle. The number of vehicles affected 
by the measure is projected at 0.66 million in 2030 and 0.75 million in 2050 in 20 Member States204, and 
the recurrent costs are estimated at EUR 27.8 million in 2030 and EUR 31.6 million in 2050 relative to the 
baseline205 (see Table 13). Expressed as present value over 2026-2050, total administrative costs for PO1a 
amount to EUR 524.2 million (see Table 12). Some common measures, like those related to the introduction 
of mandatory PN and NOx testing (PMC3 and PMC4), may lead to a higher charge per PTI for vehicle 
owners (businesses and citizens), as PTI centres may pass the additional costs of investment in equipment 
for these tests to their customers. Due to the very diverse organisation of PTI in Member States206, including 
different organisational and contractual setups between the competent authorities and PTI centres (which 
may themselves be run by public authorities or agencies as well as by authorised private companies, large 
or small), it is not possible to estimate the extent of such cost pass-through. Whether or not it will happen 
and when will depend on the specific situation in each Member State, e.g., on the timespan of existing 

202 The recurrent costs are decreasing over time due to the projected uptake of connected vehicles. No manual encoding 
is needed for the connected vehicles. 
203 This is calculated as a simple average over 2026-2035, non-discounted.  
204 Around 0.6% of the vehicle fleet is assumed to undergo significant modifications, based on data for ES and DE. PTI 
following modification is already a requirement in HR, FI, AT, NL, DE, SE and ES, and thus part of the baseline. 60% 
of the cars registrations and 100% of vans, lorries and buses registrations are undertaken by businesses. 
205 The charge per PTI is used to calculate the costs. For businesses, for the categories of vehicles relevant for them, the 
average charge per PTI at EU level is estimated at EUR 42.1 per vehicle. 
206 Cf. Annex 6, section 2 and 3. 

47 

 
 
agreements, service contracts, if they can be renegotiated or not, etc.207. On the other hand, it should be 
noted that the higher costs due to the increased number of inspections (i.e. due to the extended scope) 
are fully passed through to the vehicle owners and reflected in the costs calculations. 

In PO1b, in addition to PMC5, the annual emission testing for light commercial vehicles (PM5), the yearly 
testing of vehicles that are 10-year-old or older (PM6), the additional emission tests for vehicles that are 
found as high emitters during remote sensing or plume chasing and are sent for emission tests in a PTI centre 
(PM12), and the regular inspection of cargo securing (PM13) will lead to recurrent administrative costs for 
businesses. For PM5, affecting all Member States, the additional number of emission testing for internal 
combustion light commercial vehicles is estimated at 14.2 million in 2030 and 1.2 million in 2050 relative 
to the baseline208, and the recurrent costs at EUR 115 million in 2030 and EUR 9.4 million in 2050 (EUR 
1.46 billion expressed as present value over 2026-2050). For PM6, eleven Member States only require an 
inspection every two years for cars and vans after 10 years of their registration209. Thus, the measure is 
expected to result in a doubling of the number of inspections for vehicles over 10 years old in these Member 
States, with costs for businesses (vehicles owners) estimated at EUR 1.24 billion in 2030 and EUR 1.40 
billion in 2050 (EUR 23.3 billion expressed as present value over 2026-2050). For PM12, business that own 
cars, vans and heavy duty vehicles will incur extra costs for emissions testing if the vehicles are identified 
as high emitters via the use of remote sensing or plume chasing and are sent for PTI due to the 0.5% limit 
in the capacity for roadside inspections. The recurrent administrative costs are estimated at EUR 14 million 
in 2030 and EUR 1.2 million in 2050 (EUR 175 million expressed as present value over 2026-2050)210. For 
PM13211, the extra costs for the additional time for cooperating on the cargo securing inspections would 
amount to EUR 0.44 million in 2030 and EUR 0.55 million in 2050212 (EUR 8.5 million expressed as 
present  value  over  2026-2050).  Thus,  total  administrative  costs  for  PO1b  are  estimated  at  EUR  25.46 
billion, expressed as present value over 2026-2050. Costs related to PM6 would represent 92% of the total 
costs of PO1b.  

PO2  includes  the  same  costs  as  in  PO1b,  and  additional  recurrent  administrative  costs  related  to  the 
extension of the scope of application of roadside inspections to light commercial vehicles (PM14). The extra 
costs for the additional time for cooperating on roadside inspections in PM14213 would amount to EUR 10.9 
million in 2030 and EUR 12.9 million in 2050214 (EUR 208 million, expressed as present value over 2026-
2050). Total recurrent administrative costs for PO2 are therefore estimated at EUR 25.67 billion, expressed 
as present value over 2026-2050 relative to the baseline. The largest share of the costs in PO2 would be due 
to PM6 (91% of the costs). 

PO3 includes the same costs as in PO2, and in addition it reflects costs related to the mandatory PTI for 
light trailers (PM4). Businesses (vehicle owners) would be affected by PM4 when introduced in eleven 

207 For example, in Ireland, the changes introduced by the 2014 RWP have not resulted in any increase in PTI charges. Any price 
increase would require government decision based on a detailed business case. However, the PTI operator can still claim indexation 
through the reduction of a levy that it pays to the competent authority after each test, while keeping the charge per PTI unchanged.  
208 The decrease in the number of emission testing is driven by the decrease in the number of internal combustion light 
commercial vehicles over time. This is due to the Regulation on CO2 standards for LDVs that is included in the baseline. 
209 CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT and SK. 
210 The cost of an emission test is estimated at 20% of the PTI charge per vehicle. Around 60% of cars and 100% of vans 
and heavy duty vehicles are owned by businesses. 
211 Owners of heavy-duty vehicles would be affected by the measure to be introduced by 5 MS (EE, FR, IE, LV and LU).  
212 They are calculated considering an average hourly labour cost of EUR 21.9 for drivers (ISCO 8 - Plant and machine 
operators  and  assemblers),  the  average  time  per  inspection  of  20  minutes,  and  the  additional  number  of  roadside 
inspections (44,813 in 2030 and 55,526 in 2050). 
213 22 MS will be affected by the measure (except ES, HU, SE, SK and FI, that already conduct such inspections).  
214 They are calculated considering an average hourly labour cost of EUR 21.9 for drivers (ISCO 8 - Plant and machine 
operators  and  assemblers),  the  average  time  per  inspection  of  20  minutes,  and  the  additional  number  of  roadside 
inspections (497,627 in 2030 and 588,721 in 2050). 

48 

 
 
Member States215, with recurrent administrative costs estimated at EUR 20.4 million in 2030 and EUR 23.1 
million in 2050 (EUR 385.1 million, expressed as present value over the 2026-2050 period). Total recurrent 
administrative costs for PO3 are thus estimated at EUR 26.05 billion, expressed as present value over 2026-
2050. Costs related to PM6 represent 89% of the total costs of PO3 and PM5 6% of the costs. 

Administrative costs savings. Administrative costs savings are expected to arise in PO1b, PO2 and PO3 
from the possibility to avoid emission testing at PTI in case the vehicle passed a roadside inspection or was 
found to be in line with the applicable emission limits during a screening by remote sensing (PM12). The 
number of PTI tests avoided by businesses due to PM12 is estimated at 11.9 million in 2030 and EUR 1 
million in 2050216. The savings (see Table 12 and Table 13) would amount to EUR 102.6 million in 2030 
and EUR 10.1 million in 2050 (EUR 1.29 billion expressed as present value over 2026-2050).  

Benefits due to avoided odometer fraud. In all policy options, the requirement for mandatory recording and 
reporting  to  a  national  central  database  of  vehicle  mileage,  whenever  a  vehicle  undergoes  repair/ 
maintenance  or  in  the  case  of  tyre  changes/replacement  (PMC9)217  offers  very  significant  benefits  to 
businesses in relation to the reduction of odometer fraud, which currently affects around 4.8% of vehicles 
in national second-hand sales and 11.3% in cross-border sales. The benefits to businesses due to the avoided 
odometer  fraud reduction  are  estimated  at  EUR  6.35 billion in  2030  and EUR  6.99 billion  in  2050218. 
Expressed  as  present value  over  2026-2050 the benefits  amount to  EUR  118.34  billion, relative to the 
baseline. It should however be acknowledged that there is uncertainty regarding the  economic damage 
caused by odometer fraud and the number of cars affected. For this reason, sensitivity analysis has been 
performed and is reported in section 7.5 and Annex 4 (section 7). 

Net benefits/costs for businesses (vehicle owners). All policy options are expected to result in significant 
net benefits for businesses (vehicle owners), mainly due to the avoided odometer fraud. The highest net 
benefits are estimated for PO1a (EUR 117.82 billion), followed by PO1b (EUR 94.17 billion), PO2 (EUR 
93.96 billion) and PO3 (EUR 93.58 billion) (see Table 12).  

Table 12: Recurrent costs, costs savings and benefits for other businesses (vehicle owners) in the policy options, 
expressed as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices) 

PO1a 

PO1b 

PO2 

PO3 

Difference to the baseline 

Administrative costs 

PMC5 
PM4 
PM5 
PM6 
PM12 
PM13 
PM14 

Administrative costs 
savings 
PM12 

524.2 
524.2 

0.0 

25,458.4 
524.2 

1,454.8 
23,295.9 

175.0 
8.5 

1,287.3 

1,287.3 

25,666.4 
524.2 

1,454.8 
23,295.9 

175.0 
8.5 
208.0 
1,287.3 

1,287.3 

26,051.5 
524.2 
385.1 
1,454.8 
23,295.9 

175.0 
8.5 
208.0 
1,287.3 

1,287.3 

215 7 Member States where there is currently no requirement for PTI for either O1 or O2 (DK, EL, FI, FR, NL, IE, PT) 
and 4 Member States where there is currently only a requirement for PTI for O2 (PL, SK, BE and ES). 
216 The reason for the decreasing number of PTI tests avoided over time is the increasing share of zero-emission vehicles 
in the baseline scenario. 
217 PMC9 is relevant for all Member States, except Belgium and the Netherlands that have already introduced such requirement. 
218 The average cost of mileage fraud, due to higher purchase price and maintenance costs incurred, is estimated at EUR 
(https://www.car-
2,119 
pass.be/files/article_files/file/7/crm%2520study%2520final%2520report.pdf). More explanations are provided in section 
2 of Annex 4. 

a  Belgian  Car-Pass 

drawing 

vehicle 

prices 

study 

2022 

per 

on 

in 

49 

 
  
  
  
  
  
  
 
  
  
  
  
 
Benefits 
PMC9 
Net benefits 

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 

118,340.5 
118,340.5 

117,816.3 

118,340.5 
118,340.5 

94,169.4 

118,340.5 
118,340.5 

93,961.3 

118,340.5 
118,340.5 

93,576.3 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 13: Recurrent costs, costs savings and benefits for other businesses (vehicle owners) in the policy options, in 
2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices) 
Difference to the baseline 

PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

27.0 

27.8 

31.6 

1,362 

1,394 

1,443 

1,372 

1,405 

1,456 

1,392 

1,425 

1,479 

27.0 

27.8 

31.6 

27.0 

27.8 

31.6 

27.0 

27.8 

31.6 

115.8 

1,204 

14.8 

0.4 

115.0 

1,237 

14.0 

0.4 

9.4 

1,400 

1.2 

0.5 

115.8 

1,204 

14.8 

0.4 

10.5 

115.0 

1,237 

14.0 

0.4 

10.9 

0.0 

0.0 

0.0 

109.4 

102.6 

10.1 

109.4 

102.6 

6,043 
6,043 

6,016 

6,353 
6,353 

6,325 

6,991 
6,991 

6,959 

109.4 

6,043 
6,043 

4,791 

102.6 

6,353 
6,353 

5,062 

10.1 

6,991 
6,991 

5,558 

109.4 

6,043 
6,043 

4,780 

102.6 

6,353 
6,353 

5,051 

9.4 

1,400 

1.2 

0.5 

12.9 

10.1 

10.1 

6,991 
6,991 

5,545 

27.0 

19.3 

115.8 

1,204 

14.8 

0.4 

10.5 

27.8 

20.4 

115.0 

1,237 

14.0 

0.4 

10.9 

109.4 

102.6 

109.4 

6,043 
6,043 

4,761 

102.6 

6,353 
6,353 

5,030 

31.6 

23.1 

9.4 

1,400 

1.2 

0.5 

12.9 

10.1 

10.1 

6,991 
6,991 

5,522 

Administrative 
costs 

PMC5 

PM4 

PM5 

PM6 

PM12 

PM13 

PM14 

Administrative 
costs savings 
PM12 

Benefits 
PMC9 

Net benefits 

Source: Ricardo et al. (2024), Impact assessment support study 

6.1.3.  Impacts on citizens (vehicle owners) 

Vehicle  owners  can  be  businesses  or  citizens.  This  section  discusses  only  impacts  on  citizens219.  The 
impacts on businesses as vehicle owners are discussed in section 6.1.2.4. In all policy options citizens are 
expected to be faced with administrative costs, but also with adjustment costs savings and benefits due to 
avoided odometer fraud. In addition, PO1b, PO2 and PO3 would result in administrative costs savings (see 
Table 14 and Table 15).   

Administrative costs for citizens. In PO1a, the recurrent administrative costs for citizens are linked to one 
common measure which extends the PTI to cover vehicles with significant modifications (PMC5), and to 
the introduction of roadside inspections for motorcycles over 125cm3 as an alternative to PTI (PM1). For 
PMC5, the number of vehicles affected is estimated at 0.45 million in 2030 and 0.53 million in 2050 in 20 
Member States220, and the recurrent administrative costs (based on the number of vehicles affected and the 
cost per PTI) at EUR 17.7 million in 2030 and EUR 20.6 million in 2050 (EUR 336.3 million, expressed 
as present value over 2026-2050). For PM1, the extra costs for the time spent for cooperating on roadside 
inspections with the public authorities are estimated at EUR 0.4 million in 2030 and EUR 0.5 million in 

219 Around 40% of cars are owned by citizens (see e.g., https://www.transportenvironment.org/challenges/cars/company-
cars/  and  https://cleantechnica.com/2022/12/08/european-company-car-market-goes-green/).  For  motorcycles,  it  is 
assumed that 100% are owned by citizens, in lack of more detailed information.  
220 Around 0.6% of the vehicle fleet is assumed to undergo significant modifications, based on data for ES and DE. PTI 
following modification is already a requirement in HR, FI, AT, NL, DE, SE and ES, and thus part of the baseline.   

50 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
 
2050221 (EUR 7.9 million, expressed as present value over 2026-2050). Total administrative costs in PO1a 
are thus estimated at EUR 344.2 million, expressed as present value over 2026-2050. As explained in 
section 6.1.2.4, some common measures, like those related to the introduction of mandatory PN and NOx 
testing  (PMC3  and  PMC4),  may  lead  to  a  higher  charge  per  PTI  for  vehicle  owners  (businesses  and 
citizens), as PTI centres may pass the additional costs of investment in equipment for these tests to their 
customers. However, as explained in section 6.1.2.4, it is not possible to estimate the extent of such cost 
pass-through. On the other hand, it should be noted that the higher costs due to the increased number of 
inspections (i.e. due to the extended scope) are fully passed through to the vehicle owners and reflected in 
the costs calculations.  

In the case of PO1b, in addition to the costs of the common measure (PMC5), there will be some additional 
administrative costs for the owners of motorcycles in a few Member States222 as a result of the mandatory 
PTI for motorcycles above 125cm3 (PM2), as well as additional costs due to the mandatory yearly testing 
of vehicles older than 10 years (PM6) and due to the additional emission tests for vehicles that are found as 
high emitters during remote sensing and are sent for emission tests in a PTI centre (PM12). The related 
administrative costs for citizens due to PM2 are estimated at EUR 15.1 million in 2030 and EUR 19 million 
in 2050 (EUR 294.1 million, expressed as present value over 2026-2050). PM6 generates administrative 
costs  estimated  at  EUR  703.4  million  in  2030  and  EUR  792.3  million  in  2050223  (EUR  13.24  billion 
expressed as present value over 2026-2050). For PM12, citizens that own cars will incur extra costs for 
emissions testing if the vehicles are identified as high emitters via the use of remote sensing and are sent for 
PTI due to the 0.5% limit in the capacity for roadside inspections. The recurrent administrative costs are 
estimated at EUR 5.8 million in 2030 and EUR 0.3 million in 2050 (EUR 72.2 million expressed as present 
value over 2026-2050)224. Thus, total administrative costs for citizens under PO1b for the period 2026-2050 
are estimated at EUR 13.94 billion relative to the baseline.  

In PO2, the recurrent administrative costs for citizens  are driven by  the costs of the common measure 
(PMC5), the introduction of roadside inspections for motorcycles over 125cm3 as an alternative to PTI 
(PM1), the mandatory yearly testing of vehicles older than 10 years (PM6) and the additional emission tests 
for vehicles that are found as high emitters during remote sensing and are sent for emission tests in a PTI 
centre (PM12). The total administrative costs for citizens under PO2 for the period 2026-2050 are estimated 
at EUR 13.66 billion relative to the baseline. 

The highest impact on administrative costs for citizens is expected in PO3, where additional costs relative 
to PO2 are due to mandatory extension of PTI to all motorcycles (PM3), mandatory PTI for light trailers 
(PM4), and the extension of the scope of application of roadside inspections to 2- and 3-wheeled vehicles 
(PM15). PM6 generates by far the highest administrative costs in PO3, estimated at EUR 703.4 million in 
2030 and EUR 792.3 million in 2050 (EUR 13.24 billion expressed as present value over 2026-2050). For 
PM3, the recurrent administrative costs are estimated at EUR 17.5 million in 2030 and EUR 22.1 million 
in 2050225 (EUR 341.3 million over the period 2026-2050), while in PM4 at EUR 7.6 million in 2030 and 
EUR 8.4 million in 2050 (EUR 141.5 million, expressed as present value over 2026-2050). Finally, the 
extension of the scope of application of roadside inspections to 2- and 3-wheeled vehicles is expected to 

221 The additional number of roadside inspections is estimated at 82,566 in 2030 and 104,321 in 2050 in the MS affected 
(BE, FI, IE, NL, MT and PT). The average time required for a roadside inspection is estimated at 10 minutes and the 
average hourly labour cost at EUR 29.5. 
222 BE, FI, IE, NL, MT, PT and DK. 
223 11 MS (CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT and SK) only require an inspection every two years for cars and 
vans after 10 years of their registration. Thus, the measure is expected to result in a doubling of the number of inspections 
for vehicles over 10 years old in these Member States. More details are provided in Annex 4 (section 3). 
224 The cost of an emission test is estimated at 20% of the PTI charge per vehicle.  
225 The additional number of inspections in the 8 MS affected (BE, FI, IE, NL, MT, PT, DK, CY) is estimated at 869,017 
in 2030 and 1,097,479 in 2050. In Cyprus motorcycles above 125cm3 are already covered. 

51 

 
 
result in some costs due to the time spent for cooperating on inspections, estimated at EUR 0.9 million in 
2030 and EUR 1.1 million in 2050 (EUR 16.9 million for the period 2026-2050). The total administrative 
costs for citizens due to PO3 would amount to EUR 14.15 billion, expressed as present value over 2026-
2050 relative to the baseline (see Table 14). 

Other costs for citizens. The measures aimed at increasing the effectiveness of the PTI and RSI, along with 
new  testing  requirements  regarding  safety,  air  pollutant  emissions  and  noise,  will  lead  to  an  increased 
number of vehicle owners experiencing repair costs to ensure that their vehicles can pass the PTI inspection 
and remain in use. This may mean costs to replace breaks, axles, suspensions systems, lamps, or other 
defective components, such as a defective emission control system. It is difficult to estimate these costs as 
this may vary significantly in each case and for each vehicle type. Such costs are also expected to be higher 
as vehicles get older. Due to the number of uncertainties, it was not possible to develop an estimate of such 
costs. It should however be noted that these costs are not considered regulatory costs linked to this initiative.   

Adjustment costs savings for citizens. Adjustment cost savings for citizens are expected to come from the 
measures related to the recognition of PTI certificates in other Member States, as a result of avoided travel 
costs back to the country of vehicle registration for a PTI. The highest costs savings are expected in PO3, 
which  includes  the  obligation  for  PTI  certificate  issued  in  any  Member  State  to  be  recognised  by  the 
Member State of registration (PM7). They are estimated at EUR 228.2 million in 2030 and EUR 254.8 
million in 2050, relative to the baseline. Expressed as present value over 2026-2050, the cost savings for 
PO3 amount to EUR 4.29 billion relative to the baseline. In PO1b and PO2 the cost savings are driven by 
the recognition of the PTI certificate issued by a Member State other than Member State of registration of 
up to six months (PM8) and are estimated at EUR 114.1 million in 2030 and EUR 127.4 million in 2050. 
Expressed as present value over 2026-2050, they are estimated at EUR 2.14 billion relative to the baseline. 
PO1a  shows  the  lowest  costs  savings  for  citizens  (vehicle  owners)  among  the  options,  linked  to  the 
recognition of PTI certificates on the basis of bilateral agreements (PM9). The savings are estimated at EUR 
49 million in 2030 and in 2050 (EUR 878.2 million relative to the baseline, expressed as present value over 
2026-2050). 

Administrative  costs  savings  for  citizens.  Under  PO1b,  PO2  and  PO3,  citizens  will  benefit  from 
administrative cost savings related to the option for Member States not to require emission testing at PTI 
after the vehicle has successfully passed a screening by remote sensing (PM12), i.e., it has been found to 
emit below the emission limits applicable to it. The corresponding savings amount to EUR 48.8 million in 
2030 and are expected to drop to around EUR 2.8 million by 2050 (EUR 591.9 million expressed as present 
value over the 2026-2050 period). No administrative costs savings are expected in PO1a. 

Benefits due to avoided odometer fraud. In all policy options, the obligation for Member States to record 
odometer readings in a national database, as well as to make them available to other Member States in the 
case of a re-registration of a vehicle (PMC9), is expected to help reduce odometer fraud in the Member 
States where such a system is not currently in place226 (i.e., both in domestic sales of used vehicles and in 
cross-border sales, where odometer tampering has been found to be more common). The corresponding 
benefits for citizens are estimated at EUR 3.55 billion in 2030 and EUR 3.86 billion in 2050. Expressed as 
present value over 2026-2050, they are estimated at around EUR 65.67 billion relative to the baseline. As 
explained in section 6.1.2.4, it should be acknowledged that there is uncertainty regarding the economic 
damage caused by odometer fraud and the number of cars affected. For this reason, sensitivity analysis has 
been performed and is reported in section 7.5 and Annex 4 (section 7). 

Net  benefits  for  citizens.  All  policy  options  are  expected  to  result  in  net  benefits  for  citizens  (vehicle 
owners).  Expressed  as  present  value  over  2026-2050  relative  to  the  baseline  (see  Table  14),  they  are 

226 Only BE and NL have introduced such requirement.  

52 

 
 
estimated to be the highest in PO1a (EUR 66.20 billion), followed by PO3 (EUR 56.40 billion), PO2 (EUR 
54.75 billion) and PO1b (EUR 54.46 million).   

Table 14: Recurrent costs, costs savings and benefits for citizens (vehicle owners) in the policy options, expressed 
as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices) 

PO1a 

PO1b 

PO2 

PO3 

Difference to the baseline 

344.2 

336.3 
7.9 

Adjustment costs 

PMC5 
PM1 
PM2 
PM3 
PM4 
PM6 
PM12 
PM15 

Adjustment costs savings 

878.2 

PM7 
PM8 
PM9 

Administrative costs savings 

PM12 
Benefits 
PMC9 
Net benefits 

878.2 
0.0 

65,666.9 
65,666.9 
66,200.9 

13,944.3 

336.3 

294.1 

13,241.7 
72.2 

2,144.6 

2,144.6 

591.9 

591.9 
65,666.9 
65,666.9 
54,459.0 

13,658.1 

336.3 
7.9 

13,241.7 
72.2 

2,144.6 

2,144.6 

591.9 

591.9 
65,666.9 
65,666.9 
54,745.2 

14,150.0 

336.3 

341.3 
141.5 
13,241.7 
72.2 
16.9 
4,289.3 
4,289.3 

591.9 

591.9 
65,666.9 
65,666.9 
56,398.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 15: Recurrent costs, costs savings and benefits for citizens (vehicle owners) in the policy options, in 2026, 
2030 and 2050, relative to the baseline, in million EUR (2022 prices) 

Difference to the baseline 

PO1a 

2030 

2026 

PO1b 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

17.5 

18.1 

21.1 

724.9 

742.0 

832.3 

710.6 

727.3 

813.8 

735.3 

752.8 

844.9 

17.1 

0.4 

17.7 

0.4 

20.6 

0.5 

17.1 

17.7 

20.6 

17.1 

0.4 

17.7 

0.4 

20.6 

0.5 

17.1 

17.7 

20.6 

14.8 

15.1 

19.0 

17.0 

7.3 

17.5 

7.6 

22.1 

8.4 

686.5 

703.4 

792.3 

686.5 

703.4 

792.3 

686.5 

703.4 

792.3 

6.5 

5.8 

0.3 

6.5 

5.8 

0.3 

6.5 

0.8 

5.8 

0.9 

0.3 

1.1 

49.0 

49.0 

49.0 

110.7 

114.1 

127.4 

110.7 

114.1 

127.4 

221.5 

228.2 

254.8 

110.7 

114.1 

127.4 

110.7 

114.1 

127.4 

221.5 

228.2 

254.8 

49.0 

0.0 

49.0 

0.0 

49.0 

0.0 

3,381 

3,381 

3,412 

3,554 

3,554 

3,585 

3,857 

3,857 

3,885 

53.4 

48.8 

53.4 

3,381 

3,381 

2,820 

48.8 

3,554 

3,554 

2,975 

2.8 

2.8 

3,857 

3,857 

3,155 

53.4 

48.8 

53.4 

3,381 

3,381 

2,834 

48.8 

3,554 

3,554 

2,990 

2.8 

2.8 

3,857 

3,857 

3,173 

53.4 

48.8 

53.4 

3,381 

3,381 

2,920 

48.8 

3,554 

3,554 

3,078 

2.8 

2.8 

3,857 

3,857 

3,269 

Administrative 
costs 

PMC5 

PM1 

PM2 

PM3 

PM4 

PM6 

PM12 

PM15 

Adjustment 
costs savings 

PM7 

PM8 

PM9 

Administrative 
costs savings 
PM12 

Benefits 

PMC9 

Net benefits 

Source: Ricardo et al. (2024), Impact assessment support study 

53 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
6.1.4.  Impacts on competitiveness 

The stakeholders that participated in the survey were requested to assess the impact of each measure on the 
cost and price competitiveness of sectors affected, with a score of 1 representing a very negative impact and 
a score of 7 representing a very positive impact. According to the consulted stakeholders, a somewhat 
positive  impact  on  the  cost  and  price  competitiveness  of  affected  sectors  would  be  expected  from  the 
introduction of new PTI/RSI test requirements (average 3.89). A similarly positive impact on the cost and 
price competitiveness of sectors affected is expected by the stakeholders that participated in the survey from 
measures widening the scope of vehicles to be tested, and increased frequency of testing for certain vehicle 
categories.  Finally,  recognising  PTIs  conducted  in  Member  States  other  than  the  Member  State  of 
registration would be expected by the stakeholders to achieve almost no impact (average 3.12). 

As  explained  in  section  6.1.2.1,  the  biggest  share  of  the  additional  adjustment  costs  for  PTI  centres 
compared to the baseline is related to measures requiring the upgrade of equipment and facilities (PMC3 
and PMC4), included in all policy options, the annual emission testing for light commercial vehicles (PM5), 
the mandatory yearly testing of vehicles that are 10-year-old or older (PM6) and the requirement for more 
advanced emission and noise testing (PM10) in PO1b, PO2 and PO3, and the required investment in new 
equipment, including an advanced brake testing device and a suspension tester (PM7) under PO3. To a 
lesser extent, the extension of the scope of the vehicles covered (PM3 and PM4) also leads to additional 
adjustment costs under PO3. All policy options, and in particular PO1b, PO2 and PO3 will also result in 
greater revenue sources for testing centres, thanks to more vehicles having to undergo PTI. Overall, as 
explained in section 6.1.2.1, PO2 results in net benefits of EUR 353 thousand per PTI centre expressed as 
present value over 2026-2050 relative to the baseline, followed by PO3 with EUR 336 thousand and PO1b 
with net benefits of EUR 325 thousand per PTI centre, while PO1a results in net costs of around EUR 59 
thousand per PTI centre. Net benefits in PO2 represent around 6.3% of the turnover per PTI centre, in PO3 
around 6% of the turnover, in PO1b around 5.8% of the turnover per PTI centre, while the net costs in PO1a 
around 1.1% of the turnover. Even though the analysis shows that PO1a may result in net direct costs for 
PTI centres, these costs may be passed through to vehicle owners (citizens and businesses) through higher 
PTI charges or compensated by the competent public authorities (see discussion on cost pass-through under 
administrative costs for other businesses - section 6.1.2.4, and for citizens - section 6.1.3). It can thus be 
concluded that PO1a is not expected to have a significant negative impact, while PO1b, PO2 and PO3 are 
expected to have very positive impact on the competitiveness of PTI operators.  

Garages and other repair workshops will be affected by the requirement to record odometer readings of 
every  vehicle  they  service  (PMC9).  As  described  in  section  6.1.2.2,  total  one-off  and  recurrent 
administrative costs would amount to EUR 706 per company, expressed as present value over 2026-2050, 
which is not expected to have any significant impact on their competitiveness. Some of them, as well as 
vehicle  manufacturers  and  dealers  already  record  odometer  readings  for  the  purpose  of  keeping  a 
maintenance schedule.  

Other businesses (vehicle owners) may face somewhat higher costs as a result of the additional PTI costs 
and more frequent roadside inspections in all policy options (in particular in PO1b, PO2 and PO3), but the 
estimated extra costs in the case of HGVs are limited; they are more significant for passenger cars. At the 
same time, a more effective enforcement of the roadworthiness framework will ensure fair competition, 
reducing  the  opportunities  for  gaining  price  advantage  on  the  basis  of  lower  vehicle  standards,  and 
avoidance of the required maintenance costs of vehicles. 

6.1.5.  Impacts on innovation and technological development 

Positive impacts on innovation are expected from requiring more stringent and advanced test methods that 
also need to be adjusted to the general requirement for a PTI to be quick, simple and affordable. Although 

54 

 
new tests, such as PN- and NOx-measurement, ePTI or advanced brake and noise tests are based on existing 
technologies,  there  is  still  a  certain  degree  of  development  and  adaptation  necessary  to  ensure  their 
widespread application. The consulted stakeholders expect a positive impact on the innovative capacity of 
the sectors affected from measures related to new PTI/RSI test requirements, improved access and exchange 
of information and the digitalisation of vehicle documents. Furthermore, increased demand for new test 
methods  and  equipment  can  be  expected  to  generate  further  development  of  relevant  technologies  by 
developers of measurement equipment, a viewpoint supported by the representatives of the sector in their 
contribution to the stakeholder consultation. Together with that, relevant training of inspectors to the new 
test methods will enhance the availability of technical skills and expertise that can have a broader positive 
impact. As such, most of the common measures are expected to have some positive impact on innovation 
(PMC1 on the testing of electric vehicles, PMC2 using ePTI, PMC3 and PMC4 on new emission tests, 
PMC6 on digital PTI certificates, and PMC7 on more efficient exchange of vehicle data). 

While in the case of PO1a the digitalisation of the registration certificates  (PM16) may require further 
innovation, PO1b would introduce remote sensing and plume chasing (PM12) to monitor air pollutants and 
noise emitted by vehicles. Remote sensing also relies on existing technologies but requires adaptations to 
scale them up to cover the desired share of the vehicle fleet. Deploying these technologies at a larger scale 
than today would also necessitate process innovation. PO2 and PO3 combine the benefits of both measures. 

6.1.6.  Impacts on small and medium enterprises (SMEs) 

Periodic  technical  inspections  are  in  many  Member  States  performed  by  smaller  independent  garages. 
Moreover,  roadside  inspections  under  the  RSI  Directive  have  been  specifically  targeted  at  commercial 
vehicle fleets, which are predominantly operated by SMEs. Garages, motor vehicle dealers, tyre and repair 
workshops, etc., almost entirely SMEs, will be affected by the requirement for Member States to set up a 
system  to  record  odometer  readings  from  the  cars  and  vans  registered  in  their  territory.  Therefore,  the 
initiative is considered relevant for SMEs, and the SME test has been performed. More detailed explanations 
on the impacts on SMEs and SME test (including the four SME steps) are provided in Annex 10. 

As explained in section 2.2.3, various forms of tampering affect the safety and environmental performance 
of vehicles. Next to odometer fraud, tampering may relate to disconnecting or altering the emission and 
noise reduction systems or modifying the performance of the vehicle. As regards possible impacts on the 
SME  tuning  sector,  this  initiative  is  not  intended  to  cover  legitimate  tuning  that  is  authorised  and 
documented/registered by the competent authorities. It only refers to illegal activity where modifications 
are not authorised and documented/registered by the competent authorities. The possible impacts on the 
SME tuning sector have thus not been considered. 

6.1.7.  Impact on the functioning of the internal market and competition 

The existing divergence between vehicle registration documents and the information included and quality 
of the data stored in the vehicle registers creates challenges in coordinating enforcement actions by Member 
States. Furthermore, the non-recognition of roadworthiness certificates among EU Member State creates 
additional trade barriers for cross-border operation or sale of vehicles, hindering the efficient functioning of 
the internal market, business operations and the freedom of movement of people within the EU. All policy 
options are expected to have a positive impact on the functioning of the internal market. 

The combination of the measures related to improving the  availability and exchange of vehicle-related 
information, making the roadworthiness certificate available in electronic format, the specific measure on 
odometer fraud, harmonising testing methods, the frequency of testing, requirements for the improvement 
of the PTI and the scope of testing, can have a positive impact on the functioning of the internal market and 
on competition. Qualitative assessment shows that PO2 and especially PO3 are expected to have the highest 
positive impact on the internal market and competition. PO2 incorporates additional measures aimed at 

55 

 
extending roadside inspections to light commercial vehicles, and facilitating access to vehicle data necessary 
for thorough testing by PTI centres. This comprehensive approach is expected to have a stronger impact 
than PO1a  and PO1b  due. PO3 has  a  stronger positive  impact  due  to PM7,  which  requires that  a PTI 
certificate issued in any Member State is recognised by the Member State of registration, as well as further 
harmonisation of test methods. In addition, PO3 introduces mandatory PTI for all motorcycles and light 
trailers, which are not currently tested by all Member States. The inclusion of L-category vehicles in the 
scope of RSI (PM15) is expected to reduce the number of tampered vehicles. PO3 applies more ambitious 
measures regarding the standardisation of tests methods than provisions already included in the other policy 
options. As such, PO3 is expected to deliver the most significant positive impact on the internal market and 
competition. A more detailed discussion is presented in Annex 13. 

6.1.8.  Territorial impacts 

There is no inherent bias (positive or negative) of the proposed options towards specific regions or territories 
of the European Union, and no specific differences among the different policy options. The underlying 
measures are expected to be applied in a more harmonised way in terms of the test procedures to be followed 
in comparison to the baseline scenario. There may be a limited number of specific issues that arise for 
authorities  and  vehicles  owners  in  different  regions  of  the  European  Union.  These  may  relate  to  the 
implications of different climatic conditions when performing relevant tests (e.g., warm engine NOx test in 
Nordic countries) or the long distances needed to reach a PTI centre, and the extra costs that would arise for 
citizens and businesses in less dense and/or remote regions from widening the scope of vehicles subject to 
PTI  and/or  increasing  the  frequency  of  testing.  Furthermore,  there  are  different  profiles  of  level  of 
ownership, frequency of use, and size of motorcycles across the EU (e.g., motorcycles in most Southern 
European countries are smaller and are used more often for daily commute, in comparison to Northern 
European countries where motorcycles are more often used for leisure). In that respect, PO3 (including an 
extended scope to motorcycles of more than 50cc) could have a greater impact. However, PTI for smaller 
size motorcycles is already mandatory in some Southern European countries including in Italy, Spain, and 
Greece. It would be left open to Member States – in the implementation of the specific measures – to adapt 
the testing procedures to reflect the specific climatic conditions or to support the operation of mobile PTI 
units to minimise the time and cost for citizens in remote areas. 

6.1.9.  Digital by default 

All policy options will have a positive impact on the application of the ‘digital by default’ principle. The 
mandatory  electronic  format  of  roadworthiness  certificates  (PMC6)  should  have  a  positive  impact  on 
administrative costs for authorities and contribute to digital transformation in the EU. PMC7 will, for the 
process of re-registration, save time and costs for authorities and citizens by moving away from information 
and data exchange via e-mail etc. which is less efficient in accessing relevant vehicle data. The impact would 
be even higher in PO1a, PO2 and PO3 relative to PO1b, as those options also include the issuing of vehicle 
registration certificates in electronic format (PM16), combined with an extension of the information to be 
included in the certificates (PM17). A digital registration certificate should help reduce time and costs by 
making  access  and  exchange  of  the  relevant  information  easier,  faster.  The  introduction  of  digital 
registration  certificates  will be  a  further  step towards the  alignment of the RWP  legal  framework with 
Regulation (EU) 2018/1724 on the Single Digital Gateway, which requires that Member States ensure that 
vehicle registration procedures are delivered in a fully digital way when a citizen moves from one Member 
State to another. In all cases the expectation is that while roadworthiness and registration certificates will be 
issued in electronic format, there will still be a possibility for vehicle owners to obtain (or print) the relevant 
documents with the introduction of a QR code. This should help to minimise accessibility issues arising for 
specific parts of the population. 

56 

 
6.1.10. Reporting obligations 

In should be noted that the current reporting requirements under the three Directives is minimal. Therefore, 
there is no scope for further reducing the reporting requirements. 

6.2. 

Social impacts 

6.2.1.  Impacts on road safety 

Given that the general objective of the initiative is to improve road safety in the EU, several measures to 
achieve this objective were included in the policy options. Direct impact on road safety is expected due to 
the more effective identification of vehicles with major and dangerous defects in the fleet, which should 
lead to the reduction of road crashes caused by technical defects and, as a result, to reduced fatalities and 
injuries (serious and light). Policy options also include other measures contributing to road safety, which 
relate to better implementation and enforcement of the roadworthiness legislation (such as the exchange of 
data among Member States’ authorities).  

Several assumptions were used to establish the impacts on road safety. They are explained in detail, by 
policy  measure,  in  Annex  4  (section  4.1).  These  inputs227  were  subsequently  used  in  the  PRIMES-
TREMOVE model to derive the impacts on the number of lives saved and injuries avoided. The impacts 
on road safety assessed are only linked to the measures considered in this impact assessment. More detailed 
explanations on the impacts by policy option and policy measure are provided in Annex 4 (section 5.1).  

It should be noted that an important element in this assessment relates to the contribution of vehicle technical 
defects  to  road  crashes228.  For  this  assessment,  a  conservative  approach  was  taken  assuming  a  4% 
contribution of technical defects to road crashes in the case of light-duty vehicles, heavy-duty vehicles and 
trailers and 6% in the case of motorcycles. Considering the uncertainty,  a sensitivity analysis has been 
performed and is included in section 7.5 and Annex 4 (section 7). 

All policy options are expected to result in lives saved and injuries avoided relative to the baseline scenario. 
Table 16 provides the reduction in the number of fatalities and injuries relative to the baseline in 2030 and 
2050, as well as the cumulative number of lives saved, and injuries avoided relative to the baseline over the 
2026-2050 horizon. Cumulatively, over the period 2026-2050, PO3 is expected to  result in 7,013 lives 
saved, followed by PO2 (6,912 lives saved), PO1b (6,847 lives saved) and PO1a (4,661 lives saved). The 
numbers of severe and slight injuries avoided follow a similar pattern with PO3 having the highest impact, 
followed by PO2, PO1b, and PO1a. More explanations on the impacts by policy option and policy measure 
are provided in Annex 4 (section 5.1). 

Table 16: Expected reduction in the number of fatalities and injuries in the POs relative to the baseline, in 2030 
and 2050, and cumulative reduction over the period 2026-2050 

PO1a 

PO1b 

2030 
2050 
Cumulative over 2026-2050 
% reduction 
2030 
2050 
Cumulative over 2026-2050 

Fatalities  
195 
173 
4,661  
1.1% 
287 
253 
6,847  

Serious injuries 
1,768  
1,587  
42,272  
1.2% 
2,711  
2,420  
64,640  

Slight injuries 
9,929  
9,011  
239,803  
1.3% 
15,099  
13,658  
364,155  

227 See more details in Annex 4 (section 4.1) on the inputs by measure and their aggregation into policy options.  
228 As explained in section 2.1.1, various studies indicate that their share as a contributing factor of the cause of crashes 
is between 3 and 19%, depending on the scope and methodology of the study; for motorcycles, it is 5% to 12% of crashes. 

57 

 
  
  
  
  
  
  
  
 
PO2 

PO3 

% reduction 
2030 
2050 
Cumulative over 2026-2050 
% reduction 
2030 
2050 
Cumulative over 2026-2050 
% reduction 

Fatalities  
1.6% 
289 
255 
6,912  
1.6% 
293 
259 
7,013  
1.6% 

Serious injuries 
1.8% 
2,721  
2,429  
64,885  
1.8% 
2,753  
2,460  
65,686  
1.8% 

Slight injuries 
1.9% 
15,162  
13,712  
365,665  
1.9% 
15,274  
13,826  
368,498  
2.0% 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 17 provides the reduction in the external costs of accidents relative to the baseline, expressed as 
present value over the 2026-2050 period. The 2019 Handbook on the external costs of transport229 was used 
to monetise the costs230. As a result of the positive impacts on lives saved and injuries avoided presented 
above, PO3 shows the highest impact in terms of reduction in the external costs of accidents relative to the 
baseline  (expressed  as  present  value  over  the  2026-2050  period),  estimated  at  EUR  75.2  billion.  It  is 
followed by PO2 with EUR 74.2 billion, PO1b with EUR 73.9 billion, and PO1a with EUR 48.1 billion.  

Table 17: Reduction in the external costs of accidents in the POs relative to the baseline, expressed as present 
value over the 2026-2050 horizon, in 2022 prices (million EUR) 
 PO1a  
11,677 
21,348 
15,053 
48,079 

 Fatalities  
 Serious injuries  
 Slight injuries  
 Total  

 PO1b  
17,498 
33,235 
23,196 
73,929 

 PO3  
17,902 
33,821 
23,521 
75,244 

 PO2  
17,633 
33,299 
23,251 
74,183 

Source: Ricardo et al. (2024), Impact assessment support study 

6.2.2.  Impact on employment 

Measures involving an extension of vehicle scope or increase in testing frequency for particular vehicle 
categories will lead to additional inspections and the need for additional inspectors to perform them. The 
impact on the number of full-time RSI and PTI inspectors employed, relative to the baseline, has been 
estimated on the basis of the additional number of inspections required in each policy option231. The impacts 
on the number of full-time RSI and PTI inspectors in 2026, 2030, and 2050, relative to the baseline, are 
provided in Table 18 and Table 19, respectively. It should be noted that RSI inspectors are employed by 
and generate costs for national public authorities (discussed in section 6.1.1), while PTI inspectors by PTI 
centres (included under businesses and discussed in section 6.1.2.1).   

Apart from the indirect positive impact on garage equipment manufacturers, related to the need for new 
testing equipment (in particular under PMC3 and PMC4), no direct impacts on employment are expected 
from the common set of measures. PO1a is expected to increase the number of full-time RSI inspectors by 
16 in 2030 and 20 in 2050 relative to the baseline. The impact on employment for PO1a is solely driven by 
PM1, which requires additional RSI inspectors to perform inspections of motorcycles over 125cc for those 

229  https://op.europa.eu/en/publication-detail/-/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1  
230 Based on the Handbook, the external cost of a fatality in 2022 prices is estimated at around EUR 3.5 million, that of 
a  serious injury at around EUR 0.5 million and that of a  slight injury at around EUR 0.04 million. These values are 
multiplied by the number of fatalities, serious and slight injuries, respectively, to monetise the external costs of accidents 
in the context of this impact assessment. 
231 The number of inspections per inspector is dependent on the assumed time taken to perform the required procedure and the 
location of the test (either at PTI centres or at the roadside). 

58 

 
  
  
  
  
  
  
  
  
  
  
 
Member States where there is no PTI currently in place. No direct impact on employment for PTI centres 
is expected under this policy option. 

PO1b is expected to increase the number of full-time PTI inspectors by 18,923 in 2030 and 20,322 in 2050, 
relative  to  the  baseline.  The  increase  in  employment  is  mainly  a  result  of  PM2  and  PM5  (PTI  for 
motorcycles and annual emission testing for vans), PM6 (the mandatory yearly testing of vehicles that are 
10-year-old or older), PM10 (noise testing of motorcycles at PTI) and PM12 (for the additional emission 
tests for vehicles that are found as high emitters during remote sensing or plume chasing and are sent 
for emission test in a PTI centre). Of these, PM6 is expected to have by far the largest impact as it involves 
more frequent testing of around a quarter of the EU car and van fleet. No direct impact on employment for 
RSI inspectors is expected under this policy option.  

For PO2 the increase in the number of full-time PTI inspectors is slightly lower than in PO1b (18,752 in 
2030 and 20,107 in 2050, relative to the baseline). This is driven by the annual emission testing of vans 
(PM5), the mandatory yearly testing of vehicles that are 10-year-old or older (PM6), by the noise testing of 
motorcycles at PTI (PM10) and by the additional  emission  tests  for  vehicles  that  are  found  as  high 
emitters  during  remote  sensing  or  plume  chasing  and  are  sent  for  emission  test  in  a  PTI  centre 
(PM12). Unlike PO1b, PO2 does not include the effect of PM2. PO2 is also expected to increase the number 
of full-time RSI inspectors by 204 in 2030 and 243 in 2050, relative to the baseline. The impact of PO2 on 
the number of full-time RSI inspectors is mostly due to PM14, which requires to extend roadside inspections 
to  2%  of  the  fleet  of  vans.  PM1  also  requires  additional  inspectors  relative  to  the  baseline,  to  inspect 
motorcycles over 125cc for those Member States where there is no PTI currently in place.  

PO3 measures are expected to lead to 19,047 additional full-time PTI inspectors in 2030 and 20,357 in 
2050, relative to the baseline. Similarly to PO2, PO3 includes the impacts of PM5, PM6, PM10 and PM12. 
In addition, PM3 and PM4 also require additional inspectors from 2026 in PO3. PO3 is also expected to 
lead to an increase in the full-time RSI inspectors of 248 in 2030 and 283 in 2050, relative to the baseline. 
The increase in RSI employment for PO3, relative to the baseline, is due to the extension of the RSI scope 
to cover vans (PM14) and L-category vehicles (PM15). 

Table 18: Increase in the number of full-time RSI inspectors by policy option, relative to the baseline, in 2026, 
2030 and 2050 

Difference to the baseline 
PO2 
PO1b 
197  
-  
204  
-  
243  
-  
Source: Ricardo et al. (2023), Impact assessment support study 

PO1a 
15  
16  
20  

2026 
2030 
2050 

PO3 
242  
248  
283  

Table 19: Increase in the number of full-time PTI inspectors by policy option, relative to the baseline, in 2026, 
2030 and 2050 

2026 
2030 
2050 

PO1a 

-    
-    
-    

Difference to the baseline 
PO2 
PO1b 

        18,448  
        18,923  
        20,322  

        18,281  
        18,752  
        20,107  

PO3 

        18,569  
        19,047  
        20,357  

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

As well as the increase in the number of inspectors employed, there will be benefits from the additional 
training for the inspectors that will be needed to be able to deliver the new testing methods. The impact on 
inspectors’ skills will be positive for all policy options, with PO3 offering the greatest impact. Furthermore, 
the need for additional testing equipment for new test procedures and additional inspections will lead to 

59 

 
 
 
indirect employment benefits for the wider equipment supply chain and distribution network. In particular, 
the demand for additional and new testing equipment will lead to an increase in production-related jobs 
within Member States (provided that manufacturing capabilities are available within the EU27). Also, there 
will be employment benefits related to providing ongoing maintenance for the new testing equipment. In 
particular,  measures  concerning  new  emission  testing  equipment  (PMC3  and  PMC4)  could  increase 
equipment-related employment.  

6.2.3.  Impacts on fundamental rights 

The policy options were assessed to determine if they have an impact on the fundamental rights and/or equal 
treatment of EU citizens. The starting point of the assessment of the fundamental rights is the Charter of 
Fundamental Rights of the European Union232. All POs were assessed having regard to the relevant EU 
instrument and it was concluded that they maintain full respect for human and fundamental rights, and none 
will have any negative impact thereon. A more detailed analysis is provided in Annex 12. 

6.3.  Environmental impacts 

The analysis of environmental impacts covers the air pollutant emissions, CO2 emissions, noise emissions 
and natural resources. One of the general objectives is contributing to sustainable mobility, therefore the 
environmental  benefits  are  an  important  justification  for  the  initiative.  In  the  first  step,  the  expected 
contribution of each measure on the identification and removal of high emitter vehicles (whether due to 
defective emissions control systems or tampering) from the fleet is defined. It is assumed that high emitters 
identified will undergo repair (whether this refers to the replacement of malfunctioning filters, sensor or 
noise reduction system or the necessary modifications of the engine). The reduction of high emitters by 
policy option relative to the baseline is then used as input in the PRIMES-TREMOVE model to calculate 
the reduction in air pollutant emissions, and in the external costs of air pollution emissions and noise233. The 
impacts on environmental outcomes assessed are only linked to the measures considered in this impact 
assessment. More detailed explanations of the inputs used by policy measure are included in section 4.2 of 
Annex 4. A detailed discussion of the impacts on air pollution and noise emissions by policy option is 
provided in section 5.2 of Annex 4. A qualitative assessment is provided for the impacts on CO2 emissions 
and natural resources. 

Impacts  on  air  pollutant  emissions.  The  analysis  of  the  impact  on  emissions  has  focused  on  the  two 
pollutants  that  are  targeted  in  the  proposed  measures,  NOx  and  particulate  matter  (particulates).  Other 
pollutants have not been considered although it is possible that by targeting high emitters for these two 
pollutants, there will also be benefits related to other air pollutants (e.g. CO, HC, SO2). Table  presents the 
expected impact on the level of emissions in comparison to the baseline for each policy option. PO2 and 
PO3 are expected to have the highest cumulative impact on air pollutants reduction over 2026-2050 (3,969 
kilo-tonnes of NOx in PO2 and 3,970 kilo-tonnes of NOx in PO3, and 199 kilo-tonnes of PM in both PO2 
and PO3), representing a decrease of 21% and 18.7% for NOx and PM, respectively, relative to the baseline. 
PO1b shows somewhat lower levels of emissions reductions (20.8% for NOx and 18.5% for PM). PO1a is 
expected to bring the least reduction of both air pollutants over the 2026-2050 period (3,176 kilo-tonnes of 
NOx, representing a 16.8% reduction relative to the baseline, and 135 kilo-tonnes of PM, representing 
12.7% reduction). 

232 https://commission.europa.eu/aid-development-cooperation-fundamental-rights/your-rights-eu/eu-charter-
fundamental-rights_en  
233  The  2019  Handbook  on  the  external  costs  of  transport  (Source:  https://op.europa.eu/en/publication-detail/-
/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1) has been used to monetise the costs.  

60 

 
 
Table 20: Impact on air pollutant emissions (kilo tonnes of NOx and PM2.5 avoided relative to the baseline in 2030 
and  in  2050,  and  cumulative  over  2026-2050;  %  change  in  cumulative  air  pollution  emissions  relative  to  the 
baseline) 

2030 

2050 

Cumulative 
over 2026-2050 

% change to 
baseline 

NOx (kilo tonnes of NOx avoided) 
PO1a 
PO1b 
PO2 
PO3 
PM2.5 (kilo tonnes of PM avoided) 
PO1a 
PO1b 
PO2 
PO3 

200.5 
253.1 
255.9 
255.9 

7.8 
12.0 
12.1 
12.1 

Source: Ricardo et al. (2024), Impact assessment support study 

12.1 
13.9 
14.0 
14.0 

0.6 
0.8 
0.8 
0.8 

3,176 
3,925 
3,969 
3,970 

135 
196 
199 
199 

-16.8% 
-20.8% 
-21.0% 
-21.0% 

-12.7% 
-18.5% 
-18.7% 
-18.7% 

The external cost savings due to the reduction of air pollutant emissions (NOx and PM) were calculated 
using the 2019 Handbook on the external costs of transport234. PO2 and PO3 are expected to lead to the 
highest levels of reduction in external costs, estimated at around EUR 76.1 billion, expressed as present 
value over the 2026-2050 period. This is slightly higher than in PO1b (EUR 75.2 billion) and much higher 
than in PO1a (EUR 58.7 billion). Results are presented in Table . 

Table 21: Reduction in the external costs of air pollutant emissions relative to the baseline, expressed as present 
value over 2026-2050, in 2022 prices (million EUR) 

Reduction in external costs related to NOx emissions  

PO1a 
46,966  

PO1b 
58,054  

PO2 
58,646  

PO3 
58,659  

Reduction in external costs related to PM emissions  

11,707  

17,193  

17,429  

17,429  

Total reduction in external costs of air pollutant emissions  

58,673  

75,247  

76,075  

76,088  

Source: Ricardo et al. (2024), Impact assessment support study 

Impact on noise emissions. The impact on the reduction of high emitters and thereby on noise is expected 
to be the lowest in PO1a as it does not contain any measure directly targeted at noise (it has a small positive 
impact through 6, the assumed introduction of roadside checks for motorcycles in six Member States where 
they are not fully covered by PTI235). A higher impact is expected in the case of PO1b and PO2, combining 
more advanced noise testing in PTI (PM10) and use of remote sensing to support roadside inspections 
(PM12).  For  PO2  and  PO3,  additional  positive  impacts  can  also  arise  from  the  increase  in  roadside 
inspection of vans but the highest impacts in terms of noise reduction are expected in PO3, due to the 
mandatory RSI for motorcycles (PM15). Table 22 presents the estimated reduction in the external costs of 
noise  for  the  four  policy  options,  with  PO3  providing  the  largest  savings  of  around  EUR  7.8  billion, 
expressed as present value over 2026-2050 relative to the baseline. PO1b and PO2 are expected to bring 
similar reductions in the external costs of noise (EUR 7.3 billion over the same period). The reduction under 
PO1a would be significantly lower (EUR 0.2 billion). As for the costs of accidents and air pollution, the 
external costs of noise were calculated using the PRIMES-TREMOVE model, based on the 2019 Handbook 
on the external costs of transport. 

234  https://op.europa.eu/en/publication-detail/-/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1  
235 BE, FI, IE, MT, NL, PL. 

61 

 
  
 
 
 
 
 
 
 
 
  
 
Table 22: Reduction in the external costs of noise emissions relative to the baseline, expressed as present value 
over 2026-2050, in 2022 prices (million EUR) 

Reduction in external costs related to noise emissions  

PO1a 
154  

PO1b 
7,323  

PO2 
7,319  

PO3 
7,757  

Source: Ricardo et al. (2024), Impact assessment support study 

Impact on CO2 emissions and climate change. CO2 emissions are not tested as part of the roadworthiness 
and roadside inspections and the measures included in this analysis are not expected to have a direct impact 
on the CO2 emissions of vehicles. Any impact on CO2 emissions may only be indirect in case there would 
be reductions in the fuel consumption as a result of PTI inspections. Measure PM5 that introduces more 
frequent emission testing for vans from year 1, and PM6 on the annual testing of vehicles older than 10 
years could potentially have such an impact, but it is expected to remain very limited and has not been 
quantified. The reduction in particulate matter (soot) is not only expected to improve air quality but probably 
also have a positive impact on climate change. Since dark particles absorb sunlight, warm the atmosphere 
and cause faster melting of snow and ice, they have a warming effect on the climate236. However, the extent 
of the net impact taking various indirect effects (including in cloud formation) into account is still uncertain 
and subject to ongoing research237. Although such an impact on climate change has not been quantified, 
recent calculations indicate that it may be substantial238. 

Impact on natural resources. Some of the measures under consideration are expected to have a direct 
impact on the use of natural resources. These include the requirement for the PTI certificate to be issued in 
electronic format only (PMC6, included in all policy options), and issuing the registration certificates in 
electronic format (PM16, included in PO1a, PO2 and PO3). Both can be expected to bring saving in terms 
of the use of paper that will be proportionate to the number of PTIs and vehicle registrations. However, their 
impact  may  be  lower  in  the  short  term  due  to  continued  provision  of  paper  versions  on  request.  The 
replacement of paper PTI certificates with digital copies is projected to affect 161.5 million vehicles in 2026, 
167.3 million vehicles in 2030 and 190.6 million in 2050. The replacement of paper registration certificates 
with digital copies is projected to affect 24.1 million new vehicles in 2026, 25.3 million new vehicles in 
2030 and 27.6 million in 2050. Hence the savings from electronic PTI certificates are expected to be much 
greater than for electronic registration certificates.  

Regarding  the  impact  on  biodiversity,  it  is  considered  that  the  reduction  of  NOx  emissions  from  road 
transport may also have positive impact on the health of ecosystems, due to their reduced indirect exposure 
related  to  chronic  accumulation  of  nitrogen.  This  impact,  while  established  in  various  studies  and 
reviews239, was however not analysed and quantified for this initiative since it is expected to be indirect and 
limited. 

All policy options are consistent with the environmental objectives of the European Green Deal (though 
contributing to these objectives at varying degrees as outlined above) and the European Climate Law240. 
All policy  options  contribute towards Sustainable  Development Goals SDG  3.  No significant harm  is 
expected on the environment in any of the policy options.   

236 See e.g.https://climate.nasa.gov/explore/ask-nasa-climate/3271/aerosols-small-particles-with-big-climate-effects/  
237 See also Bond, T. C., et al. (2013), Bounding the role of black carbon in the climate system: A scientific assessment, 
J. Geophys. Res. Atmos., 118, 5380–5552, doi:10.1002/jgrd.50171.  
238 Mayer, A.C., Mayer, J., Wyser, M. et al.  Particulate Filters for Combustion Engines to Mitigate Global Warming. 
Estimating  the  Effects  of  a  Highly  Efficient  but  Underutilized  Tool.  Emiss.  Control  Sci.  Technol.  (2024). 
https://doi.org/10.1007/s40825-023-00236-x  
239 Ricardo-AEA Ltd for Natural (2016), Such as the ecological effects of air pollution from road transport: an updated 
review. 
240 Regulation (EU) 2021/1119 

62 

 
  
 
7.  HOW DO THE OPTIONS COMPARE? 

7.1.  Effectiveness 

The assessment of effectiveness looks at the extent to which the policy options meet the general and specific 
objectives (SO) of the intervention.  Table   provides the link between policy objectives and assessment 
criteria. 

Table 23: Link between objectives and assessment criteria 

Objectives 

Assessment criteria 

General objectives 

GO1- Improve road safety in the EU 

GO2 – Contribute to sustainable mobility 

GO3 - Facilitate the free movement of persons and 
goods in the Union 

Specific objectives 

the  adequacy,  consistency, 
SO1  –  Ensure 
objectivity and quality of roadworthiness testing of 
today's and tomorrow's vehicles  

SO2  –  Significantly  reduce  fraud  and  tampering, 
and improve the detection of defective vehicles 

SO3 - Improve electronic storage and exchange of 
relevant vehicle identification and status data 

% reduction in the level of fatalities and injuries and associated 
external costs 

% reduction in the level of air pollutant emissions and noise 
from road transport and associated external costs 

Removal of obstacles to re-registration of vehicles in another 
MS related to roadworthiness legal framework  
Removal of obstacles related to the roadworthiness testing of 
vehicles (recognition of certificates issued by other MSs) 

Use of available test methods and procedures to assess the 
roadworthiness of vehicles, including new internal combustion 
engine and electric vehicles, and their electronic safety and 
emission control systems  
Impact (% of reduction) on the number of defective vehicles  

Impact (% reduction) on the number of vehicles with tampered 
emission/noise control system 

Impact (% reduction) on the number of vehicles with tampered 
odometer  

Reduction of time/costs associated with the  access to relevant 
vehicle  data  by  inspection  centres  and  enforcement  and 
registration authorities. 

All policy options contribute to the general objective of increasing road safety in the EU through more 
effective identification of vehicles with major and dangerous defect in the fleet. The most effective policy 
options are PO3 (7,013 lives saved and 65,686 serious injuries avoided), PO2 (6,912 lives saved and 64,885 
serious injuries avoided) and PO1b (6,847 lives saved and 64,640 serious injuries avoided), while for PO1a 
a smaller positive effect is expected (4,661 lives saved and 42,272 serious injuries avoided). All policy 
options will also contribute to sustainable mobility by reducing air pollutant and noise emissions. This 
will lead to a reduction of external costs of these emissions, with the most effective options being PO3 
(external costs savings from the reduction of air pollutants and noise estimated at EUR 83.8 billion), PO2 
(external costs savings estimated at EUR 83.4 billion) and PO1b (external costs savings estimated at EUR 
82.6 billion). PO1a, as the least effective, is expected to bring external costs savings of EUR 58.8 billion. 
All policy options will facilitate the free movement of persons and goods in the EU through removal of 
obstacles to re-registration of vehicles in another Member State, where PO1a, PO2 and PO3 are expected 
to be similarly effective, while PO1b is expected to be less effective due to the absence of measures on 
digital  vehicle  registration  certificate  and  additional  data  included  in  the  vehicle  register.  Regarding 
removing  obstacles  related  to  the  roadworthiness  testing  of  vehicles,  PO3  is  expected  to  be  the  most 
effective option due to EU wide recognition of PTI certificates in another Member State extended to all 
vehicles, followed by PO2 and PO1b (limited EU wide recognition of PTI certificates) and PO1a as the 
least effective (bilateral agreements on recognition of PTI certificates).  

63 

 
Thanks to the common set of measures, all policy options are effective in reaching the specific objectives. 
The differences in their overall effectiveness are linked to their focus, and thus the inclusion of additional 
measures aimed at further addressing one or the other specific objective.  

As regards SO1, all options can be expected to bring significant benefits through introducing test methods 
for the inspection of electric vehicles, improved emission testing for internal combustion engine vehicles 
(NOx and PN measurement), and the introduction of testing ADAS and other safety systems required by 
the General Safety Regulation. PO1b, PO2 and PO3 are expected to perform better than PO1a as they would 
bring additional positive impacts through the introduction of mandatory cargo securing inspections and new 
ways of testing, such as plume chasing and remote sensing to monitor pollutant and noise emissions. PO2 
and PO3 go even further than PO1b with the data governance measures to define the procedures and means 
of access to vehicle technical information by PTI centres, that should also contribute to the enhanced quality 
and consistency of inspections.  

In terms of the achievement of SO2, all options are expected to lead to a reduction of defective and tampered 
vehicles  through  improved  detection,  thanks  to  the  new  ways  of  testing,  as  well  as  to  systematically 
addressing odometer fraud. PO1b, PO2 and PO3 are however expected to be significantly more effective, 
due to the increase in the scope of vehicles covered (mandatory yearly testing of vehicles over 10 years old). 
PO1b  and  PO3  are  more  effective  than  PO2  in  reducing  the  negative  externalities  associated  with 
motorcycles (mandatory PTI versus optional in the other two options). 

Roadside  inspections  are  an  effective  complementary  measure  when  it  comes  to  the  identification  of 
tampering of emission and noise control systems, the latter especially for motorcycles, that are much more 
difficult to capture as part of the PTI since they are very easy to manipulate. Therefore, PO2 and PO3 are 
expected to be more effective, given that both extend RSI to light commercial vehicles, and in the case of 
PO3, also to motorcycles. Nevertheless, the differences between PO3 and PO1b and PO2 in terms of the 
expected level of reduction of defective vehicles and high emitters are relatively small, essentially linked to 
the more comprehensive approach of PO3, i.e. the inclusion of all motorcycles in both PTI and RSI. PO3 is 
expected to be the most effective in addressing SO2, closely followed by PO2and PO1b, while PO1a is 
expected to be significantly less effective. 

In  relation to  SO3,  all options  can be  expected to  make  a positive  contribution  based on  the  common 
measures on the mandatory electronic roadworthiness certificate, access to relevant PTI and registration 
data for national authorities by using a common interface  and the harmonisation and regular update of 
technical data in  vehicle  registration  documents. PO1a,  PO2  and PO3  are  expected to  bring additional 
benefits due to the extension of data included in the vehicle register database and the introduction of the 
vehicle registration document in digital format. Moreover, PO2 and PO3 are expected to be more effective 
than  PO1a  and  PO1b  because  of  improved  data  governance  and  enhanced  access  to  relevant  vehicle 
technical information for PTI centres. Taken together, while there are limited differences among the four 
policy options in meeting the SO3, PO2 and PO3 appear to be most effective, followed by PO1a, and PO1b 
being the least effective option.  

Overall, option PO3 seems to be the most effective when considering the expected contribution towards the 
achievement of all general and specific objectives, closely followed by PO2. PO1a is the least effective – 
especially in relation to specific objectives SO1 and SO2. PO1b is almost as effective as PO2 in terms of 
SO1 and SO2, but is expected to be less effective in the case of objective SO3. A more detailed assessment 
of the effectiveness, including quantified impacts per objective can be found in Annex 9. 

7.2.  Efficiency 

Efficiency concerns the ‘extent to which objectives can be achieved for a given cost (cost effectiveness)’. 
The estimates of costs and benefits are summarised in Table .  

64 

 
Table 24: Summary of costs and benefits of policy options – present value over 2026-2050 compared to the baseline 
(in million EUR), in 2022 prices 

PTI centres 
Adjustment costs 
Administrative costs 
Administrative costs savings 
Benefits  
Garages, motor vehicle dealers, 
tyre and repair stations, etc. 

Administrative costs 
OEMs 
Administrative costs 
Other businesses - vehicle owners 
Administrative costs 
Administrative costs savings 
Benefits 
Citizens 
Administrative costs 
Adjustment costs savings 
Administrative costs savings 
Benefits 
National public authorities 
Adjustment costs 
Administrative costs 
Enforcement costs 
Administrative costs savings 
External costs savings 
Air pollution 
Accidents 
Noise 
Total costs 
Total benefits 
Net benefits 
Benefits to costs ratio 

PO1a 

3,734.1 
0.0 
0.0 
860.5 

460.0 

0.0 

524.2 
0.0 
118,340.5 

344.2 
878.2 
0.0 
65,666.9 

7.0 

2,233.8 
0.0 
5,226.3 

58,673.1 
48,078.8 
154.2 
7,303.3 
297,878.5 
290,575.2 
40.8 

Difference to the baseline 
PO2 
PO1b 

23,507.9 
0.0 
0.0 
39,394.2 

460.0 

0.0 

25,458.4 
1,287.3 
118,340.5 

13,944.3 
2,144.6 
591.9 
65,666.9 

198.3 

2,190.4 
32.9 
3,796.8 

75,246.6 
73,929.4 
7,323.4 
65,792.3 
387,721.5 
321,929.2 
5.9 

23,332.2 
136.5 
1,643.4 
39,100.1 

460.0 

55.9 

25,666.4 
1,287.3 
118,340.5 

13,658.1 
2,144.6 
591.9 
65,666.9 

207.2 

2,387.5 
0.0 
5,226.3 

76,074.5 
74,183.0 
7,319.4 
65,903.9 
391,577.8 
325,674.0 
5.9 

PO3 

25,061.7 
136.5 
1,643.4 
39,968.0 

460.0 

55.9 

26,051.5 
1,287.3 
118,340.5 

14,150.0 
4,289.3 
591.9 
65,666.9 

208.0 

2,397.9 
77.4 
5,226.3 

76,087.7 
75,244.2 
7,756.7 
68,598.9 
396,102.1 
327,503.2 
5.8 

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

Total costs are projected to be the lowest in PO1a, estimated at EUR 7.3 billion expressed as present value 
over 2026-2050 relative to the baseline, followed by PO1b (EUR 65.8 billion), PO2 (EUR 65.9 billion) and 
PO3 (EUR 68.6 billion). Of these, adjustment costs for PTI centres (for equipment, training, and additional 
inspectors to perform the inspections) represent around 51% of the total costs in PO1a, 36% in PO1b, 35% 
of the total costs in PO2 and 37% in PO3. Administrative costs for other businesses (i.e., vehicle owners), 
for  additional  periodic  technical  inspections  and  cooperating  on  roadside  inspections  with  the  public 
authorities, represent another important element of the total costs (7% of total costs in PO1a, 39% in PO1b 
and in PO2 and 38% in PO3). This is also the case of administrative costs for citizens (for additional periodic 
technical inspections and cooperating on roadside inspections with the public authorities), estimated at 5% 
of the total costs in PO1a and 21% of total costs in PO1b, PO2 and PO3. The large share of administrative 
costs  for  other  businesses  and  citizens  (i.e.,  vehicle  owners)  in  PO1b,  PO2  and  PO3  is  related  to  the 
mandatory yearly testing for vehicles that are 10-year-old or older (PM6). Finally, administrative costs for 
national public administrations are expected to represent around 31% of the total costs in PO1a and below 
4% in PO1b, PO2 and PO3. In PO1a these relate to the setup of the database with odometer readings and 

65 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
the operation of the system (PMC9). Other costs represent a relatively small share of the total costs in all 
policy options.  

Total benefits are estimated at EUR 297.9 billion in PO1a, EUR 387.7 billion in PO1b, EUR 391.6 billion 
in PO2 and EUR 396.1 billion in PO3, expressed as present value over 2026-2050 relative to the baseline. 
Of these, external costs savings related to air pollutant emissions, noise emissions and accidents would 
represent around  36% in PO1a and 40%  in PO1b, in PO2 and in PO3. Benefits for citizens and other 
businesses (i.e., vehicle owners) due to the avoided odometer fraud would represent 62% of the total benefits 
in PO1a, 47% in PO1b and in PO2 and 46% in PO3. In addition, the mandatory yearly testing for vehicles 
that are 10-year-old or older (PM6) would lead to additional benefits for the PTI centres in PO1b, PO2 and 
PO3 due to the higher number of inspections relative to the baseline. The total benefits for the PTI centres 
are estimated at around 10% of the total benefits in PO1b, PO2 and PO3. Other costs savings represent a 
relatively small share of the total benefits in all policy options. 

Overall, all policy options result in net benefits relative to the baseline. PO3 shows the highest net benefits, 
estimated at EUR 327.5 billion expressed as present value over 2026-2050, followed by PO2 (EUR 325.7 
billion), PO1b (EUR 321.9 billion) and PO1a (EUR 290.6 billion). PO1a shows the highest benefits to costs 
ratio among the options (40.8), followed by PO1b (5.9), PO2 (5.9) and PO3 (5.8). 

Among the measures included in the policy options, it should be noted that the setup of the database with 
odometer readings and the operation of the system (PMC9, included in all options) is estimated to lead to 
the highest benefits to costs ratio (69.8). The mandatory yearly testing for older vehicles (PM6, included in 
PO1b, PO2 and PO3) is estimated to lead to benefits to costs ratio of 1.4, the mandatory PTI for light trailers 
(PM4, included in PO3) to benefits to costs ratio of 0.7, and the policy measures focusing on motorcycles 
to benefits to costs ratios of 2.4 to 20.2. More specifically, for motorcycles the policy measures focusing on 
roadside inspections (PM1, included in PO1a and PO2; and PM15, included in PO3) show much higher 
benefits to costs ratio (20.2 for PM1 and 18.5 for PM15) than measures extending the PTI (PM2, included 
in PO1b with benefits to costs ratio of 2.4; and PM3, included in PO3, with benefits to costs ratio of 2.5). 
This is because of the higher effectiveness of the roadside inspections relative to PTI. More details on the 
calculation of the benefits to costs ratios for these measures are provided in Annex 4 (section 6).  

7.3.  Coherence 

Internal coherence assesses how various elements of the proposed options are expected to work together 
to achieve the objectives. Although all four policy options address the identified specific objectives and 
underlying problem drivers, they do so in different ways, and with a different level of intervention. All 
policy options ensure internal coherence. Among the four options, PO2 and PO3 are expected to benefit 
from a broader range of synergies that can contribute to a higher level of achievement of the objectives. 
This is thanks to their more comprehensive approach compared to PO1a and PO1b. Synergies indicated 
in relation to PO1a and PO1b are expected to increase in the case of PO2 and PO3, containing more 
comprehensive sets of measures and even lead to extra synergies, for example due to measures on 
registration certificates and more harmonised registered data. The differences between PO2 and PO3 
are limited. They consist in PO3 proposing almost complete harmonisation in the area of roadworthiness 
testing: in terms of testing methods, full recognition of PTI certificates, and the full coverage of smaller 
motorcycles (down to 50 cm3) and light trailers by PTI, as well as RSI for motorcycles. On the other hand, 
PO2 addresses the bulk of the issues/inconsistencies. 

External coherence focuses on the compliance of the initiative with other EU instruments and relevant EU 
policies, as well as national policies or international obligations. All identified policy options show strong 
links to several EU instruments. In terms of external coherence, all policy options are considered consistent 
with relevant EU strategies and legal instruments and contribute to EU policy priorities. PO1b (focussing 

66 

 
on more and better testing), as well as PO2 and PO3 perform best when it comes to coherence with the road 
safety policies, notably the “Vision Zero” objective. The same is true as regards coherence with the EU’s 
green policies, such as the European Green Deal, the Sustainable and Smart Mobility Strategy, the Zero 
Pollution Action Plan and the air quality legislation. On the other hand, PO1a, PO2 and PO3 are more 
coherent with digital policies (e.g. the Single Digital Gateway, Data Act) than PO1b. In relative terms, PO3 
and PO2 are  expected to  be the most coherent with the policy objectives in related EU legislation and 
strategies,  followed  by  PO1b  and PO1a being slightly less  coherent.  In  relation to the  well-established 
national policies in the field, however, stronger interventions, in particular in PO3, are less coherent. This is 
further explained under section 7.4 below. Detailed comparison of policy options regarding internal and 
external coherence is provided in Annex 14. 

7.4. 

Subsidiarity and proportionality 

Regarding subsidiarity, and as described in sections 3.2 and 3.3, EU action is justified on the basis that 
Member States alone would not be able to reach the objectives of the initiative, i.e., updating the harmonised 
rules on roadworthiness testing, including coordinated exchange of vehicle-related data. What differentiates 
the policy options beyond the common measures necessary to achieve the objectives at a minimum level is 
their focus (between PO1a and PO1b) and the extent to which they can fulfil the objectives (PO2 and PO3 
going beyond the other two). In terms of proportionality, as the level of intervention and associated costs 
increase from PO1a to PO3, the level of positive impacts also increases, although not proportionally (as 
shown by the efficiency ratios).  

In general, the scope of the options is limited to what can best be achieved at the EU level (in terms of 
harmonisation of methods and scope of testing, as well as in finding common solutions to ensure efficient 
sharing  and  access  to  the  necessary  vehicle  data).  All  policy  options  comply  with  the  principle  of 
subsidiarity and proportionality,  with  PO3 possibly going  somewhat  beyond what  is  necessary to 
reach  the  objectives.  This  may  be  the  case  in  particular  with  requiring  full  recognition  of  PTI 
certificates, which may not be compatible with existing structural differences  in the way Member 
States have set up their periodic testing involving, among others, significant differences in pricing, 
granting concessions and differences in the structural organisation of the PTIs. In addition, it could 
be argued that the need to introduce PTI for light motorcycles and trailers, which primarily circulate 
on national territory, may be best assessed by Member States. More detailed analysis on subsidiarity 
and proportionality is provided in Annex14. 

Table 25 provides a summary of the comparison of the options against the baseline scenario in terms of 
effectiveness, efficiency, coherence, subsidiarity, and proportionality. The following ranking symbols have 
been used: from '+' (more effective/efficient/coherent/proportionate than the baseline) to '+++' (much more 
effective/efficient/coherent/proportionate than the baseline). 

Table 25: Comparison of options in terms of effectiveness, efficiency, coherence, subsidiarity and proportionality 
relative to the baseline 

Impacts  

Effectiveness 
Road safety (GO1) 
Reduced fatalities by 
Reduced severe injuries by 
Reduced slight injuries by 
External cost savings (billion EUR) 

Air pollution and noise (GO2) 
Reduction of NOx emissions (kt) 

PO1a 
+ 

4,661 
42,272 
239,803 
48.1 
(++) 

PO1b 
++ 

6,847 
64,640 
364,155 
73.9 
(+++) 

PO2 
++/+++ 

6,912 
64,885 
365,665 
74.2 
(+++) 

PO3 
+++ 

7,013 
65,686 
368,498 
75.2 
(+++) 

3,176 

3,925 

3,969 

3,970 

67 

 
 
 
  
  
  
  
 
  
  
  
  
Impacts  

Reduction of PM emissions (kt) 
External cost savings - emissions (billion 
EUR) 

External  cost  savings  -  noise  (billion 
EUR) 

Free  movement  of  persons  and  goods 
(GO3) 
Removal of obstacles to re-registration of 
vehicles in another MS 
Removal  of  obstacles  related  to  the 
roadworthiness testing 
Update of roadworthiness testing (SO1) 
Roadworthiness of vehicles (incl. electric) 
in terms of their road safety performance 
Roadworthiness  of  vehicles  in  terms  of 
their environmental performance 
Reducing 
detection of defected vehicles (SO2) 
Reduction 
tampered 
defective 
vehicles  in  terms  of  emission  control 
systems 
Reduction  of  vehicles  with  tampered 
emission/noise control system 
Reduction of odometer tampering 
Benefits  due  to  reduction  of  odometer 
tampering (billion EUR) 

tempering, 

improving 

and 

PO1a 
135 
58.7 

(++) 
0.2 

(0/+) 

(++) 

(+) 

(+) 

(+) 

(++) 

(0/+) 

PO1b 
196 
75.2 

(+++) 
7.3 

(++) 

(+) 

(++) 

(+++) 

(+++) 

PO2 
199 
76.1 

(+++) 
7.3 

(++) 

(++) 

(++) 

(+++) 

(+++) 

PO3 
199 
76.1 

(+++) 
7.8 

(++) 

(++) 

(+++) 

(+++) 

(+++) 

(+++) 

(+++) 

(+++) 

(+) 

(++) 

(+++) 

(+++) 
118.3 (businesses 
owners) 
65.7 (consumers) 

(+++) 
118.3 (businesses 
owners) 
65.7 (consumers) 

(+++) 
118.3 (businesses 
owners) 
65.7 (consumers) 

(+++) 
118.3 (businesses 
owners) 
65.7 (consumers) 

Electronic  storage  and  exchange  of 
vehicle  identification  and  status  data 
(SO3) 
Reduction  of  time/costs  related  to  the 
access  and  exchange  of  relevant  vehicle 
data: 
-  Cost  savings  for  authorities  (billion 
EUR) 
-  Cost  savings  for  PTI  centres  (billion 
EUR) 
Efficiency 
Coherence 
Subsidiarity and proportionality 

(+++) 

0.64 

1.43 

+++  
++ 
++ 

Source: Ricardo et al. (2024), Impact assessment support study 

7.5. 

Sensitivity analysis 

(+) 

0.64 

0.0 

++  
++ 
++ 

(+++) 

(+++) 

0.64 

1.43 

 ++ 
+++ 
++ 

0.64 

1.43 

++  
++ 
+ 

Sensitivity analysis on contribution of technical defects to road crashes and share of high emitting 
vehicles of air pollution and noise in the fleet. As indicated in section 6.2.1, there is significant uncertainty 
around the contribution of technical defects to road crashes. The central assumption used is that 4% of road 
crashes are caused by technical defects in the case of cars, vans, heavy duty vehicles and trailers and 6% in 
the case of motorcycles. A sensitivity analysis has been performed to understand the implications of lower 
or higher contribution of technical defects to road crashes. The following cases have been assessed: 

-  Low case:  3% for motorcycles and 1% for all other categories;  

-  High case: 9% for motorcycles and 7% for all other vehicle categories.  

68 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
In addition, considering the uncertainty of the share of high emitting vehicles of air pollution and noise in 
the fleet, the implications of alternative shares of high and low emitters in the baseline scenario have been 
assessed. More specifically, compared to the central case the following assumptions have been used: 

-  Low case: shares of high emitters 25% lower than in the baseline; 

-  High case: shares of high emitters 25% higher than in the baseline. 

Subsequently, the impacts on external costs and the efficiency of the policy options is assessed for the low 
and high case, including both elements related to safety and emissions. 

Table 29 presents the impacts on total benefits, net benefits and benefits to costs ratio by policy option in 
the low case, central case and high case. It shows that all policy options are expected to result in net benefits 
under the three cases considered. It also shows that the ranking of the policy options is not expected to 
change in the low case and high case relative to the central case estimates. More details on the sensitivity 
analysis, including the details on the external costs by type, are provided in Annex 4 (section 7). 

Table 26: Summary of costs and benefits of the policy options in the low case, central case and high case, expressed 
as present value over 2025-2050 compared to the baseline (in million EUR, in 2022 prices) 

Total costs 

Total benefits 

Low case 

Central case 

High case 

Net benefits 

Low case 

Central case 

High case 

Benefits to costs ratio 

Low case 

Central case 

High case 

 Difference to the Baseline  

 PO1a  

 PO1b  

 PO2  

 PO3  

7,303.3 

65,792.3 

65,903.9 

68,598.9 

     282,344.8  

           347,977.0  

           351,341.5  

           355,230.4  

     297,878.6  

           387,721.5  

           391,578.3  

           396,102.2  

     317,762.6  

           428,602.8  

           432,933.3  

           438,106.8  

     275,041.5  

           282,184.7  

           285,437.6  

           286,631.5  

     290,575.3  

           321,929.3  

           325,674.4  

           327,503.3  

     310,459.3  

           362,810.5  

           367,029.4  

           369,507.9  

              38.7  

                      5.3  

                      5.3  

                      5.2  

              40.8  

                      5.9  

                      5.9  

                      5.8  

              43.5  

                      6.5  

                      6.6  

                      6.4  

Source: Ricardo et al. (2024), Impact assessment support study 

Sensitivity  analysis  on  odometer  fraud.  As  explained  in  sections  6.1.2.4  and  6.1.3,  it  should  be 
acknowledged that there is uncertainty regarding the economic damage caused by odometer fraud and the 
number  of  vehicles  affected.  For  this  reason,  sensitivity  analysis  has  been  performed  on  the  economic 
damage caused by odometer fraud and the number of vehicles affected. 

With regard to the economic damage caused by odometer fraud, a central estimate of EUR 2,119 per 
vehicle has been used and it is explained in more detail in Annex 4 (section 2). The following cases have 
been assessed: 

-  Low economic damage case: 20% lower damage costs/costs savings per vehicle (EUR 1,696 per 

vehicle);  

-  High economic damage case: 20% higher damage costs/costs savings per vehicle (EUR 2,543 per 

vehicle).  

69 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
With regard to the number of vehicles affected, the central assumptions used for the shares of vehicles with 
tampered odometers are provided in Annex 4 (section 2), Table 37. The following cases have been assessed: 

-  Fewer vehicles affected case: share of affected vehicles 20% lower than in the central case;  

-  More vehicles affected case: share of affected vehicles 20% higher than in the central case.  

In addition, the combined impact of the economic damage caused by odometer fraud and vehicles affected 
has been assessed as follows: 

-  Low  economic  damage  and  vehicles  affected  case:  20%  lower  damage  costs/costs  savings  per 
vehicle (EUR 1,696 per vehicle) and the share of affected vehicles 20% lower than in the central 
case;  

-  High economic damage and vehicles affected case: 20% higher damage costs/costs savings per 
vehicle (EUR 2,543 per vehicle) and the share of affected vehicles 20% higher than in the central 
case.  

Subsequently, the impacts on the benefits due to avoided odometer fraud and the efficiency of the policy 
options is assessed for the low case and for the high case. In this section, only the combined impact of the 
sensitivity analysis for economic damage caused by odometer fraud and vehicles affected is presented. The 
results of the separate sensitivity analysis for the economic damage caused by odometer fraud and for the 
number of vehicles affected is presented in Annex 4 (section 7).  

Table 27 presents the impacts on total benefits, net benefits and benefits to costs ratio by policy option in 
the low economic damage and vehicles affected case, central case and high economic damage and vehicles 
affected case. It shows that all policy options are expected to result in net benefits under the three cases 
considered. It also shows that the ranking of the policy options is not expected to significantly change in the 
low economic damage and vehicles affected case and high economic damage and vehicles affected case 
relative to the central case estimates. More details on the benefits due to avoided odometer fraud in each 
case are provided in Annex 4 (section 7). 

Table 27: Summary of costs and benefits of the policy options in the low economic damage and vehicles affected 
case, central case and high economic damage and vehicles affected case, expressed as present value over 2025-
2050 compared to the baseline (in million EUR, in 2022 prices) 

Total costs 
Total benefits 
Low economic damage and vehicles 
affected case 
Central case 
High economic damage and vehicles 
affected case 
Net benefits 
Low economic damage and vehicles 
affected case 
Central case 
High economic damage and vehicles 
affected case 
Benefits to costs ratio 
Low economic damage and vehicles 
affected case 
Central case 

 PO1a  

 Difference to the Baseline  
 PO1b  

 PO2  

 PO3  

7,303.3 

65,792.3 

65,903.9 

68,598.9 

231,635.9 

321,478.8 

325,335.2 

329,859.5 

297,878.5 

387,721.5 

391,577.8 

396,102.1 

378,841.8 

468,684.7 

472,541.1 

477,065.4 

224,332.5 

255,686.6 

259,431.3 

261,260.6 

290,575.2 

321,929.2 

325,674.0 

327,503.2 

371,538.5 

402,892.5 

406,637.2 

408,466.5 

4.9 

5.9 

4.9 

5.9 

4.8 

5.8 

31.7 

40.8 

70 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
High economic damage and vehicles 
affected case 

 PO1a  

 Difference to the Baseline  
 PO1b  

 PO2  

 PO3  

51.9 

7.1 

7.2 

7.0 

Source: Ricardo et al. (2024), Impact assessment support study 

8.  PREFERRED OPTION 

8.1. 

Identification of the preferred policy options and stakeholder views 

Each  of  the  policy  options  addresses  the  problems  identified,  their  drivers  and  the  specific  objectives, 
however some options are more effective in achieving the specific and general objectives. As indicated in 
the previous sections, PO3 is the most effective option, as it performs best or among the best under all 
assessment criteria (cf. Annex 9), since it aims to fill most regulatory gaps. It is followed very closely by 
PO2, with PO1b and PO1a being less effective (especially PO1a at least in terms of bringing quantifiable 
benefits). The fact that PO1a and PO1b perform less well on certain aspects is due to their focus on better 
exchange of data (PO1a) and on better testing (PO1b), while PO2 and PO3 combine the key measures of 
the first two options.  While PO1b performs very well in relation to the objectives of improving road safety 
(GO1) and reducing the number of high-emitting vehicles (GO2), PO1a does so in terms of improving free 
movement (GO3). The advantages of PO2 and PO3 become clear when comparing the options against the 
specific objectives, where they achieve high scores while PO1a and PO1b are limited by their specific focus. 
PO1a is the least effective, especially in relation to specific objectives SO1 and SO2. 

On the other hand, in terms of efficiency, PO1a performs much better as it generates the lowest costs, while 
PO1b, PO2 and PO3 are more costly but also bring more benefits. PO1a is the most efficient option, with 
benefits to costs ratio estimated at 40.8. PO1b, PO2 and PO3 show very similar benefits to costs ratio (5.8 
to 5.9).  In terms of net benefits that can be quantified, PO1b, PO2 and PO3 perform significantly better 
than PO1a, while the quantifiable differences among these three options are relatively limited (they are 
essentially down to the measures extending PTI or RSI to relatively smaller groups of vehicles). In addition, 
compared to PO1b, PO2 brings cost savings for PTI centres due to improved data governance, as well as 
increased and more accessible data for authorities and inspection centres in PO2  as compared to PO1b 
which facilitates re-registration and roadside inspections. The efficiency and the net benefits of PO2 and 
PO3 would further increase compared to PO1b if the benefits related to achieving the objectives related to 
free movement (GO3) could be quantified. PO2 appears to strike the best balance between achieving the 
objectives to a high degree, while performing at better the other options in terms of internal and external 
coherence (by combining the most important measures of PO1a and PO1b while not having issues with 
external coherence as PO3), as well as in terms of subsidiarity and proportionality (by including only what 
is most needed to achieve the objectives). 

While all options include the most efficient policy measure (PMC9 addressing odometer fraud), which offer 
very high benefits compared to limited costs, only PO1b, PO2 and PO3 feature relatively costly measures 
that introduce new testing requirements. Among them, the mandatory yearly testing of vehicles older than 
10 years generate the highest costs, but also the largest benefits, both in terms of road safety and emission 
reductions. Crucially, this measure also generates a significant number of jobs, especially in Member States 
where the automotive industry is facing historical challenges. Comparatively, the measures differentiating 
between PO2 and PO3 are less significant, albeit still relevant. The detailed costs and benefits of those 
measures are outlined in Annex 4, section 5 and 6. 

PO2 addresses all identified issues in a comprehensive manner by adapting roadworthiness testing to new 
vehicles with a capability of identifying a significant share of high-emitters and various forms of tampering, 
including odometer fraud with the help of digitalisation and better exchange of vehicle data. What PO2 does 
not do in comparison to PO3 is mandatory PTI for all motorcycles, trailers, including lighter ones, and the 

71 

 
  
full recognition of PTIs conducted in another Member State with further harmonisation of test methods. 
While these measures could bring further benefits, they appear to be limited in comparison to the costs and 
additional administrative efforts required, and thus lower the efficiency of PO3. In relation to the well-
established national policies in the field, PO3 also appears to be less coherent than PO2, and regarding the 
full  recognition  of  PTI  certificates,  PO3  could  be  going  beyond  what  is  necessary  to  reach  the 
objectives and it may not be compatible with existing structural differences of PTI testing setup in 
the Member States.   

The analysis above points at PO2 as the preferred policy option, given it is considered effective 
in  reaching  the policy objectives, it presents  high  efficiency and net  benefits  and it appears to  be  
coherent with the well-established national policies in the field, while including in its set of measures 
only those which are needed to achieve the objectives. 

The preferred option enjoys the support of the PTI industry (CITA, FSD and others) as well as FIA, testing 
equipment (EGEA) and motorcycle manufacturers (ACEM). It is supported also by some Member States, 
notably  those  that  rely  on  thousands  of  smaller  roadworthiness  testing  centres.  Regarding  access  and 
exchange of information, 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. 
Stricter cargo securing requirements included in this option are strongly supported by the logistics industry.  

Various industry respondents, including PTI operators, called for the extension of the PTI Directive 
to cover all road vehicles. While stakeholders belonging to motorcyclists’ groups at EU or national 
level did not support such extension of the PTI to motorcycles 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.  

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,  PO2 
introduces annual emission testing for vans, and it also contains a requirement for an annual PTI for 
vehicles over 10 years old, both these measures being supported by a majority of stakeholders in the 
survey. 

Regarding  the  recognition  of  PTIs  conducted  in  another  Member  State,  PO3  introduces  a  full 
recognition,  while  PO2  requires  the  recognition  of  the  PTI  from  another  MS  than  the  MS  of 
registration for a period of up to 6 months. 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 

72 

 
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  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, 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, there was a high level of support for mandatory 
checks  during  roadside  inspections  of  commercial  vehicles  to  ensure  the  safe  securing  of  cargo, 
expressed in the survey and OPC.  

In  relation  to  introducing  RSI  to  light  commercial  vehicles,  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, but some stakeholders also suggested that this 
could bring additional costs, in terms of lost time, for SMEs operating such vehicles.   

the  existing 

Regarding  access  and  exchange  of  information/data,  two-thirds  of  respondents  in  OPC  supported 
clarifying 
in-vehicle  data.  Vehicle  and  equipment 
to 
manufacturers/suppliers were less supportive of this provision than others. 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.  

rules  on  access 

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. 

More details on stakeholder views are provided in Annex 2. 

8.2.  REFIT (simplification and improved efficiency) 

This  initiative  is  included  in  the  Commission  Work  Programme  2023241,  item  3  in  Annex  II:  REFIT 
initiatives, under headline A – A European Green Deal. It contributes to increasing the efficiency of the 
existing legislation in various ways: by replacing obsolete test methods with stat-of-the art solutions both at 
periodic as well as at roadside checks by requiring to use the most recent measurement techniques and 
technology to more effectively detect a large number of high-emitting vehicles; by introducing simple, 
nevertheless meaningful tests to check the safety and environmental performance of modern vehicles in a 
harmonised way; by interconnecting national databases to help share and access vehicle data that otherwise 
would be exchanged using more cumbersome procedures. The initiative is expected to significantly reduce 
fraud  related to  emission  and  safety-relevant  systems  as  well as  to  the  stated mileage  of  used  vehicles 

241 2023 Commission work programme – key documents (europa.eu) 

73 

 
 
especially in cross-border sales and would thus lead to significant savings in external costs as well as in 
avoided damage to consumers. 

8.3.  Application of the ‘one in, one out’ approach  

PO2 is expected to lead to administrative costs for PTI centres and vehicle manufacturers due to the measure 
on data governance (PM11), and for garages, motor vehicle dealers, tyre service and repair stations due to 
the measure on odometer readings (PMC9).  

For PTI centres, the one-off administrative costs for the adaptation of their IT systems are estimated at 
EUR 1,000 per centre. Total one-off administrative costs would amount to EUR 48.9 million in 2026, for 
the 48,880 PTI centres across the EU. The recurrent administrative costs for the maintenance of the IT 
systems are estimated at 10% of the capital costs, or EUR 100 per PTI centre. Total recurrent administrative 
costs are thus estimated at EUR 4.9 million per year from 2026 onwards.  

Vehicle manufacturers will also need to adjust their own IT systems to ensure access to the relevant data. 
The one-off costs are expected to be around EUR 1 million per vehicle manufacturer, with total one-off 
administrative costs of EUR 20 million in 2026 for the 20 vehicle manufacturers across the EU. Recurrent 
administrative costs are estimated at 10% of the capital costs or EUR 100,000 per vehicle manufacturer. 
For the 20 vehicle manufacturers, they amount to EUR 2 million per year from 2026 onwards.  

The costs for the garages, motor vehicle dealers, tyre service and repair stations will relate to possible 
software updates to allow them to transfer their data to the central national database, maintenance costs for 
the software and the time needed to record the odometer readings. Based on input from Car-Pass and the 
European Parliament study242, the costs for software updates are estimated at EUR 229 per garage in 2022 
prices243. In PMC9 these costs are relevant for 651,351 companies (470,765 repair shops and garages across 
the EU and 180,586 motor vehicle dealers)244, excluding those in Belgium and the Netherlands, which 
implemented the measure already and are part of the baseline. Total one-off administrative costs are thus 
estimated at EUR 149.2 million in 2026. In addition, for the purpose of the ‘one in one out approach’, the 
average annual recurrent administrative costs over 2026-2035 are estimated at EUR 19.5 million per year245 
or EUR 29.9 per company.  

In total, the additional one-off administrative costs relative to the baseline relevant for the ‘one in one 
out approach’ in PO2 are estimated at EUR 218 million in 2026. Expressed as annualised net present 
value  over  the  relevant  period  they  amount  to  EUR  25.5  million.  In  addition,  the  recurrent 
administrative costs relative to the baseline amount to EUR 26.4 million per year. Thus, the total 
additional administrative costs (one-off and recurrent) relevant for the ‘one in one out approach’ in 
PO2 are estimated at EUR 51.9 million per year relative to the baseline. Other administrative costs for 
citizens and businesses (i.e., vehicle owners) in PO2 relate to additional periodic technical inspections and 
cooperating on roadside inspections with the public authorities and are thus not subject to the ‘one in one 
out approach’. 

242 European Parliament (2018), Odometer Manipulation in motor vehicles in Europe, 
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf 
243 The cost was estimated at EUR 200 per garage in 2018 prices. Using the harmonised index of consumer prices (HICP) 
from Eurostat, this is equivalent to EUR 229 per garage in 2022 prices. 
244 Eurostat, Structural business statistics, Enterprise statistics by size class and NACE Rev.2 activity. 
245 This is calculated as a simple average over 2026-2035, non-discounted.  

74 

 
 
9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The Commission services will monitor the implementation and effectiveness of this initiative through a 
number of actions and a set of core indicators that will measure progress towards achieving the operational 
objectives. Five years after the revised legislation will have been applied, the Commission services should 
carry out an evaluation to verify to what extent the objectives of the initiative have been reached. 

Road safety: the Commission regularly monitors key road safety indicators, including the evolution of the 
number of fatalities, serious and slight injuries per Member State and per vehicle category, age and certain 
vehicle characteristics. Detailed information on the causes of crashes, notably on vehicle defects is unlikely 
to become available at large scale soon. In the future, analysis of event data recorders mandated by the 
General  Safety  Regulation  may  provide  more  detailed  insight  into  the  causes  of  a  significant  share  of 
crashes.  Until  then,  existing  reporting  requirements  should  be  updated  to  better  respond  to  current 
monitoring needs, as outlined in Annex 15.  

Similarly,  the  evolution  of  air  and  noise  pollution  is  continuously  monitored  by  the  EEA.  Part  of  the 
reduction expected over the years to come will be related to this initiative through better maintenance of 
vehicles  and  reduced  tampering  with  emission  control  systems.  Progress  towards  the  objective  of 
contributing to sustainable mobility can be measured through the evolution of PTI and RSI results, as well 
as from remote sensing data. As for facilitating free movement, indicators of success will be the number of 
Member States recognising PTIs conducted abroad. 

To  measure  the  success  of  the  initiative,  the  following  operational  objectives  are  set:  1)  Apply  newly 
available  safety  and  emission  testing  methods;  2)  Interconnect  Member  States’  vehicle  registers  and 
odometer databases through a common hub; 3) Digitalise vehicle documents; 4) Reduce the number of 
defective and tampered vehicles on EU roads. Indicators to monitor progress towards these objectives are 
defined in Annex 15. 

75 

 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  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. Action 66 called on 
the Commission to assess the need for a proposal to require efficient exchange of odometer readings 
across the EU. 
This initiative is included in the Commission Work Programme 2023246, item 3 in Annex II (REFIT 
initiatives), under headline A – A European Green Deal. 

2.  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 2021247. 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.  

3.  CONSULTATION OF THE RSB 

The draft impact assessment and evaluation reports were submitted to the RSB on 20 November 2023 
and were discussed by the Board on  13 December 2023. The RSB issued a positive opinion with 
reservations on 15 December 2023. The recommendations from the Board have been addressed in 
this final version of the Impact Assessment report as detailed in the table below. 

Table 28: Modifications of the impact assessment report in response to RSB recommendations 

RSB recommendations 

Modifications to the IA report 

Main considerations 

(1) The report is not sufficiently clear about the 
scale  of  the  problem,  the  robustness  of  the 
underlying evidence and the assumptions made 
in the analysis. 

Theses aspects have been clarified in section 2 
of  the  impact  assessment,  as  explained  below 
under (1) and (2). 

246 2023 Commission work programme – key documents (europa.eu) 
247 Vehicle safety – revising the EU’s roadworthiness package (europa.eu) 

76 

 
 
(2)  The  report  does  not  clearly  explain  the 
reasoning  behind  the  packaging  of  options.  It 
does  not  sufficiently  bring  out  the  key  policy 
choices and the related trade-offs, including in 
terms  of  reduced  fatalities  and  injuries.  The 
costs  and  benefits  implications  of  key  safety 
measures are not clearly presented. 

(3) The comparison of options is not sufficiently 
detailed  and  nuanced,  including  in  terms  of 
coherence  with  the  ‘Vision  Zero’  road  safety 
policy framework. 

The packaging of the options and the trade-offs 
were  revisited  and  clarified,  and  are  further 
described under points (3), (4), and (5) below. 
The costs and benefits are now further detailed 
in  Annex  4  (e.g.  in  new  section  6)  and  better 
explained also in the comparion of options.  

The comparison, including re ‘Vision Zero’ has 
been  further  detailed  as  described  under  point 
(6) below. 

Adjustment requirements 

is, 

identified 

the  problems 

(1) The report should make clear what the scale 
including 
of 
regarding vehicles currently exempted, such as 
motorcycles, or not subject to a yearly PTI, such 
as vehicles older than 9 years. The strength and 
robustness  of  the  evidence  underpinning  the 
analysis  of  the  problems  and  impact  analysis 
and of related estimations should be made more 
explicit.  The  report  should  clarify  supporting 
assumptions when it comes to the contribution 
of  defects  in  vehicles  to  road  crashes  and  the 
link  between  road  safety  and  inspections.  The 
the  problems 
geographical  distribution  of 
identified should also be better explained, with 
clear  references  to  the  situation  in  different 
Member States. 

The scale of the problem of unsafe and polluting 
vehicles  has  been  explained  in  more  detail, 
including  geographical  details,  in  section  2.1, 
2.2  and  2.2.5.  The  level  of  confidence  in  the 
underpinning  evidence  has  been  clarified  and 
backed  by  additional  sensitivity  analysis. 
Further  details  as  regards 
the  underlying 
assumptions  and  calculations  are  described 
sections  4  and  5  of  Annex  4  (impact  on  road 
safety and emissions of individual measures and 
policy options). 

(2) The report should more clearly acknowledge 
any  uncertainties  related  to  the  evidence  and 
assumptions used, in particular in relation to the 
analysis  of  the  impacts  of  the  odometer  fraud 
measure.  A  sensitivity  analysis  should  be 
carried out to show how these limitations affect 
the  overall  cost-benefit  analysis  (looking  for 
instance  at  the  assumptions  on  the  number  of 
cars affected and the economic damage caused 
by odometer fraud).  

The  report  should  be  clearer  about 
the 
assumptions used and why different data points 
(lower bound in some cases) were selected for 
the  estimations.  It  should  also  clarify  to  what 
extent  key  assumptions  were  validated  by 
independent  experts  and  represent  the  state  of 
the  art  on  this  matter.  Similarly,  the  report 
should  clarify  the  scale  and  geographical 

The uncertainty regarding the economic damage 
caused  by  odometer  fraud  and  the  number  of 
cars affected is acknowledged in section 6.1.2.4 
and section 6.1.3. Sensitivity analysis has been 
performed on the assumptions on the economic 
damage  caused  by  odometer  fraud  and  the 
number of cars affected, and its impacts in terms 
of  overall  cost-benefit  analysis  are  reported  in 
section 7.5 and Annex 4 (section 7). 

The calculations of the costs for measure PMC6 
(Require roadworthiness certificate in electronic 
format  only)  have  been  revised  to  account  for 
the  volumes  of  inspections  per  Member  State 
instead  of  using  the  lower  bound  of  the 
estimates  provided  during  the  stakeholders 
consultation.  The  evidence  underlying 
the 
problems  and  their  drivers,  as  well  as  the 
assessment  of  impacts,  is  based  on  the  best 

77 

 
available  evidence,  including  multiple  studies 
research,  as  well  as 
involving  scientific 
thorough  consultation  with  experts.  This  has 
been further emphasised in section 2 and section 
6. Additional sensitivity analysis has also been 
performed  and  is  reported  in  section  7.5  and 
Annex 4 (section 7). 

The  scale  and  geographical  distribution  of  the 
problem of older vehicles and powered two- and 
three-wheelers  is  clarified  as  explained  above 
(1). 

Following  the  comments  received  from  the 
Board, the measure on recording the odometer 
reading  has  now  been  included  in  all  policy 
options.  In  addition,  the  mandatory  yearly 
testing for vehicles that are 10-year-old or older 
(PM6) is now included in PO1b, PO2 and PO3. 

The changes are reflected in sections 5.2. 

Following  the  observations  of  the  Board,  the 
measure in question (PM1 – roadside inspection 
of motorcycles as an alterantive to PTI) has been 
revised.  It  is  now  presented  as  a  binding 
measure,  which  indeed  corresponds  to  the 
relvant  calculations  in  terms  of  costs  and 
benefits.  The  changes  are  reflected  in  sections 
5.2, 6.1, as well as in the Annexes. 

distribution  of  the  problem  when  it  comes  to 
older  cars,  lighter  vehicles  and  mopeds  not 
being  (sufficiently)  tested  for  roadworthiness 
and the consequences of this. 

(3) The report should explain more clearly the 
reasoning  behind  the  packaging  of  options.  It 
should  clarify  why  certain  policy  measures, 
such  as  recording  the  odometer  reading  or 
registration of certificates in digital formats are 
not included in all policy packages. Given that 
the policy measure aimed at tackling odometer 
fraud  is  expected  to  bring  by  far  the  most 
significant net benefits, excluding this measure 
in  some  policy  packages  would  make  them 
underperforming  by  design.  The  report  should 
provide  a  clear  justification  why  this  key 
measure  should  not  be  included  in  the  set  of 
measures  common  for  all  options.  If  an 
exclusion can be convincingly argued, the report 
should  present  variants  for  options  1a/b 
including the odometer measure to allow a fairer 
and more balanced comparison of options. 

(4)  The  report  should  explain  the  reasoning 
behind  advocating  a  non-binding  measure  for 
the testing of powerful motorcycles, despite its 
more limited potential beneficial impact on road 
safety. The explanation should also clarify why 
a  non-binding  measure  is  considered  as  an 
adequate measure exclusively in the safety case 
of  powerful  motorcycles  but  not  for  any  other 
road safety  problem  area. When substantiating 
this  reasoning,  the  report  should  make  clear 
references  to  the  evidence  available  from 
different  Member  States  (which  are  currently 
applying a testing regime and which are not and 
what a non-binding or binding EU measure on 
this would bring) 

(5)  The  report  should  present  better  the  key 
in 
policy  choices  and  related 
particular  regarding  the  benefits  and  costs  of 

trade-offs, 

The  benefits  of  the  measures  were  indeed 
the  policy  options, 
assessed  as  part  of 
considering  also  the  synergies  between  them. 

78 

 
several key road safety measures, including the 
mandatory yearly testing for older vehicles and 
the ending of the exemptions of motorcycles and 
light  trailers.  These  measures  are  currently 
included as a bundle and assessed together only 
in  the  most  ambitious  option  package  3. 
However, 
complementary  measure-by-
measure  benefit-cost  assessment  should  allow 
the  identification  of  potentially  net  beneficial 
measures  in  terms  of  overall  reduced  fatalities 
and  injuries.  As  these  are  highly  relevant  for 
decision-making,  the  report  should  bring  them 
out more clearly. 

a 

(6) The comparison of the revised set of options 
needs  to  be  more  nuanced  and  granular.  To 
allow a more coherent effectiveness comparison 
of options the report should present one clear set 
of specific objectives avoiding overlaps with the 
general  objectives.  Regarding  coherence,  the 
report needs to demonstrate why packages 2 and 
packages  3  are  scored  the  same,  despite  the 
to 
differences  with 
significant 
contribution  to  the  Vision  Zero  road  safety 
goals.  The  comparison  overview  Table  25 
should be reworked to allow a detailed overview 
of  quantitative  and  qualitative  key  impacts,  so 
that  the  key  differences  between  the  options 
become more obvious. On this basis, the report 
should better justify the choice of the preferred 
option, while being clear on the key trade-offs 
between  options 
terms  of  efficiency, 
effectiveness and coherence.  

respect 

in 

costs,  however,  were 

Their 
individually. 

calculated 

The estimated impacts (in terms of lives saved 
and external costs savings) of the options have 
now  been  split  to  show  the  impact  of  the 
relevant individual measures. 

The  expected  cumulative  reduction  in  the 
number  of  fatalities  and  injuries  by  policy 
option  and  policy  measure  is  now  included  in 
section 5 of Annex 4. In addition, the trade-offs 
regarding the costs and benefits of those policy 
measures are presented in a new section 6 of the 
same annex. 

impacts 

In section 7, a more detailed presentation of the 
key 
(costs  and  benefits),  both 
quantifiable  and  qualitative,  has  now  been 
included. 

The  comparison  of  effectiveness  now  focuses 
on  achieving  the  specific  objectives,  while  the 
limited  differences  in  coherence  between  PO2 
and  PO3  are  also  explained  in  section  7  and 
Annex 14. 

Table  25  has  been  replaced  with  a  detailed 
overview of the key impacts as requested. 

In  section  8,  the  differences  and  trade-offs 
between  the  revised  options  are  clarified  in 
relation to the three criteria. 

4.  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, and other EU bodies. This includes:  

•  Stakeholder consultation activities (see dedicated annex);  
•  Regular  meetings  of  the  Expert  Group  on  Roadworthiness  and  Vehicle  Registration 

Documents (RWEG); 

•  External  support  studies  carried  out  by  independent  consortia  (the  study  supporting  the 
evaluation  was  led  by  VVA  and  the  one  supporting  the  impact  assessment  was  led  by 
Ricardo). The external support studies will be published alongside this report; 

•  Ad-hoc consultation of industry experts; and 

79 

 
 
 
•  The  Commission’s  own  experience  in  monitoring  and  implementing  the  Roadworthiness 

Package.

80 

 
ANNEX 2: STAKEHOLDER 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 

81 

 
criteria of relevance, effectiveness, efficiency, 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. 

•  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 

82 

 
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 29: 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 
user groups  

of 

and 

Road 
safety 
environmental 
NGOs  
Research / academia  

Citizens 

Description  

Authorities involved in different activities relating to the RWP, 
including  vehicle  registration,  inspection,  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 involved in 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.  

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

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 

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 

83 

 
 
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. 

•  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' 

84 

 
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  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. 

85 

 
•  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 
in 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. 

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

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•  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. 

•  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 

87 

 
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 4.  

Figure 5: 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 6: 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 

88 

 
 
 
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.  

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’ Associations (FEMA) argued that 

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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 7: 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 8: 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 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 

90 

 
 
 
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.  

A common argument in favour of more frequent testing for N1 vehicles, which were mentioned in 
different consultation exercises, was 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 

91 

 
 
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 
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 

92 

 
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 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 

93 

 
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 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 

94 

 
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 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 

95 

 
 
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 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’).  

96 

 
 
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  

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 

97 

 
 
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 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 

98 

 
 
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  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 

99 

 
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. 

100 

 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE 

Summary of the implementation of the preferred policy option  

The  primary  objective  of  the  initiative  is  to  improve  road  safety  in  the  European  Union,  by 
contributing  to  the  objective  of  decreasing  the  casualties  and  serious  injuries  resulting  from  road 
crashes by 50% by 2030 as an important milestone of “Vision Zero” by 2050. At the same time, the 
initiative aims to improve the environmental performance of vehicles and in this way contribute to 
cleaner air and a lower environmental footprint of the road transport sector in the EU. The preferred 
policy option will ensure that today’s and tomorrow’s road vehicles remain safe and maintain their 
approved environmental performance throughout their lifetime. It will significantly reduce tampering 
of safety-related and emission control systems as well as odometer fraud and improve data exchange 
and  cooperation  among  Member  States,  thereby  reducing  the  external  costs  generated  by  road 
transport, improving consumer protection, and facilitating the free movement of people and goods. 

The  benefits  of  the  preferred  policy  option  are  expected  to  fall  on  different  stakeholder  groups: 
citizens, vehicle owners, PTI centres, inspectors, public authorities. 

Citizens will benefit from the increased road safety on EU roads, leading to less fatalities and injuries. 
They will also benefit from healthier environment due to reductions in air pollutant emissions (NOx 
and PM) and noise emissions thanks to better detection of defective and tampered vehicles.  

Vehicle owners (businesses and citizens) will enjoy the benefits due to avoided odometer fraud. 
This will require mandatory recording and reporting to a national central database of vehicle mileage, 
whenever a vehicle undergoes repair/maintenance or in the case of tyre changes/replacement. It will 
help reduce odometer fraud in both, domestic sales of used vehicles as well as in cross-border sales. 
Additional benefits for vehicle owners will come from avoiding emission testing at PTI in case the 
vehicle passed a roadside inspection or was found to be in line with the applicable emission limits 
during a screening by remote sensing. They are also expected to save costs related to the recognition 
of PTI certificates in other Member States (for up to 6 months), as a result of avoided travel costs. 

Measures  involving  an  extension  of  vehicle  scope  or  increase  in  testing  frequency  for  particular 
vehicle  categories  will  require  additional  inspections  and  will  lead  in  increase  of  employment  of 
vehicle inspectors. Benefits are expected also from the additional training for the inspectors that will 
have to deliver the new testing methods. Adapting PTI methods to the testing of electric vehicles, 
including the training of inspectors, will also provide a safer workplace for vehicle inspectors. 

PTI centres will benefit from more frequent emission testing of light commercial vehicles and from 
the  mandatory  yearly  testing  for  vehicles  that  are  10-year-old  or  older.  They  will  also  enjoy  cost 
savings due to new data governance measure and access to relevant technical information. 

National  administrations  are  expected  to  benefit  from  significant  cost  savings  due  to  the 
introduction of roadworthiness certificate in electronic format and the interlinking of national vehicle 
registers. As regards roadworthiness certificates, they should become mandatory in electronic format 
and  gradually  replace  the  paper  and  smartcard  format.  This  would  bring  savings  to  national 
authorities  as  they  would  avoid  the  costs  of  printing,  distribution,  and  handling  of  paper/plastic 
registration certificates. Additional saving should come from transition to issuing digital registration 
certificates instead of paper ones. They can also expect cost savings due to the time saved for the re-
registration of a vehicle in another Member State. 

101 

 
The costs of the measures included in the preferred policy option are expected to fall on different 
stakeholder groups: national public authorities, periodic technical inspection (PTI) centres, vehicle 
repair shops, garages, vehicle owners (citizens and businesses). 

National  public  authorities  will  face  one-off  adjustment  costs  linked  to  setting  up  a  database  for 
recording odometer history of the vehicles registered in their territory, the interconnection of national 
vehicle registers, adding new data elements to the registers and introducing remote sensing, which 
requires the purchase and installation of new  roadside equipment as well as a monitoring system. 
They  will  also  face  additional  administrative  costs  due  to  an  increased  number  of  roadside 
inspections. 

PTI centres will face adjustment costs linked to updated and new test requirements, and an increased 
number of tests  will  require  additional investments  in  equipment, testing  capacity and training of 
inspectors. It is however expected that PTI centres will be able to recover the additional costs through 
the additional business opportunities (increased number of tests) and in some cases (depending on 
the Member State) through somewhat increased PTI charges (this aspect could not be quantified). 

Vehicle repair shops, motor vehicle dealers and other garages will face additional administrative costs 
due to the requirement for Member States to set up a system to record odometer readings from the 
cars and vans registered in their territory. This includes one-off costs for software updates, to allow 
them to transfer their data to the central national database, and recurrent costs for the maintenance of 
the software and the time spent for recording the odometer readings. 

Automobile manufacturers will face administrative costs related to the setting up of a governance 
framework for providing access to in-vehicle data necessary to carry out PTI and RSI to inspection 
centres and competent authorities. The costs are due to the adjustments to their IT systems to ensure 
access to the relevant data, and maintenance costs.  

Some vehicle owners will also face additional costs due to the extension of the scope or frequency of 
PTI  and  roadside  inspections.  Vehicle  owners  may  also  face  administrative  costs  related  to  the 
roadworthiness  test  following  any  significant  modification  that  could  affect  safety  or  the 
environmental  performance  of  the  vehicle.  Due  to  new  testing  requirements  regarding  safety,  air 
pollutant emissions and noise, some vehicle owners will incur repair costs to ensure that their vehicles 
can pass the PTI inspection and remain in use. The regular inspection of cargo securing will lead to 
recurrent administrative costs for businesses vehicle owners.  

2.  SUMMARY OF COSTS AND BENEFITS 

I. Overview of Benefits (total for all provisions) – Preferred Option (PO2) 

Description 

Amount 

Comments 

Direct benefits 

EUR 5.23 billion 

costs 
Administrative 
savings for Member States 
administrations,  expressed 
as  present  value  over 
2026-2050,  relative  to  the 
baseline 

102 

to 

issuing 

Administrative  cost  savings  for  national 
administrations  due 
the 
roadworthiness  certificates  in  electronic 
format  only,  the  interlinking  of  national 
vehicle  registers,  the  time  saved  for  the 
re-registration  of  a  vehicle  in  another 
Member  State,  and  due  to  avoiding  the 
costs  of  printing,  distribution  and 
handling  of  paper/plastic  registration 
certificates,  estimated  at  EUR  5.23 
billion,  expressed  as  present  value  over 

 
I. Overview of Benefits (total for all provisions) – Preferred Option (PO2) 

Description 

Amount 

Comments 

Administrative costs 
savings for businesses 
(PTI centres), expressed 
as present value over 
2026-2050, relative to the 
baseline 

Benefits for businesses 
(PTI centres) from 
additional technical 
inspections, expressed as 
present value over 2026-
2050, relative to the 
baseline 

Administrative costs 
savings for other 
businesses (vehicle 
owners) expressed as 
present value over 2026-
2050, relative to the 
baseline 

Benefits for other 
businesses (vehicle 
owners) due to avoided 
odometer fraud 

Adjustment costs savings 
for citizens (vehicle 
owners) expressed as 
present value over 2026-
2050, relative to the 
baseline 

Administrative costs 
savings for citizens 
(vehicle owners) 
expressed as present value 
over 2026-2050, relative 
to the baseline 

EUR 1.64 billion 

EUR 39.10 billion 

EUR 1.29 billion 

EUR 118.34 billion 

EUR 2.14 billion 

EUR 591.9 million 

103 

2026-2050. 

Administrative  costs  savings  for  PTI 
centres  due  to  the  access  to  relevant 
technical  information  (data  governance) 
estimated at EUR 1.64 billion, expressed 
as present value over 2026-2050. 

from 

additional 

Benefits 
periodic 
technical inspections for PTI centres due 
to the extension of scope of PTI and more 
testing  of  certain  vehicle 
frequent 
categories, 
the  yearly 
including  for 
testing of vehicles that are 10-year-old or 
older.  Estimated  at  EUR  39.10  billion 
expressed  as  present  value  over  2026-
2050. 

Administrative  costs  savings  for  other 
businesses  (vehicle  owners)  due  to  the 
possibility  to  avoid  emission  testing  at 
PTI in case the vehicle passed a roadside 
inspection  or  was  in  line  with 
the 
emission  limits  during  a  screening  by 
are 
remote 
estimated at EUR 1.29 billion, expressed 
as present value over 2026-2050.  

sensing.  The 

savings 

Benefits  for  other  businesses  (vehicle 
owners) due to mandatory recording and 
reporting to a national central database of 
vehicle  mileage,  whenever  a  vehicle 
undergoes  repair/maintenance  or  in  the 
case  of  tyre  changes/replacement  which 
helps reducing odometer fraud, estimated 
at  EUR  118.34  billion,  expressed  as 
present value over 2026-2050.  

Adjustment cost savings for citizens due 
to  the  recognition  of  PTI  certificates 
issued  by  a  Member  State  other  than 
Member State of registration of up to six 
months, as a result of avoided travel costs 
back to the country of vehicle registration 
for a PTI. Estimated at EUR 2.14 billion 
relative  to  the  baseline  (expressed  as 
present value over 2026-2050). 

Administrative costs savings for citizens 
due  to  not  requiring  emission  testing  at 
PTI  after  the  vehicle  has  successfully 
passed  a  screening  by  remote  sensing, 
estimated  at  up  to  EUR  591.9  million, 
expressed  as  present  value  over  2026-
2050. 

 
I. Overview of Benefits (total for all provisions) – Preferred Option (PO2) 

Description 

Amount 

Comments 

Benefits for citizens 
(vehicle owners) due to 
avoided odometer fraud 

EUR 65.67 billion 

Improvement in the 
functioning of the internal 
market 

Benefits for citizens and 
administration due to 
‘digital by default’ 

Increase in employment of 
PTI and RSI inspectors, 
relative to the baseline 

PTI inspectors: 18,752 additional full-time 
inspectors in 2030 and 20,107 in 2050, 
relative to the baseline 

RSI inspectors: 204 additional full-time 
inspectors in 2030 and 243 in 2050, relative 
to the baseline 

104 

Benefits due to the obligation for Member 
States  to  record  odometer  readings  in  a 
national  database,  as  well  as  to  make 
them available to other Member States in 
the case of a re-registration of a vehicle in 
order 
fraud. 
Estimated  at  around  EUR  65.67  billion, 
expressed  as  present  value  over  2026-
2050. 

reduce  odometer 

to 

to 

the 

related 

improving 

frequency  of 

information,  making 

Positive impact on the functioning of the 
internal market is expected due to the the 
the 
measures 
availability  and  exchange  of  vehicle-
related 
the 
roadworthiness  certificate  available  in 
electronic  format,  harmonising  testing 
methods, 
testing, 
requirements for the improvement of the 
PTI and the scope of testing. Harmonising 
vehicle  registration  documents  across 
Member  States  will  help  to  verify  the 
vehicle's 
its 
characteristics, 
registration status in the country of origin. 
This  can  help  addressing  potential 
obstacles to re-registration in another EU 
Member  State  where  the  vehicle  is 
registration 
reported 
certificate 
of  being 
fraudulent.  

its 
suspected 

stolen,  or 

and 

is 

The  mandatory  electronic  format  of 
roadworthiness certificates should have a 
positive impact on digital transformation 
in  the  EU.  For  the  process  of  re-
registration, it will save time and costs for 
authorities and citizens by moving away 
from  information  and  data  exchange  via 
e-mail,  which  is  less  efficient  and  time 
consuming.  A 
registration 
certificate  should  help  reduce  time  and 
costs  for  authorities  and  citizens  by 
making  access  and  exchange  of  the 
relevant information easier, faster. 

digital 

The  preferred  policy  option  will  lead  to 
additional  inspections  and  the  need  for 
additional  inspectors  PTI  and  RSI  to 
perform them due to extension of vehicle 
scope or increase in testing frequency for 
particular  vehicle  categories  (such  as 
testing  of  vans, 
annual 
mandatory yearly testing of vehicles that 
are 10-year-old or older, the noise testing 
of  motorcycles  and  extension  of  RSI  to 
vans).  In  addition,  there  will be  benefits 
from  the  additional  training  for  the 
inspectors that will be needed to be able 

emission 

 
 
 
 
I. Overview of Benefits (total for all provisions) – Preferred Option (PO2) 

Description 

Amount 

Comments 

to  deliver  the  new  testing  methods.  The 
demand  for  additional  and  new  testing 
equipment  will  lead  to  an  increase  in 
production-related  jobs  within  Member 
States.  There  will  also  be  employment 
opportunity related to providing ongoing 
maintenance 
testing 
equipment.  

the  new 

for 

Indirect benefits 

6,912 lives saved and 64,885 serious injuries 
avoided 

Reduction in the number 
of fatalities and serious 
injuries relative to the 
baseline (cumulative over 
2026-2050) 

Reduction in external 
costs of accidents 
(fatalities and injuries), 
expressed as present value 
over 2026-2050, relative 
to the baseline 

Reduction  of  air  pollutant 
emissions  (kilo  tonnes  of 
NOx  and  PM2.5  avoided) 
(cumulative  over  2026-
2050) 

EUR 74.2 billion 

Air pollutants reduction: 3,969 kilo-tonnes of 
NOx and 199 kilo-tonnes of PM 

to  society  at 

Indirect  benefit 
large. 
Significant positive effects on road safety 
are  expected,  in  particular  due  to  to  the 
more  effective  identification  of  vehicles 
with major and dangerous defects in the 
fleet, which should lead to the reduction 
of  road  crashes  caused  by  technical 
defects  and,  as  a  result,  to  reduced 
fatalities  and  injuries.  Measures  which 
implementation  and 
relate 
to  better 
roadworthiness 
the 
enforcement  of 
legislation  will  also  contribute.  The 
impacts are estimated at 6,912 lives saved 
and 64,885 serious injuries avoided over 
the 2026-2050, relative to the baseline. 

in 

Indirect benefit to society at large, due to 
the lives saved and injuries avoided. The 
reduction 
the  external  costs  of 
accidents  is  estimated  at  EUR  74.2 
billion,  expressed  as  present  value  over 
the  2026-2050  horizon  (in  2022  prices) 
relative to the baseline. 

positive 

to  society  at 
effects 

large 
Indirect  benefit 
Significant 
on 
environment  are  expected,  due  to  the 
measures  having  an 
impact  on  air 
pollutant  emissions  and  targeted  at  high 
emitters of NOx and particulate matter in 
the  vehicle  fleet,  which  should  be 
effectively  identified  and  repaired,  with 
impact  on  air 
expected  cumulative 
pollutants reduction 3,969 kilo-tonnes of 
NOx  and  199  kilo-tonnes  of  PM  over 
2026-2050. 

Reduction in the external 
costs of air pollutant 
emissions relative to the 
baseline, expressed as 
present value over 2026-
2050 

EUR 76.1 billion 

Indirect benefit to society at large, due to 
the  reduced  air  pollutant  emissions.  The 
reduction  in  the  external  costs  of  air 
pollution  is  estimated  at  EUR  76.1 
billion,  expressed  as  present  value  over 
the  2026-2050  horizon  (in  2022  prices) 
relative to the baseline. 

Reduction  in  the  external 
costs  of  noise  emissions 

EUR 7.3 billion 

Indirect benefit to society at large, due to 
reduced  noise  emissions.  The 
the 

105 

 
 
I. Overview of Benefits (total for all provisions) – Preferred Option (PO2) 

Description 

Amount 

Comments 

relative  to  the  baseline, 
expressed as present value 
over 2026-2050 

reduction  in  the  external  costs  of  noise 
pollution is estimated at EUR 7.3 billion, 
expressed as present value over the 2026-
2050 horizon (in 2022 prices) relative to 
the baseline. 

II. Overview of costs – Preferred option (PO2) 

Citizens/Consumers 

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Direct adjustment costs 
(expressed as present value 
over 2026-2050, relative to 
the baseline) 

Direct administrative costs 
(expressed as present value 
over 2026-2050, relative to 
the baseline) 

Direct regulatory fees and 
charges 

Direct enforcement costs 
(expressed as present value 
over 2026-2050, relative to 
the baseline) 

Indirect costs 

- 

- 

- 

- 

- 

For 
national 
public 
authorities: 
EUR 29.7 
million 

For 
national 
public 
authorities: 
EUR 77.9 
million 

For national 
public 
authorities: 
EUR 177.5 
million 

For national 
public 
authorities: 
EUR 2.31 
billion 

- 

For PTI 
centres: EUR 
3.2 billion 

For PTI 
centres: 20.1 
billion 

For citizens 
(vehicle 
owners): EUR 
13.7 billion  

For 
businesses:  
EUR 218 
million, of 
which: 
- EUR 48.9 
million for 
PTI centres 
- EUR 149.2 
million for 
garages, repair 
stations, etc. 
- EUR 20 
million for 
vehicle 
manufacturers 

For 
businesses:  
EUR 26.1 
billion, of 
which: 
- EUR 87.7 
million for 
PTI centres 
- EUR 310.8 
million for 
garages, repair 
stations, etc. 
- EUR 35.9 
million for 
vehicle 
manufacturers 
- EUR 25.7 
billion for 
other 
businesses 
(for vehicle 
owners) 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

106 

 
 
 
 
 
 
III. Application of the ‘one in, one out’ approach – Preferred option (PO2) 

[M€] 

One-off 

Recurrent 

Total 

(annualised total net present 
value over the relevant 
period) 

(nominal values per year) 

Businesses 

New administrative 
burdens (INs) 

Removed 
administrative burdens 
(OUTs) 

Net administrative 
burdens 

Adjustment costs 
(expressed as present 
value over 2026-2050, 
relative to the 
baseline) 

Citizens 

New administrative 
burdens (INs) 

Removed 
administrative burdens 
(OUTs) 

Net administrative 
burdens 

Adjustment costs 

Total administrative 
burdens 

EUR 25.5 million, of 
which: 
- EUR 5.7 million for the 
PTI centres 
- EUR 2.3 million for 
vehicle manufacturers  
- EUR 17.5 million for 
garages, repair stations  

EUR 26.4 million, of which:  
- EUR 4.9 million for PTI 
centres 
- EUR 2 million for vehicle 
manufacturers 
- EUR 19.5 million for garages, 
repair stations, etc. 

 EUR 51.9 million, of   
which: 

-EUR 10.6 million for 
PTI centres 
-EUR 4.3 million for 
vehicle manufacturers 
-EUR 37 million for 
garages, repair 
stations, etc. 

- 

- 

- 

EUR 25.5 million 

EUR 26.4 million 

 EUR 51.9 million 

For PTI centres: EUR 
3.2 billion 

For PTI centres: 20.1 billion 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

EUR 25.5 million 

 EUR 26.4 million 

 EUR 51.9 million 

3.  RELEVANT SUSTAINABLE DEVELOPMENT GOALS 

IV. Overview of relevant Sustainable Development Goals – Preferred Option (PO2) 
Comments 
Relevant SDG 

Expected  progress  towards  the 
Goal 

SDG 3 (Ensure healthy lives and 
promote well-being for all at all 
ages) including targets 3.6 (halving 
the number of deaths and injuries 
from road traffic accidents) and 3.9 
(by 2030, substantially reduce the 

Reduction in the number of 
fatalities and serious injuries 
relative to the baseline (cumulative 
over 2026-2050): 
6,912 lives saved and 64,885 serious 
injuries avoided 

Legislation  on  safe  vehicles  is  a  core 
element of the Safe System Approach in 
road  safety  and  a  core  principle  of  the 

107 

 
 
 
 
 
 
IV. Overview of relevant Sustainable Development Goals – Preferred Option (PO2) 
Comments 
Relevant SDG 

Expected  progress  towards  the 
Goal 

number of deaths and illnesses 
from hazardous chemicals and air, 
water and soil pollution and 
contamination) for the air pollution 
emissions. 

Reduction of air pollutant emissions 
(kilo  tonnes  of  NOx  and  PM2.5 
avoided),  cumulative  over  2026-
2050: 
air  pollutants  reduction  3,969  kilo-
tonnes  of  NOx  and  199  kilo-tonnes 
of PM 

2020  UN  “Stockholm  Declaration  on 
road safety”248 

248 https://www.roadsafetysweden.com/contentassets/b37f0951c837443eb9661668d5be439e/stockholm-declaration-

english.pdf 

108 

 
 
 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

1.  DESCRIPTION OF THE ANALYTICAL METHODS USED  

The main model used for developing the baseline scenario for this initiative is the PRIMES-TREMOVE 
transport model by E3Modelling, a specific module of the PRIMES models. The model has a successful 
record of use in the Commission's energy, transport and climate policy assessments. In particular, it has 
been used for the impact assessments underpinning the Communication on a 2040 climate target249, the “Fit 
for 55” package250, the impact assessments accompanying the 2030 Climate Target Plan251 and the Staff 
Working  Document  accompanying  the  Sustainable  and  Smart  Mobility  Strategy252,  the  Commission’s 
proposal for a Long Term Strategy253 as well as for the 2020 and 2030 EU’s climate and energy policy 
framework. In addition, building on the PRIMES-TREMOVE model results, the baseline projections for 
the number of periodic technical inspections (PTI) have been developed by Ricardo et al. in the context of 
the impact assessment support study254.  

For the assessment of the impacts of the policy options, the PRIMES-TREMOVE model has been used for 
quantifying the impacts on the number of fatalities and injuries, as well as the impacts on the air pollutant 
and noise emissions. An Excel-based tool has been additionally developed in the context of the impact 
assessment support study, to quantify the impacts on costs and costs savings. The Excel-based tool draws 
on the Standard Cost Model. The proposed measures are assumed to be implemented from 2026 onwards, 
so that the assessment has been undertaken for the 2026-2050 period and refers to EU27. Costs and benefits 
are expressed as present value over the 2026-2050 period, using a 3% discount rate. 

PRIMES-TREMOVE model  

The PRIMES-TREMOVE transport model projects the evolution of demand for passengers and freight 
transport,  by  transport  mode,  and  transport  vehicle/technology,  following  a  formulation  based  on 
microeconomic  foundation  of  decisions  of  multiple  actors.  Operation,  investment  and  emission  costs, 
various policy measures, utility factors and congestion are among the drivers that influence the projections 
of the model. The projections of activity, equipment (fleet), usage of equipment, energy consumption and 
emissions (and other externalities) constitute the set of model outputs.  

The PRIMES-TREMOVE transport model can therefore provide the quantitative analysis for the transport 
sector in the EU, candidate and neighbouring countries covering activity, equipment, energy and emissions. 
The model  accounts  for  each  country  separately  which means that the detailed long-term outlooks  are 
available both for each country and in aggregate forms (e.g. EU level). 

In  the  transport  field,  PRIMES-TREMOVE  is  suitable  for  modelling  soft  measures  (e.g.  eco-driving, 
labelling); economic measures (e.g. subsidies and taxes on fuels, vehicles, emissions; ETS for transport 
when linked with PRIMES; pricing of congestion and other externalities such as air pollution, accidents and 
noise; measures supporting R&D); regulatory measures (e.g. CO2 emission performance standards for new 
light  duty  vehicles  and  heavy  duty  vehicles;  EURO  standards  on  road  transport  vehicles;  technology 
standards  for  non-road  transport  technologies,  deployment  of  Intelligent  Transport  Systems)  and 

249 EUR-Lex - 52024DC0063 - EN - EUR-Lex (europa.eu) 
250 Delivering the European Green Deal | European Commission (europa.eu) 
251 SWD(2020)176 final. 
252 EUR-Lex - 52020SC0331 - EN - EUR-Lex (europa.eu)  
253 Source: 2050 long-term strategy (europa.eu)   
254 Ricardo et al. (2024), Impact assessment support study on the directives of the roadworthiness package, Contract no. 
MOVE/C2/SER/2022-583/SI2.895928, under FWC no. MOVE/2022/OP/0001 

109 

 
 
infrastructure  policies  for  alternative  fuels  (e.g.  deployment  of  refuelling/recharging  infrastructure  for 
electricity, hydrogen, LNG, CNG). Used as a module that contributes to the PRIMES energy system model, 
PRIMES-TREMOVE can show how policies and trends in the field of transport contribute to economy-
wide trends in energy use and emissions. Using data disaggregated per Member State, the model can show 
differentiated trends across Member States.  

The  PRIMES-TREMOVE  has  been  developed  and  is  maintained  by  E3Modelling,  based  on,  but 
extending features of, the open source TREMOVE model developed by the TREMOVE255 modelling 
community.  Part  of  the  model  (e.g.  the  utility  nested  tree)  was  built  following  the  TREMOVE 
model.256 Other parts, like the component on fuel consumption and emissions, follow the COPERT 
model. 

Data inputs 

The main data sources for inputs to the PRIMES-TREMOVE model, such as for activity and energy 
consumption, come from EUROSTAT databases and from the Statistical Pocketbook "EU transport 
in figures257. Excise taxes are derived from DG TAXUD excise duty tables. Other data comes from 
different sources such as research projects (e.g. TRACCS and New Mobility Pattern projects) and 
reports. 

In the context of this exercise, the PRIMES-TREMOVE transport model is calibrated to 2005, 2010 and 
2015 historical data. Available data on 2020 market shares of different powertrain types has also been taken 
into account. 

2.  BASELINE SCENARIO 

In  order  to  reflect  the  fundamental  socio-economic,  technological  and  policy  developments,  the 
Commission  prepares  periodically  an  EU  Reference  Scenario  on  energy,  transport  and  GHG 
emissions.  The  socio-economic  and  technological  developments  used  for  developing  the  baseline 
scenario for this impact assessment build on the latest “EU Reference scenario 2020”258. The same 
assumptions  have  been  used  in  the  policy  scenarios  underpinning  the  impact  assessments 
accompanying the “Fit for 55” package259.  

255 https://www.tmleuven.be/en/navigation/TREMOVE   
256 Several model enhancements were made compared to the standard TREMOVE model, as for example: for the number 
of  vintages  (allowing representation  of  the  choice  of  second-hand  cars);  for  the  technology  categories  which  include 
vehicle types using electricity from the grid and fuel cells. The model also incorporates additional fuel types, such as 
biofuels  (when  they  differ  from  standard  fossil  fuel  technologies),  LPG,  LNG,  hydrogen  and  e-fuels.  In  addition, 
representation of infrastructure for refuelling and recharging are among the model refinements, influencing fuel choices. 
A major model enhancement concerns the inclusion of heterogeneity in the distance of stylised trips; the model considers 
that  the  trip  distances  follow  a  distribution  function  with  different  distances  and  frequencies.  The  inclusion  of 
heterogeneity was found to be of significant influence in the choice of vehicle-fuels especially for vehicles-fuels with 
range limitations. 
257 EU transport in figures: Statistical Pocketbook - European Commission (europa.eu) 
258 EU Reference Scenario 2020 (europa.eu)  
259 Policy scenarios for delivering the European Green Deal (europa.eu) 

110 

 
 
Main assumptions of the Baseline scenario 

The main assumptions related to economic development, international energy prices and technologies are 
described below. 

Economic assumptions  

The modelling work is based on socio-economic assumptions describing the expected evolution of the 
European society. Long-term projections on population dynamics and economic activity form part of the 
input  to  the  model  and  are  used  to  estimate  transport  activity,  particularly  relevant  for  this  impact 
assessment.  
Population  projections  from  Eurostat260  are  used  to  estimate  the  evolution  of  the  European 
population,  which  is  expected  to  change  little  in  total  number  in  the  coming  decades.  The  GDP 
growth projections are from the Ageing Report 2021261 by the Directorate General for Economic and 
Financial Affairs, which are based on the same population growth assumptions. 

Table 30: Projected population and GDP growth per Member State 

Population 

GDP growth 

EU27 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

2020 

447.7 

8.90 

11.51 

6.95 

4.06 

0.89 

10.69 

5.81 

1.33 

5.53 

67.20 

83.14 

10.70 

9.77 

4.97 

60.29 

1.91 

2.79 

0.63 

0.51 

17.40 

37.94 

10.29 

19.28 

5.46 

2.10 

2025 

449.3 

9.03 

11.66 

6.69 

3.94 

0.93 

10.79 

5.88 

1.32 

5.54 

68.04 

83.48 

10.51 

9.70 

5.27 

60.09 

1.82 

2.71 

0.66 

0.56 

17.75 

37.57 

10.22 

18.51 

5.47 

2.11 

2030 

449.1 

9.15 

11.76 

6.45 

3.83 

0.96 

10.76 

5.96 

1.31 

5.52 

68.75 

83.45 

10.30 

9.62 

5.50 

59.94 

1.71 

2.58 

0.69 

0.59 

17.97 

37.02 

10.09 

17.81 

5.44 

2.11 

2020-‘25 

2026-‘30 

0.9% 

0.9% 

0.8% 

0.7% 

0.2% 

0.7% 

1.6% 

2.0% 

2.2% 

0.6% 

0.7% 

0.8% 

0.7% 

1.8% 

2.0% 

0.3% 

1.4% 

1.7% 

1.7% 

2.7% 

0.7% 

2.1% 

0.8% 

2.7% 

1.1% 

2.1% 

1.1% 

1.2% 

0.8% 

1.3% 

0.6% 

1.7% 

2.0% 

1.7% 

2.6% 

1.2% 

1.0% 

0.7% 

0.6% 

2.6% 

1.7% 

0.3% 

1.9% 

1.5% 

2.0% 

4.1% 

0.7% 

2.4% 

0.8% 

3.0% 

1.7% 

2.4% 

260 EUROPOP2019 population projections: Eurostat - Data Explorer (europa.eu)   
261  The  2021  Ageing  Report :  Underlying  assumptions  and  projection  methodologies  The  2021  Ageing  Report: 
Underlying Assumptions and Projection Methodologies | European Commission (europa.eu)   

111 

 
 
  
 
Spain 

Sweden 

Population 

GDP growth 

2020 

47.32 

10.32 

2025 

48.31 

10.75 

2030 

48.75 

11.10 

2020-‘25 

2026-‘30 

0.9% 

1.4% 

1.6% 

2.2% 

Beyond the update of the population and growth assumptions, an update of the projections on the sectoral 
composition of GDP was also carried out using the GEM-E3 computable general equilibrium model. These 
projections take into account the potential medium- to long-term impacts of the COVID-19 crisis on the 
structure  of  the  economy,  even  though  there  are  inherent  uncertainties  related  to  its  eventual  impacts. 
Overall, conservative assumptions were made regarding the medium-term impacts of the pandemic on the 
re-localisation of global value chains, teleworking and teleconferencing and global tourism. 

International energy prices assumptions  

Alongside socio-economic projections, transport modelling requires projections of international fuel 
prices. The table below shows the oil prices assumptions of the baseline and policy options of this 
impact assessment, that draw on the modelling underpinning the REPowerEU package262.  

Table 31: Oil prices assumptions  
Oil 

2015 

in $'15 per boe 

in €'15 per boe 

Technology assumptions 

2020 

2030 

2040 

2050 

52.3 

47.2 

39.8 

35.8 

92.1 

83.0 

97.4 

87.8 

117.9 

106.3 

Modelling scenarios is highly dependent on the assumptions on the development of technologies, 
both in terms of performance and costs. For the purpose of the impact assessments related to the “Fit 
for 55” policy package, these assumptions have been updated based on a rigorous literature review 
carried out by external consultants in collaboration with the JRC and consulted with stakeholders263. 
In addition, the technology assumptions for heavy duty vehicles have been updated in the context of 
the work on the impact assessment accompanying the revision of the HDV CO2 standards Regulation264. 
The same assumptions have been used in the context of this impact assessment. 

Policies in the Baseline scenario  

The EU Reference scenario 2020 (REF2020) is the starting point for the impact assessment of this 
initiative.  The  REF2020  takes  into  account  the  impacts  of  the  COVID-19  pandemic  that  had  a 
significant impact on the transport sector. More detailed information about the preparation process, 
assumptions, and results are included in the Reference scenario publication265. Building on REF2020, 
the baseline has been designed to include the initiatives of the ‘Fit for 55’ package proposed by the 
Commission  on  14 July  2021266  and  the  initiatives  of  the  RePowerEU  package  proposed  by  the 
Commission on 18 May 2022267. The baseline scenario factors in the revision of the HDV CO2 standards 

262 SWD(2022)230 final. 
263 EU Reference Scenario 2020 (europa.eu)  
264 SWD(2023) 88 final 
265 EU Reference Scenario 2020 (europa.eu)  
266 https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/delivering-european-green-deal_en 
267 https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131  

112 

 
 
  
 
Regulation268 and the new Euro 7 standards269,270, the proposed end-of-life vehicles (ELV) Regulation271,272 
and the forthcoming initiative on fair and non-discriminatory access to in-vehicle data273, as well as other 
initiatives part of the Road Safety package274 and the Greening Freight package275.  

The  baseline  scenario  assumes  no  further  EU  level  intervention  beyond  the  current  Roadworthiness 
Package (i.e., the PTI and the RSI Directives as amended by the delegated Regulations to align with 
the evolution of type-approval legislation276 and to introduce the testing of eCall at PTI277, and the 
VRD Directive as last amended by the revision of the Eurovignette Directive278). As some of the 
provisions of the RWP allowed for a very long transition period279, certain Member States are still 
notifying transposition measures to the Commission. In addition, the baseline reflects the introduction 
of PN measurement by three Member States280.  

The baseline also incorporates foresight megatrends281 and developments captured in the 2022 Strategic 
Foresight Report282. Among others, it captures the trend of increasing demand for transport as population 
and living standards grow as well as the links between the digital and green transition. In particular, the 
projected transport activity draws on the long-term population projections from Eurostat and GDP growth 
from the Ageing Report 2021283 by the Directorate General for Economic and Financial Affairs. 

Baseline scenario results 

Transport activity projections. In the baseline scenario, EU transport activity is projected to grow post-2020, 
following the recovery from the COVID pandemic. Road transport would maintain its dominant role within 
the EU by 2050. Road passenger transport activity (expressed in passenger-kilometres)284 is projected to 
grow by 10% between 2015 and 2030 (27% for 2015-2050), while road freight transport activity (expressed 

268 Regulation (EU) 2024/1610. 
269 COM(2022) 586 final.   
270 Taking into account the expected effects of the Euro 7, based on the Commission’s proposal, the currently dominant 
Euro 5/V and 6/VI vehicles should be gradually replaced by new ones complying with the Euro 7 standard. This would 
result in reduced levels of tampering and lower emissions, in particular for heavy-duty vehicles. A limitation to mention 
here is that the baseline reflects the Commission proposal. Following the changes by the co-legislators, the baseline likely 
overestimates the reduction in the air pollution emissions over time and thus slightly underestimates the contribution of 
this initiative to the air pollution emissions reduction. This is particularly relevant in the short to medium term. In the 
medium to long term this is less relevant due to the expected large-scale penetration of the zero-emission vehicles in the 
fleet.  
271 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52023PC0451  
272  The  proposal  for  a  Regulation  on  end-of-life  vehicles  (ELV)  (COM(2023)  451  final)  calls  for  data  related  to  the 
reasons of deregistering vehicles to be recorded in the national vehicle registers (see Recital 86).  
273 According to current plans, the proposal on access to in-vehicle data would provide for non-discriminatory access to 
such  data  in  a  harmonised,  machine-readable  format.  This  will  be  key  for  vehicle  inspection  too,  without,  however, 
specifying the means of data access, which will continue to allow manufacturers to set their own (often cumbersome) 
rules. 
274 Proposal for a Directive amending the Driving Licence Directive, proposal for a Directive amending the Cross-Border 
Enforcement Directive and proposal for a Directive on the Union-wide effect of certain driving disqualifications. 
275 Green Deal: Greening freight for more economic gain with less environmental impact (europa.eu) 
276 https://eur-lex.europa.eu/eli/dir_del/2021/1717/oj and https://eur-lex.europa.eu/eli/dir_del/2021/1716/oj  
277 https://eur-lex.europa.eu/eli/reg/2015/758/oj  
278 Directive (EU) 2022/362 amending Directives 1999/62/EC, 1999/37/EC and (EU) 2019/520, as regards the charging 
of vehicles for the use of certain infrastructures, https://eur-lex.europa.eu/eli/dir/2022/362/oj  
279 For example, PTI for motorcycles (with a possibility for exemptions) since January 2022; the deadline to equip all test 
centres with all the required equipment was 20 May 2023 (five years after the date of application). 
280 Belgium, Germany and the Netherlands. 
281 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore  
282 COM(2022) 289 final. 
283 doi:10.2765/733565. 
284 Covering passenger cars, buses and coaches and power-two wheelers.  

113 

 
 
in tonne-kilometres)285 by 27% during 2015-2030 (52% for 2015-2050). Rail transport activity is projected 
to grow significantly faster than for road, driven in particular by the completion of the TEN-T core network 
by 2030 and of the comprehensive network by 2050, supported by the CEF, Cohesion Fund and ERDF 
funding, but also by measures of the ‘Fit for 55’ package286 and the Greening Freight package. Passenger 
rail activity is projected to go up by 37% by 2030 relative to 2015 (86% for 2015-2050). Freight rail traffic 
would increase by 50% by 2030 relative to 2015 (107% for 2015-2050).  

Zero-emission vehicles. The share of zero-emission vehicles in the light duty vehicle fleet (passenger cars 
and  light  commercial  vehicles)  is  projected  at  15%  in  2030,  going  up  to  95%  in  2050  in  the  baseline 
scenario, while for heavy duty vehicle fleet (buses and coaches, and heavy goods vehicles) at 6% in 2030 
and 72% in 2050. These developments are driven by the CO2  standards Regulations, supported by the 
Alternative Fuels Infrastructure Regulation.  

High-emitting vehicles. The current limitations of the emission testing methods applied under the PTI 
and RSI Directives are expected to persist in the baseline scenario, with the shares of high-emitting 
vehicles287 in the Euro 5/V and Euro 6/VI fleet remaining largely the same. On the other hand, the 
share of high-emitting vehicles in the Euro 7 fleet is expected to be lower than for Euro 5/V and Euro 
6/VI. The shares of high-emitting vehicles are further discussed in the section below.  

Air  pollution  and  CO2  emissions  projections.  The  uptake  of  zero-emission  vehicles  and  the 
penetration of Euro 7 vehicles in the fleet, combined, are expected to result in significant reductions 
of  the  air  pollution  emissions  from  road  transport  in  the  baseline  scenario.  NOx  emissions  are 
projected to reduce by 52% in 2030 relative to 2015 (98% reduction for 2015-2050), while particulate 
matter (PM2.5) emissions would decrease by 43% in 2030 relative to 2015 (98% reduction for 2015-
2050). CO2 emissions from road transport are projected to decrease by 32% by 2030 relative to 2015, 
and be close to zero by 2050, thanks to the large-scale uptake of zero-emission vehicles and some 
use of renewable and low-emission fuels. 

Projected  number  of  fatalities  and  injuries.  In  the  baseline  scenario,  the  number  of  fatalities  is 
projected to decrease by 24% by 2030 relative to 2015 and by 31% by 2050 relative to 2015288. The 
number of serious and slight injuries is projected to decrease by 19% between 2015 and 2030 and by 
26% for 2015-2050. This is despite the increase in traffic over time. Relative to 2019, the number of 
fatalities would decrease by 15% by 2030 and 23% by 2050, and the number of serious injuries by 
10% by 2030 and 18% by 2050. Thus, the targets of the EU Road Safety Policy Framework 2021-
2030 – Next steps towards “Vision Zero”, of reducing the number of road deaths and the number of 
serious injuries by 50% between 2019 and 2030, would not be met. In addition, this is still far from 
the goal of the Sustainable and Smart Mobility Strategy of a close to zero death toll for all modes of 
transport in the EU by 2050. 

285 Covering heavy goods vehicles and light commercial vehicles.  
286 These measures increase to some extent the competitiveness of rail relative to road and air transport. 
287 It should be noted that there is no standard definition of a high emitter. One possible definition would be: a vehicle 
whose  average  emissions  are  at  least  2  standard  deviations  higher  than  the  average  emissions  of  the  sample  tested 
(https://pure.iiasa.ac.at/id/eprint/10156/1/XO-12-019.pdf). A pragmatic approach has been used for the analysis, making 
use of information/data provided in relevant studies, while recognising that they are not always consistent in the definition 
applied.  Furthermore, it should be noted that high emitters may be vehicles with defective emission or noise control 
systems or vehicles with tampered emissions/noise control systems. In the absence of more detailed information, a 50% 
share of defective and tampered vehicles is assumed in the total share of high emitters in the fleet. 
288 Projections refer to injuries in accidents in which a passenger vehicle (car), a light commercial vehicle (van), a bus or 
a truck, or a motorcycle is involved. 

114 

 
 
Number of periodic technical inspections and odometer fraud. In the baseline scenario, the number 
of periodic technical inspections (PTI) for LDVs, HDVs and motorcycles is projected to increase 
from 151.5 million in 2015 to 168.9 million in 2030 and 192.3 million in 2050289. For O1 and O2 
vehicles the number of inspections is projected at 7.9 million in 2030 and 8.7 million in 2050. More 
details on these projections are presented below.  

At the same time, the number of national second-hand vehicle sales with mileage fraud at EU level 
is projected at 1.63 million in 2026, 1.71 million in 2030 and 1.90 million in 2050, and that of cross 
border vehicle sales with mileage fraud at 3.18 million in 2026, 3.35 million in 2030 and 3.64 million 
in 2050. The national and cross-border odometer fraud is estimated to lead to damages for European 
consumers estimated at EUR 10.2 billion in 2026, EUR 10.7 billion in 2030 and EUR 11.7 billion in 
2050290. Expressed as present value over 2026-2050 this amounts to EUR 194.6 billion. 

Share of high emitter vehicles of air pollution emissions 

The  limitation  of  the  current  testing  methods  to  effectively  identify  vehicles  with  defective  or 
tampered emission control systems is expected to continue under the baseline scenario. As such, the 
current situation in terms of shares of high emitter vehicles and the resulting level of emissions from 
high emitters – per Euro standards and vehicle age group and Euro standard - is expected to remain 
largely the same. On the other hand, the move towards Euro 7 and the use of OBM will help reduce 
the level of tampering in comparison to Euro 5 and Euro 6. Therefore, the share of high emitters in 
the Euro 7 fleet is expected to be lower, although still increasing for older age groups.   

It should however be noted that the increase in the share of zero-emission vehicles in the fleet over 
time, will reduce the number of defective/tampered vehicles and the associated tailpipe emissions in 
the overall fleet.  

In the context of the stakeholders’ consultation, the view expressed show no firm confidence that the 
current RWP can reduce the number of vehicles with defective or tampered emission control systems 
(weighted  average  of  responses,  in  a  scale  of  1-None  at  all  to  7-Very  high,  was  3.5).  A  similar 
assessment was provided in terms of the expected contribution to reducing high emitting vehicles on 
the  road  by  technological  development  or  by  other  measures  taken  at  the  Member  State  level 
(weighted average of responses of 3.6 and 3.8, respectively). 

Data is limited but the analysis of available evidence based on remote sensing campaigns in different 
Member States has allowed to develop estimates on the shares of high emitters for different vehicle 
type and age groups. 

Information on high emitter shares for motorcycles - and more generally for L-category vehicles - is 
even  more  limited.  Data  from  PTI  in  Spain291  reveal  that  15%  of  the  deficiencies  in  L-category 
vehicles  are  related  to  nuisance,  which  includes  air  pollutant  and  noise  emissions.  However,  the 
information available does not provide the proportion of the fleet this represents. Data from Germany 
suggests that emission defects represent 0.4% of the total across the whole fleet tested. As expected, 
the percentage of defective vehicles is higher among older motorcycles (>9 years). However, in both 
cases the numbers refer to the results of PTI inspections that cannot effectively capture the occurrence 
of tampering. Hence, this is expected to underestimate the share of high emitters in the fleet. As for 

289 They are derived based on the ‘testing frequency’ and the average number of PTIs in the statistical life of a vehicle. 
290 The average cost of mileage fraud, due to higher purchase price and maintenance costs incurred, is estimated at EUR 
(https://www.car-
2,119 
pass.be/files/article_files/file/7/crm%2520study%2520final%2520report.pdf).   
291 UC3M (2019), Roadworthiness testing contribution to vehicle safety and environment. 

a  Belgian  Car-Pass 

drawing 

vehicle 

prices 

study 

2022 

per 

on 

in 

115 

 
 
motorcycles  no  data  is  currently  available  from  remote  sensing  campaigns,  in  the  baseline  it  is 
assumed that motorcycles follow the same profile as petrol Euro 5 passenger car vehicles, in terms 
of  shares  of  high  emitters  and  emissions  ratios.  This  is  considered  a  conservative  estimate  in  the 
absence of more specific data. 

The  tables  below  summarise  the  assumptions  on  the  share  of  high  emitters  and  their  respective 
emission rates in the baseline scenario. These have been assumed to remain stable over time for the 
respective vehicle groups.  

Table 32: Share (%) of M1 high emitter vehicles in the stock, by age group and Euro standard 
Diesel 
Petrol 
Euro 6 
Euro 6 

Euro 5 

Euro 7 

Euro 5 

Vehicle’s age (years) 
NOx 

PM/PN  

0-4 
5-9 
10-14 
15-19 

0-4 

5-9 

10-14 

15-19 

2.5 
5.0 
7.5 
10.0 

2.5 

5.0 

7.5 

2.5 
5.0 
7.5 
10.0 

2.5 

5.0 

7.5 

10.0 

10.0 

1.3 
3.0 
4.5 
5.0 

1.3  

3.0 

4.5 

5.0 

3.5 
6.5 
9.8 
13.0 

2.6 

5.2 

7.8 

10.4 

3.3 
6.5 
9.8 
13.0 

2.6 

5.2 

7.8 

10.4 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 33: Share (%) of N1 high emitter vehicles in the stock by age group and Euro standard 
Diesel 
Petrol 
Euro 6 
Euro 6 

Euro 5 

Euro 7 

Euro 5 

Vehicle’s age (years) 
NOx 

0-4 

5-9 

10-14 

15-19 

PM/PN 
0-4 

5-9 

10-14 

15-19 

6.0 

9.0 

12.0 

15.0 

6.0 

9.0 

12.0 

15.0 

6.0 

9.0 

12.0 

15.0 

6.0 

9.0 

12.0 

15.0 

3.0 

4.5 

6.0 

7.5 

3.0 

4.5 

6.0 

7.5 

7.8 

11.7 

15.6 

19.5 

6.2 

9.4 

12.5 

15.6 

7.8 

11.7 

15.6 

19.5 

6.2 

9.4 

12.5 

15.6 

Euro 7 

1.6 
3.3 
4.9 
6.5 

1.3 

2.6 

3.9 

5.2 

Euro 7 

3.9 

5.9 

7.8 

9.8 

3.1 

4.7 

6.2 

7.8 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 34: Shares (%) of N2/N3 and M2/M3 high emitter vehicles in the stock by Euro standard and age 

Vehicle’s age (years) 

Euro V 

Euro VI 

Euro 7 

NOx 

0-4 

5-9 

10-14 

15-19 

7.2 

8.8 

10.4 

12.0 

10.3 

12.6 

14.9 

17.2 

116 

3.6 

4.4 

5.2 

6.0 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
PM/PN 

0-4 

5-9 

10-14 

15-19 

10.3 

12.6 

14.9 

17.2 

7.2 

8.8 

10.4 

12.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 35: Shares (%) of L high emitter vehicles in stock by age 

Vehicle’s age (years) 

0-4 

5-9 

10-14 

15-19 

NOx 

3.5 

6.5 

9.7 

13.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Emission rates 

3.6 

4.4 

5.2 

6.0 

PM/PN 

2.6 

5.2 

7.8 

10.4 

The emission rate is defined as the ratio between the emission of a defective vehicle and a vehicle 
with its emission control system functioning according to the requirements.  

The values used in the baseline scenario, summarised in the table below, are based on the evidence 
available in the literature and on experts’ consultation. Valuable source of information were the DIAS 
project292, the CITA paper293, and the TNO study294.  

Table 36: Emission rates of high emitters vehicles (defective and tampered) for air pollutants by Euro standard 

Vehicle 

NOx 

M1/N1 diesel 

M1/N1 petrol 

N2/N3/M2/M3 

L3-L7 

PM/PN 

M1/N1 diesel 

M1/N1 petrol 

N2/N3/M2/M3 

L 

Euro 5/V 

Euro 6/VI 

Euro 7 

4 

6 

4 

5 

10 

5 

4 

5 

10 

10 

10 

10 

5 

10 

20 

20 

20 

50 

25 

50 

Source: Ricardo et al. (2024), Impact assessment support study 

Share of high emitter vehicles of noise emissions 

Data for motorcycles – vehicle category L – exceeding the legal noise threshold is very limited and 
does not allow to reach specific conclusions. Feedback from stakeholders suggests that the issue of 

292 DIAS (2022), D6.5 Impact assessment and guidelines for future anti-tampering regulations. 
293 CITA (2022), Monitoring of NOx emissions as part of the PTI. Position Paper. 
294  TNO  (2022),  Approaches  for  detecting  high  NOx  emissions  of  aged  petrol  cars  during  the  periodic  technical 
inspection. R10659v2. 

117 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
vehicles with defective or tampered noise control systems on the EU’s roads has not been effectively 
addressed  till  now  and  it  is  expected  to  persist.  It  was  noted  that  based  on  differences  in  the 
composition of the motorcycle fleet and the intensity of use of motorcycles between North and South 
Europe, the share of high emitters may be higher in the South. 

According to  data  from  PTI in  Spain295 around 15% of L-category vehicles tested showed major 
deficiencies related to emissions and vehicle noise. In Germany, where noise is reported separately, 
a very low share of total defects related to noise was identified (1%). However, especially in the case 
of noise tampering, PTI is considered as particularly ineffective due to the ease with which the noise 
control system can be activated or deactivated for L category vehicles. Therefore, the results from 
PTI  are  expected  to  underestimate  the  scale  of  the  problem.  The  fact  that  the  problem  is  more 
widespread than what shown at PTI is revealed by the 30% share of motorcycles with tampered noise 
control systems found by police in Bavaria, during roadside checks, during the European Bike Week 
in 2018296. 

In the baseline it is assumed that on average 30% of L-vehicles emit noise above the legal limit.  

Share of vehicles with tampered odometers  

There are limited sources of evidence in terms of the level and evolution of odometer tampering. 
According to a study commissioned by the European Parliament297, tampering rates were estimated 
between 5% and 12% of national second hand vehicles sales and between 30% and 50% of cross-
border  second  hand  vehicles  sales.  Tampering  was  found  to  be  more  common  among  vehicles 
imported in EU12 Member States, estimated in the range of 30% to 80%, in comparison to 20%-40% 
of the second hand vehicles imported in EU15 countries.  

More  recent  estimates  provided  by  CarVertical298,  based  on  analysis  of  vehicle  history  reports, 
suggest  overall  lower  odometer  fraud  rates  for  most  of  the  countries  reported  than  those  in  the 
European Parliament study. However, except for the Car-Pass system in Belgium, adopted in 2006, 
and a similar system implemented in the Netherlands, no other Member State has taken action so far. 
Both have achieved significant reduction to the level of odometer tampering – especially in relation 
to national sales, by requiring that readings are submitted after any maintenance, repair, assembly or 
inspection.  It  has  been  reported  that  odometer  tampering  has  almost  been  eliminated  (up  to  97% 
success rates)299 in Belgium, a point also supported by the Car-Pass manager during the stakeholders’ 
consultation.  Other  Member  States  (e.g.  Slovakia,  Luxembourg,  France)  are  considering  the 
introduction of relevant measures but so far no action has been taken.  

The  table  below  presents  the  estimated  shares  of  odometer  tampering  for  national  and  imported 
second hand vehicles. In the case of Member States where data is not available (cells in grey) the 
median values for EU12 and EU15 have been used. Values in  blue and italics, concerning cross-
border fraud rates, were based on the finding of the European Parliament study (also supported by 
CarVertical data) that cross border odometer fraud rates are around twice those of national odometer 

295 UC3M (2019), Roadworthiness testing contribution to vehicle safety and environment. 
296  About  motorcycles  (2018),  Police  control  Bike  Week  Faaker,  see  2018.  Retrieved  from  About  motorcycles: 
https://misfitmademotorcycles.com/police-control-bike-week-faaker-see-2018/  
297 Research for TRAN Committee - Odometer tampering: measures to prevent it (europa.eu) 
298 Overall mileage fraud analysis is available at : https://www.carvertical.com/blog/research-what-countries-have-the-
highest-percentage-of-cars-with-a-fake-mileage 
index 
(https://www.carvertical.com/transparency-index ). Specific analysis of the share of odometer tampering for national and 
imported second hand vehicles is available at : https://www.carvertical.com/blog/research-local-or-imported-cars-have-
more-mileage-rollbacks  
299 TRT (2017), Research for TRAN Committee (European Parliament) - Odometer tampering: measures to prevent it.  

the  CarVertical  Market 

transparency 

and 

in 

118 

 
 
 
fraud rates. Values in green are drawing on the data from Car-Pass for Belgium300. The same rates 
are assumed for the Netherlands.   

Table 37: National and cross-border odometer fraud rates as shares of national and cross-border second hand 
vehicle sales, respectively  

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

Cross border odometer fraud rates 
12.0% 
0.2% 
9.7% 
12.0% 
13.6% 
6.8% 
8.1% 
18.9% 
12.0% 
10.3% 
7.5% 
10.4% 
9.1% 
13.8% 
12.0% 
15.4% 
18.8% 
20.0% 
25.7% 
12.0% 
0.2% 
12.9% 
4.4% 
18.7% 
12.0% 
7.4% 
8.9% 

National odometer fraud rates 
4.0% 
0.1% 
4.9% 
4.0% 
7.1% 
3.4% 
4.1% 
7.4% 
4.0% 
3.8% 
3.8% 
3.7% 
6.8% 
9.6% 
4.0% 
5.3% 
7.3% 
10.0% 
9.2% 
4.0% 
0.1% 
5.6% 
2.2% 
5.9% 
10.0% 
3.7% 
4.5% 

Source: Ricardo et al. (2024), Impact assessment support study; Note: Values in bold are from CarVertical. Values in 
italics and blue are based on the finding of the European Parliament study (also supported by CarVertical data) that 
cross border odometer fraud rates are around twice  those of national odometer fraud rates. Cells in grey reflect the 
median values. Values in green and italics are based on data from Car-Pass for Belgium. 

There is no evidence that the fraud rates would change over time in lack of action. The input from 
stakeholders suggests that the issue of odometer tampering has not be effectively addressed up to this 
point. Respondents were rather sceptical in relation to the role of technological developments and of 
the existing roadworthiness package, but more positive on the role of national measures (weighted 
average of responses on a scale of 1-‘None at all’ to 7-‘Very high’ were 3.1, 3.6 and 4.3 respectively). 
They were even more sceptical when asked to indicate the expected contribution of technological 
developments, the existing roadworthiness package and national measures to reducing the level of 
odometer tampering in the future (weighted average of responses on a scale of 1-‘None at all’ to 7-
‘Very high’ were 3.2, 3.2 and 4.1 respectively). While recognising the possibility for action taken at 
national level by some Member States, in the baseline scenario it has been assumed that the odometer 
tampering rates will remain constant over time.  

300 Car-Pass annual report 2022 - News about Car-Pass 

119 

 
 
 
Based  on  the  projected  number  of  second  hand  vehicles  sales  and  the  fraud  rates,  the  projected 
odometer tampering for national and cross-border sales in the baseline scenario are presented in the 
tables below.  

Table 38: Odometer tampering for national sales by Member State (number of vehicles) in the baseline scenario 
2030 

2050 

2026 

2040 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
EU27 

27,663 
459 
11,023 
1,313 
54,579 
247,601 
20,920 
4,677 
28,388 
77,388 
18,869 
226,930 
12,940 
89,001 
11,869  
443,025 
18,756 
16,511 
3,733 
2,166  
1,595 
92,942 
10,552 
47,649 
135,124 
5,503 
20,755 
1,631,930  

29,082 
483 
11,589 
1,381 
57,377 
260,298 
21,993 
4,917 
29,844 
81,357 
19,836 
238,567 
13,604 
93,565 
12,478  
465,744 
19,718 
17,357 
3,925 
2,277  
1,677 
97,709 
11,093 
50,092 
142,053 
5,785 
21,819 
1,715,619  

31,537 
475 
9,047 
1,263 
60,172 
269,488 
24,297 
5,663 
23,627 
91,773 
18,836 
274,456 
12,965 
112,148 
13,847  
604,117 
22,992 
21,486 
5,245 
2,278  
1,981 
63,577 
13,362 
60,704 
130,506 
6,098 
23,834 
1,905,771  

28,931 
463 
11,114 
1,411 
59,126 
259,158 
23,783 
7,371 
30,595 
81,513 
18,401 
260,370 
18,986 
114,756 
14,412  
581,076 
22,508 
21,893 
5,221 
2,292  
1,704 
91,578 
12,903 
59,554 
140,141 
6,220 
23,287 
1,898,770  

Source: Ricardo et al. (2024), Impact assessment support study 

Table  39:  Odometer  tampering  for  cross-border  sales  by  Member  State  (number  of  vehicles)  in  the  baseline 
scenario 

AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 
FR 
HR 
HU 

2026 

124,483 
3,978 
83,946 
24,202 
98,613 
237,345 
32,862 
40,536 
127,748 
319,806 
38,438 
530,593 
37,087 
117,061 

2040 

141,915 
4,110 
68,893 
23,280 
108,719 
258,326 
38,165 
49,087 
106,320 
379,251 
38,372 
641,715 
37,159 
147,505 

2050 

130,189 
4,013 
84,640 
26,006 
106,829 
248,424 
37,359 
63,891 
137,675 
336,853 
37,485 
608,782 
54,415 
150,936 

2030 

130,867 
4,182 
88,251 
25,443 
103,670 
249,517 
34,547 
42,615 
134,299 
336,207 
40,409 
557,803 
38,989 
123,064 

120 

 
  
  
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
EU27 

2026 

53,558 
318,608 
150,151 
14,152 
28,139 
9,773 
3,419 
318,222 
51,145 
293,029 
65,211 
19,839 
49,222 
3,191,167 

2030 

56,305 
334,947 
157,851 
14,878 
29,582 
10,274 
3,594 
334,541 
53,768 
308,057 
68,555 
20,856 
51,746 
3,354,817 

2040 

62,483 
434,460 
184,061 
18,417 
39,530 
10,278 
4,245 
217,678 
64,764 
373,319 
62,983 
21,986 
56,524 
3,593,545 

2050 

65,035 
417,890 
180,185 
18,765 
39,352 
10,345 
3,651 
313,549 
62,543 
366,244 
67,633 
22,426 
55,227 
3,650,341 

Source: Ricardo et al. (2024), Impact assessment support study 

Odometer damage cost per vehicle 
Detailed analysis of the cost of odometer tampering is provided in a European Parliament study301. 
According to the study, the total damage from odometer fraud is a result of three elements, notably:  

•  Unaccounted depreciation, that results from  a car’s nominal (sales) value being higher than its 
actual market value. One of the key determinants of car price is its mileage. Cars from the same 
production year with  a higher mileage cost  less than cars with  lower mileage. Odometer fraud 
leads to a situation where part of the existing depreciation is not reflected in the value of the car 
sold.  

•  Higher maintenance costs, that result from a higher frequency of repairs needed on a car with more 

mileage. This is due to the wear of mechanical components of the vehicle. 

•  Additional  environmental  damages,  that  are  a  result  of  the  unaccounted  emissions.  Vehicle-
kilometres  missing  from  the  odometer  record  have  already  been  driven  and  the  associated 
emissions have taken place. This third element is however not considered in the analysis as this is 
not a direct cost to the user. 

Estimates on the damage from odometer fraud vary depending on vehicle size and level of mileage 
tampering.  According  to  a  Belgian  Car  Pass  study302,  the  costs  of  odometer  fraud  to  the  user, 
expressed in 2022 prices, are:  

-  For small cars: 3.4 EUR cents per missing vehicle-kilometre (vkm) for depreciation and 1.3 EUR 

cents per vkm for maintenance;  

-  For medium size cars: 5.2 EUR cents per missing vehicle-kilometre (vkm) for depreciation and 

3.2 EUR cents per vkm for maintenance;  

-  For executive/large cars: 7.7 EUR cents per missing vehicle-kilometre (vkm) for depreciation and 

3.8 EUR cents per vkm for maintenance. 

On  this  basis,  the  total  costs  per  vehicle  for  different  levels  of  odometer  tampering  (i.e.  different 
levels of mileage change) can be estimated. An weighted average per vehicle can be further derived 

301 https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf 
302 https://www.car-pass.be/files/article_files/file/7/crm%2520study%2520final%2520report.pdf  

121 

 
  
 
based on the fleet distribution by vehicle size from the baseline scenario developed with the PRIMES-
TREMOVE model for the period 2020-2050. 

Table 40: Damage costs from odometer fraud per vehicle for different levels of odometer tampering 
Tampering level (km) 

Cost category  

Vehicle size 

EUR cents 
per vkm 

Small (45% share) 

Medium (45% share) 

Executive/Large (10% share) 

Depreciation 
Maintenance 
Total 
Depreciation 
Maintenance 
Total 
Depreciation 
Maintenance 
Total 

Weighted average (in 2022 prices) 

Source: Ricardo et al. (2024), Impact assessment support study 

3.4 
1.3 

5.2 
3.2 

7.7 
3.8 

10,000 

30,000 

60,000 

90,000 

345 
128 
473 
524 
319 
843 
766 
383 
1,150 
706 

1,035 
383 
1,418 
1,571 
958 
2,529 
2,299 
1,150 
3,449 
2,119 

2,069 
766 
2,835 
3,142 
1,916 
5,058 
4,598 
2,299 
6,897 
4,239 

3,104 
1,150 
4,253 
4,713 
2,874 
7,587 
6,897 
3,449 
10,346 
6,358 

For estimating the total damage costs/costs savings from odometer fraud, the weighted average cost 
of EUR 2,119 per vehicle has been used, corresponding to tampering levels of 30,000 km, which is 
considered a conservative estimate303.  

Additional evidence was identified based on a number of sources providing estimates of the costs 
from odometer tampering, although with limited information on the assumptions used (e.g. level of 
mileage fraud, vehicle size) and, as a result, limited comparability. Nonetheless, all sources point to 
damage costs that are higher than EUR 2,000 per vehicle: 

•  According to CarVertical, tampered cars buyers spend 21% more on average for their vehicles. 
The higher price depends on many factors, such as the brand, year of manufacture, and the number 
of tampered kilometres304. The United Kingdom (29% higher price than a non-tampered car), Italy 
(29% higher price), and Lithuania (25% higher price) are among the countries where the value 
increase of tampered cars is the highest, while in Ukraine (17% higher price than a non-tampered 
car), Poland (19% higher price), and Romania (20% higher price) odometer fraud has the lowest 
impact on a car’s value. More specifically: 
-  For every 100,000 kilometres tampered, buyers overspend around EUR 2,000. 
-  There are significant differences between car brands, with price increases varying from 15 to 

27%, resulting in overspending between EUR 2,000 and EUR 10,700. 

-  The highest fake increase in value is found for Land Rover (27%), Mercedes-Benz (24%), and 
BMW  (24%)  vehicles,  while  Dacia  (15%),  Mazda  (15%),  and  Nissan  (17%)  models  are 
impacted by odometer fraud the least. 

•  According to an European Parliament study, odometer tampering has seen the mileage rolled back 
on  up  to  50%  of  second-hand  cars  traded  in  the  EU,  with  the  price  of  vehicles  fraudulently 
increasing by EUR 2,000 to 5,000 on average305.  

303 Evidence from UK (UK: average kilometers clocked on used cars with a tampered odometer by Model Year | Statista), 
suggests that the average kilometres of tampering has reduced over time with 30,000 representing an average.  
304 https://www.carvertical.com/blog/odometer-fraud-vs-car-value 
305 https://www.europarl.europa.eu/news/en/headlines/society/20180525STO04312/fighting-mileage-fraud-on-used-
cars  

122 

 
  
  
  
  
  
 
•  According to ADAC, the fraudsters increase the value by an average of EUR 3,000 per car306.  

Projected number of periodic technical inspections (PTI) 

The approach used to estimate the number of annual PTI inspections in each Member State and for 
each vehicle type draws on the ‘testing frequency’ and the average number of PTIs in the statistical 
life of a vehicle.  

The formula used is: 

Number of annual PTI inspections = Number of inspections during average life of vehicle x 
Number of registered vehicles 

EU Directive 2014/45/EU defines the minimum testing frequency that Member States must comply 
with, but in many cases the testing is more frequent, as determined by national legislation. These 
testing regimes have been identified for light duty vehicles, motorcycles, trucks, buses and coaches, 
and trailers. The key sources of information are the European Commission website307 and a 2022 
report by EReg308.  

The average vehicle life by Member State draws on ACEA309. No data was available for motorcycles 
and trailers. Thus, for these two vehicle categories, an average life of 18 years has been used. This 
defines the period over which the number of PTIs are counted to estimate the average PTI number 
during the vehicle’s life. The tables below present the testing regimes by Member State, the average 
life and the average number of inspections for each vehicle type over the vehicle’s life. 

The  annual  number  of  registered  vehicles  is  based  on  the  baseline  scenario  developed  with  the 
PRIMES-TREMOVE model.  

Table 41: Testing regime for light duty vehicle 

Member State 

Testing regime 

Average age 

Croatia 
Latvia 
Belgium 
Austria 
Bulgaria 
Sweden 
Luxembourg 
Ireland 
Netherlands 
Portugal 
Slovenia 
Spain 
Finland 
Romania 

1-1-1 
2-2-1-1 
4-1-1 
3-2-1 
3-2-1 
3-2-1 
4-2-1 
4-2-2-2-1 
4-2-2-1 
4-2-2-1 
4-2-2-1 
4-2-2-2-1 
4-2-2-2-1 
3-2-2-2-2-1 

13.0 
15.0 
10.0 
9.0 
13.0 
10.0 
8.0 
9.0 
11.0 
14.0 
11.0 
14.0 
13.0 
15.0 

Number of inspections 
during average life 
13.0 
13.0 
7.0 
6.0 
10.0 
7.0 
4.0 
3.5 
6.0 
9.0 
6.0 
8.0 
7.0 
9.0 

306 https://www.adac.de/rund-ums-fahrzeug/auto-kaufen-verkaufen/gebrauchtwagenkauf/tacho-manipulation/ 
307 https://road-safety.transport.ec.europa.eu/road-safety-member-states/roadworthiness-certificate-and-proof-test_en  
308 2022-the-vehicle-and-driver-chain.pdf (ereg-association.eu) 
309 ACEA (2023), Vehicles in use Europe 2023, https://www.acea.auto/files/ACEA-report-vehicles-in-use-europe-
2023.pdf 

123 

 
 
Member State 

Testing regime 

Average age 

Cyprus 
Estonia 
Germany 
Lithuania 
Poland 
Czechia 
Denmark 
France 
Greece 
Hungary 
Italy 
Malta 
Slovakia 

4-2-2 
4-2-2-2-1 
3-2-2 
3-2-2 
3-2-1 
4-2-2 
4-2-2 
4-2-2 
4-2-2 
4-2-2 
4-2-2 
4-2-2 
4-2-2 

13.0 
17.0 
10.0 
15.0 
15.0 
16.0 
9.0 
11.0 
17.0 
15.0 
12.0 
13.0 
14.0 

Number of inspections 
during average life 
5.5 
11.0 
4.5 
7.0 
12.0 
7.0 
3.5 
4.5 
7.5 
6.5 
5.0 
5.5 
6.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 42: Testing regime for motorcycles (no values are shown for MS that have not yet introduce a testing regime) 

Member State 

Testing regime 

Average age 

Croatia 
Latvia 
Belgium 
Austria 
Bulgaria 
Sweden 
Luxembourg 
Ireland 
Netherlands 
Portugal 
Slovenia 
Spain 
Finland 
Romania 
Cyprus 
Estonia 
Germany 
Lithuania 
Poland 
Czechia 
Denmark 
France 
Greece 
Hungary 
Italy 
Malta 
Slovakia 

1-1-1 
2-2-2 

3-2-1 
2-2-2 
4-2-2 
4-2-2 

4-2-2 
4-2-2 

2-2-2 
4-2-2 
4-2-2-2-1 
2-2-2 
3-2-2 
3-1-1 
6-4-4 

4-2-2 
4-2-2 
4-2-2 
4-2-2 

4-2-2 

18 
18 

18 
18 
18 
18 

18 
18 

18 
18 
18 
18 
18 
18 
18 

18 
18 
18 
18 

18 

Source: Ricardo et al. (2024), Impact assessment support study 

124 

Number of inspections 
during average life 
18.0 
9.0 

15.0 
9.0 
8.0 
8.0 

8.0 
8.0 

9.0 
8.0 
12.0 
9.0 
8.5 
16.0 
4.0 

8.0 
8.0 
8.0 
8.0 

8.0 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 43: Testing regime for heavy duty vehicles designed and constructed primarily for the carriage of goods, 
having a maximum mass exceeding 3.5 tonnes (N2 and N3) 

Member State 

Testing regime 

Average age 

Croatia 
Latvia 
Belgium 
Austria 
Bulgaria 
Sweden 
Luxembourg 
Ireland 
Netherlands 
Portugal 
Slovenia 
Spain 
Finland 
Romania 
Cyprus 
Estonia 
Germany 
Lithuania 
Poland 
Czechia 
Denmark 
France 
Greece 
Hungary 
Italy 
Malta 
Slovakia 

1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 

14 
14 
13 
7 
13 
13 
8 
11 
10 
16 
10 
14 
14 
19 
13 
18 
10 
10 
13 
18 
8 
9 
23 
13 
19 
13 
16 

Number of inspections 
during average life 
14.0 
14.0 
13.0 
7.0 
13.0 
13.0 
8.0 
11.0 
10.0 
16.0 
10.0 
19.0 
14.0 
19.0 
13.0 
18.0 
10.0 
10.0 
13.0 
18.0 
8.0 
9.0 
23.0 
13.0 
19.0 
13.0 
16.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 44: Testing regime for heavy duty vehicles designed and constructed primarily for the carriage of over eight 
persons and their luggage (M2 and M3) 

Member State 

Testing regime 

Average age 

Croatia 
Latvia 
Belgium 
Austria 
Bulgaria 
Sweden 
Luxembourg 
Ireland 
Netherlands 
Portugal 
Slovenia 
Spain 

1 
1-1-0.5 
1 
1 
0.5-0.5-0.5 
1 
1 
1 
1 
1-1-1… (0.5-0.5 ≥8 years) 
1-0.5-0.5 
1-1-1… (0.5-0.5 ≥5 years) 

125 

12 
14 
11 
5 
12 
7 
6 
11 
10 
15 
10 
12 

Number of inspections 
during average life 
12.0 
26.0 
11.0 
5.0 
24.0 
7.0 
6.0 
11.0 
10.0 
23.0 
19.0 
20.0 

 
Member State 

Testing regime 

Average age 

Finland 
Romania 
Cyprus 
Estonia 
Germany 
Lithuania 
Poland 
Czechia 
Denmark 
France 
Greece 
Hungary 
Italy 
Malta 
Slovakia 

1 
1-0.5-0.5 
1 
1-1-1…(0.5-0.5 ≥10 years) 
1 
1-0.5-0.5 
1 
1 
1 
0.5-0.5-0.5 
1 
1 
1 
1 
1-1-1 (0.5-0.5 ≥8 years for M3) 

12 
20 
12 
13 
8 
14 
16 
15 
8 
8 
19 
12 
14 
12 
11 

Number of inspections 
during average life 
12.0 
39.0 
12.0 
17.0 
8.0 
27.0 
16.0 
15.0 
8.0 
16.0 
19.0 
12.0 
14.0 
12.0 
15.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 45: Testing regime for trailers designed and constructed for the carriage of goods or persons, as well as for 
the accommodation of persons, having a maximum mass not exceeding 3.5 tonnes (O1 and O2) (no values are 
shown for MS that have not yet introduce a testing regime) 

Member State 

Testing regime 

Average age 

Croatia 
Latvia 
Belgium 
Austria 
Bulgaria 
Sweden 
Luxembourg 
Ireland 
Netherlands 
Portugal 
Slovenia 
Spain 
Finland 
Romania 
Cyprus 
Estonia 
Germany 
Lithuania 
Poland 
Czechia 
Denmark 
France 
Greece 
Hungary 
Italy 

3-1-1 
2-2-2 
1-1-1 
2-1-1 
1-1-1 
4-2-2 
4-2-2 

4-2-2 
1-1-1 
2-2-2 
2-2-2 
4-2-2 
1-1-1 
2-2-2 
3-2-2 
3-2-2 
4-2-2 

4-2-2 
4-2-2 

18 
18 
18 
18 
18 
18 
18 

18 
18 
18 
18 
18 
18 
18 
18 
18 
18 

18 
18 

126 

Number of inspections 
during average life 
16.0 
9.0 
18.0 
17.0 
18.0 
8.0 
8.0 

8.0 
18.0 
9.0 
9.0 
8.0 
18.0 
9.0 
8.5 
8.5 
8.0 

8.0 
8.0 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Member State 

Testing regime 

Average age 

Malta 
Slovakia 

2-2-2 
4-2-2 

18 
18 

Source: Ricardo et al. (2024), Impact assessment support study 

Number of inspections 
during average life 
9.0 
8.0 

The  projected  number  of  total  periodic  technical  inspections  for  light  duty  vehicles,  heavy  duty 
vehicles and motorcycles in the baseline scenario by Member State is provided in the table below.  

Table 46: Projected number of total periodic technical inspections for light duty vehicles, heavy duty vehicles and 
motorcycles in the baseline scenario 

Member State 

2015 

2026 

2030 

2040 

2050 

AT 
BE 
BG 
CY 
DE 
EE 
FI 
FR 
EL 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
ES 
DK 
CZ 
EU27 

4,155,271  
4,627,640  
2,939,951  
278,758  
24,143,239  
553,898  
2,137,187  
17,804,012  
3,797,487  
1,818,815  
1,748,586  
975,524  
21,787,538  
684,749  
230,981  
697,880  
144,079  
5,001,465  
21,838,488  
3,954,336  
3,837,465  
4,008,852  
704,916  
1,143,786  
18,516,367  
1,139,841  
2,828,535  
151,499,646  
Source: Ricardo et al. (2024), Impact assessment support study 

4,289,162  
4,645,244  
2,998,948  
318,686  
25,306,809  
608,122  
2,329,681  
18,516,590  
3,784,340  
1,900,904  
2,018,861  
1,123,119  
23,125,847  
772,006  
242,455  
688,124  
166,296  
5,035,101  
24,495,294  
4,263,212  
5,544,479  
4,384,731  
839,788  
1,284,672  
19,984,375  
1,267,055  
3,198,299  
163,132,202  

4,530,504  
4,717,772  
3,163,260  
344,851  
26,146,795  
646,300  
2,392,392  
18,836,560  
3,863,813  
2,061,143  
2,213,884  
1,207,534  
23,515,772  
800,382  
265,514  
685,111  
179,665  
5,392,059  
25,523,350  
4,352,909  
5,915,902  
4,426,372  
880,475  
1,400,369  
20,604,857  
1,353,595  
3,496,014  
168,917,154  

5,147,602  
4,863,174  
3,402,701  
382,206  
28,373,603  
767,699  
2,495,553  
20,515,273  
3,948,544  
2,280,267  
2,688,078  
1,361,256  
25,687,923  
954,701  
330,792  
713,317  
213,693  
6,113,987  
26,597,403  
4,466,218  
6,822,807  
4,836,699  
851,091  
1,635,656  
22,849,906  
1,435,067  
4,066,895  
183,802,112  

5,405,069  
4,804,878  
3,586,559  
418,612  
29,042,084  
887,990  
2,460,964  
21,086,208  
4,345,918  
2,639,968  
2,998,731  
1,476,122  
27,671,372  
999,994  
346,504  
788,612  
223,523  
6,092,085  
27,301,601  
4,565,840  
7,107,093  
5,059,638  
895,080  
1,716,079  
24,427,719  
1,488,357  
4,513,062  
192,349,663  

Table 47: Projected number of total periodic technical inspections for the carriage of goods or persons, as well as 
for the accommodation of persons, having a maximum mass not exceeding 3.5 tonnes (O1 and O2)  
Member State 
AT 
BE 
BG 
CY 
DE 

2040 
869,556  
251,418  
19,577  
5,758  
4,316,696  

2050 
880,200  
244,638  
20,488  
6,263  
4,279,445  

2030 
769,604  
245,555  
19,241  
5,200  
4,075,824  

2026 
725,952  
241,444  
18,653  
4,785  
3,961,968  

127 

 
Member State 
EE 
FI 
FR 
EL 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 
ES 
DK 
CZ 
EU27 

2026 
121,803  
564,199  

32,120  
225,089  

129,160  
8,166  
11,428  
30,028  
1,258  

2030 
127,946  
575,727  

34,543  
246,708  

130,008  
8,368  
12,537  
28,943  
1,406  

2040 
153,685  
600,400  

39,538  
292,630  

142,941  
9,750  
16,081  
29,596  
1,613  

2050 
181,224  
579,017  

46,621  
323,983  

153,072  
9,871  
16,879  
33,548  
1,630  

299,327  

309,885  

325,458  

326,384  

218,840  
492,039  
12,203  
126,470  
216,501  

240,811  
494,348  
12,755  
138,824  
223,033  

274,248  
541,838  
11,999  
161,484  
252,025  

281,309  
562,309  
12,573  
165,811  
260,511  

254,357  
8,570,650  

275,993  
8,661,771  

226,256  
206,773  
7,927,521  
7,648,208  
Source: Ricardo et al. (2024), Impact assessment support study 

3.  IMPACTS BY POLICY MEASURE ON COSTS AND COSTS SAVINGS 

This  section  explains  the  inputs  used  and  provides  the  assessment  of  the  impacts  of  the  policy 
measures  included  in  the  policy  options  on  costs  and  costs  savings.  The  synergies  between  the 
measures included in the options are already captured in this section.  

3.1.  PMC1 - Adapt PTI to electric and hybrid vehicles (safety, environmental performance, 

standardised data), including training of inspectors  

3.1.1.  Adjustment costs for PTI centres 

PMC1 will require PTI centres to make certain adjustments to be able to deliver PTI for electric and 
hybrid vehicles. The exact nature of the adjustments will depend on the specific requirements for the 
PTI and whether this will go beyond visual inspections. A number of stakeholders were in favour of 
visual inspections on the basis of a checklist that would not require new equipment. Others suggested 
that a specific electronic interface to support such inspection may be needed. One stakeholder (FSD 
–  the  German  PTI  agency)  provided  a  cost  estimate  of  EUR  500  for  additional  tools  to  measure 
insulation resistance and equipotential bonding. The number of PTI centres in the EU is estimated at 
48,880. Given the current small share of EVs in the fleet and in the PTI tests, it is expected that one 
such tool will be sufficient per PTI centre for the initial period (i.e., 2026), with a second one added 
in  2030.  The  one-off  adjustment  costs  are  estimated  at  EUR  24.4  million  in  2026  and  EUR  24.4 
million in 2030. Expressed as present value over 2026-2050, one-off adjustment costs are estimated 
at EUR 48.2 million (in 2022 prices) relative to the baseline.   

128 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Tailored  training  for  inspectors  that  will  deliver  such  PTI  services  will  also  be  needed  to  ensure 
correct application of test procedure and, crucially, to maximise their own safety when checking high 
voltage components. Stakeholders’ views differed as to whether the necessary training could be part 
of periodic training and the qualification examinations, most indicating that specific training would 
be needed. On the basis of the input from DEKRA – a PTI service provider – it is assumed that an 
additional  three-day  training  per  PTI  inspector  will  take  place  in  2026.  With  an  hourly  cost  for 
technicians and associate professionals (ISCO 3) of EUR 34/hour310, and assuming 7.3 working hours 
per day, a three day training for a total of 128,536 inspectors across EU is estimated at EUR 95.4 
million in 2026.  

The new PTI tests for EVs will replace emission testing for ICE, that last a few minutes, and it is 
assumed that the new test will have a similar duration. Thus, no impact on PTI duration is expected 
that could give rise to higher labour costs per PTI.  

The total adjustment costs for PTI expected as a result of this measure are summarised in the tables 
below. They are the same for all policy options.  

Table 48: One-off adjustment costs for the PTI centres due to PMC1 in 2026, 2030, 2040 and 2050 in the policy 
options (for all options) relative to the baseline (in million EUR, 2022 prices) 

Total one-off adjustment costs 

One-off costs for adapting the PTI 
One-off costs for training 

Difference to the baseline 

2026 
119.8 
24.4 
95.4 

2030 
24.4 
24.4 
0.0 

2040 
0.0 
0.0 
0.0 

2050 
0.0 
0.0 
0.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 49: One-off adjustment costs for the PTI centres due to PMC1 in the policy options, expressed as present 
value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total one-off adjustment costs 

One-off costs for adapting the PTI 
One-off costs for training 

Difference to the baseline 

PO1a 
143.6 
48.2 
95.4 

PO1b 
143.6 
48.2 
95.4 

PO2 
143.6 
48.2 
95.4 

PO3 
143.6 
48.2 
95.4 

Source: Ricardo et al. (2024), Impact assessment support study 

Depending on the Member State, the additional costs for the PTI centres may be passed through to 
vehicle owners (i.e., citizens and businesses). This will depend on how PTI charges are set by the 
Member  State:  where  prices  are  not  regulated,  it  is  likely  that  PTI  centres  will  seek  to  recover 
investment  costs,  possibly  on  a  relatively  short  term.  On  the  other  hand,  in  Member  States  that 
regulate the level of PTI charges, the evolution of those charges will depend on the public contract 
agreed  with  the  PTI  service  provider,  potentially  subject  to  renegotiation,  or  on  the  price-setting 
policy of the authority that is itself responsible for PTI. In these cases, costs may either be borne by 
the service provider/authority, or be recovered over a longer period.  

3.2.  PMC2 - Update PTI and RSI due to new requirements in General Safety Regulation and 
checking  emission  reduction  systems  (new  test  items,  including  checks  of  software 
status/integrity), by reading on-board diagnostics 

PMC2 requires to  update the PTI and RSI to  new requirements in  the General  Safety  Regulation 
(including software status/integrity of safety or emission relevant systems during PTI for all vehicles 

310 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 

129 

 
  
  
 
and  at  technical  roadside  inspections  of  commercial  vehicles),  using  ePTI  (electronic  PTI:  ISO 
20730:2021). 

3.2.1.  Adjustment costs for PTI centres  

No significant adjustment costs are expected to implement the updates due to new requirements of 
the General Safety Regulation, since ePTI uses the standard vehicle interface (OBD connector)311 
and a PTI scan tool is a mandatory equipment of PTI stations since May 2023. Nonetheless, some 
stakeholders indicated that there may be a need for software updates with cost estimates ranging from 
EUR 100 to EUR 1,000 in case of a standardised solution. Assuming an extra cost for the software 
update of EUR 500 per PTI tool and 128,536 PTI tools in the EU, the one-off adjustment costs are 
estimated at EUR 64.3 million in 2026.  

No  additional  costs  are  expected  for  PTI  inspections  to  perform  the  software  status  and  integrity 
checks and update the safety and emission software. As these can be performed remotely (OTA) and 
the additional time taken during a PTI or RSI test is considered negligible, no increase in the costs of 
the PTI/RSI tests is assumed. For the PTI tests on vehicles, the tools necessary to perform the software 
checks are already available as they may currently be used for OBD checks of the emission and safety 
systems (such as anti-lock and electronic braking systems, steering or airbags).  

In addition, training of 128,536 PTI inspectors would be needed, covering new test items for GSR 
and software status/integrity of safety and/or emission relevant systems. Assuming one extra training 
day per inspector, the one-off adjustment costs for training are estimated at EUR 31.8 million in 2026.  

The introduction of ePTI will possibly lead to time and cost savings for PTI centres. However, PMC2 
is not about the introduction of ePTI, but its use in relation to the new items to be checked as a result 
of the General Safety Regulation and would therefore not directly lead to time savings.  

The total adjustment costs for PTI centres as a result of PMC2 are summarised in the tables below.  

Table 50: One-off adjustment costs for PTI centres due to PMC2 in 2026, 2030, 2040 and 2050 in the policy options 
(for all options) relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off  costs  for  updates  due  to  General  Safety 
Regulation 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

31.8 

2026 
96.1 
64.3 

Difference to the baseline 

2030 
0.0 
0.0 

0.0 

2040 
0.0 
0.0 

0.0 

2050 
0.0 
0.0 

0.0 

311 https://www.iso.org/standard/73801.html  

130 

 
  
 
Table 51: One-off adjustment costs for PTI centres due to PMC2 in the policy options, expressed as present value 
over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for updates due to General Safety Regulation 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

PO1a 
96.1  
64.3  
31.8  

PO1b 
96.1  
64.3  
31.8  

PO2 
96.1  
64.3  
31.8  

PO3 
96.1  
64.3  
31.8  

Depending on the Member State, the additional costs for the PTI centres may be passed through to 
vehicle owners (i.e., citizens and businesses). As indicated under PMC1, this will depend on the way 
PTI charges are set in the Member State. 

3.2.2.  Adjustment costs for national public authorities 

Adjustment  costs  are  also  expected  for  national  public  authorities,  in  relation  to  equipment  and 
training that is required for RSI. The requirement for testing of software status/integrity of safety 
and/or emission relevant systems at RSI would result in investments in OBD scanning tools. Based 
on input from one equipment supplier (Texa) the costs are estimated at EUR 1,000 per tool. One tool 
is required per RSI unit, and the number of RSI units total 131 at EU level. Training would also be 
required for RSI inspectors on software checks using OBD scanning tool. Two hours of training are 
assumed for each of the 393 RSI inspectors across EU27. An hourly cost for technicians and associate 
professionals (ISCO 3) of EUR 34/hour312 is used for estimating the costs of training. The total one-
off adjustment costs are estimated at EUR 157,712 in 2026.  

The adjustment costs for national public authorities responsible for RSI due to PMC2 are presented 
in the tables below.  

Table 52: One-off adjustment costs for national public authorities due to PMC2 in 2026, 2030, 2040 and 2050 in 
the policy options (for all options) relative to the baseline (in million EUR, 2022 prices) 
Difference to the baseline 
2040 
2030 
0.0 
0.0 
0.0 
0.0 

Total adjustment costs 
One-off adjustment costs  
Source: Ricardo et al. (2024), Impact assessment support study 

2050 
0.0 
0.0 

2026 
0.2 
0.2 

Table 53: One-off adjustment costs for national public authorities due to PMC2 in the policy options relative to 
the baseline, expressed as present value over 2026-2050 (in million EUR, 2022 prices) 

Total adjustment costs 
One-off adjustment costs 
Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 
0.2  
0.2  

Difference to the baseline 
PO2 
PO1b 
0.2  
0.2  
0.2  
0.2  

PO3 
0.2  
0.2  

312 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 

131 

 
  
  
  
 
3.3.  PMC3 - Mandatory PN testing of LDVs and HDVs equipped with particle filter, at PTI, 

and of HDVs at technical roadside inspections of commercial vehicles 

3.3.1.  Adjustment costs for PTI centres 

The introduction of a PN check as part of PTI, to replace the current exhaust gas opacity test at least313 
for vehicles equipped with particle filters, would lead to additional costs for PTI centres that will 
need  to  purchase  and  maintain  the  new  PN  testing  equipment  and  provide  additional  training  for 
inspectors.  

To introduce a new emission check during PTI requires that PTI centres will be provided with new 
devices for the PN counting. For the 36,173 PTI centres in the EU affected by this measure (excluding 
Belgium, Germany and the Netherlands, which have already introduced such testing and are thus part 
of the baseline), the price per new PN measurement equipment is estimated at EUR 5,000, based on 
stakeholders’ feedback. Two devices per PTI inspection centre would be needed. Thus, the one-off 
adjustment costs for the purchase of the new equipment are estimated at EUR 361.7 million in 2026.  

In addition, recurrent maintenance and calibration costs are assumed at 5% of the capital costs (i.e., 
EUR  250  per  PN  measurement  equipment),  based  on  stakeholders’  feedback314.  Total  recurrent 
adjustment costs are thus estimated at EUR 18.1 million per year from 2026 onwards. Expressed as 
present  value  over  2026-2050,  the  total  recurrent  adjustment  costs  for  the  maintenance  of  new 
equipment are estimated at EUR 324.4 million relative to the baseline.   

In terms of training, an additional half day of training related to the use of PN testing for 88,776 
inspectors (excluding Belgium, Germany and the Netherlands, which have already introduced such 
testing and are thus part of the baseline) is assumed to take place in 2026. The one-off adjustment 
costs are estimated at EUR 11 million in 2026315.  

No difference is expected in terms of emissions testing time by replacing the opacity test with the 
new PN testing. Therefore, no additional labour costs for PTI are expected.  

The total adjustment costs for PTI centres due to PMC3 are summarised in the tables below. 

Table 54: One-off and recurrent adjustment costs for PTI centres due to PMC3 in 2026, 2030, 2040 and 2050 in 
the policy options (for all options) relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for new equipment  
Recurrent costs for the maintenance of equipment 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

2026 
390.8 
361.7 
18.1 
11.0 

2030 
18.1 
0.0 
18.1 
0.0 

2040 
18.1 
0.0 
18.1 
0.0 

2050 
18.1 
0.0 
18.1 
0.0 

Table 55: One-off and recurrent adjustment costs for PTI centres due to PMC3 in the policy options relative to 
the baseline, expressed as present value over 2026-2050 (in million EUR, 2022 prices) 

Total adjustment costs 

Difference to the baseline 

PO1a 
697.1  

PO1b 
697.1  

PO2 
697.1  

PO3 
697.1  

313  Where  technically  possible  (i.e.,  the  measuring  equipment  allows  it),  this  could  be  extended  to  older  emission 
standards. This possibility is not part of the cost calculations. 
314 According to GOCA, the yearly calibration cost of a PN measurement device is EUR 305, while that of a smoke tester, 
which it would replace is EUR 157.5. The 5% thus includes maintenance, too. 
315 Calculated using an hourly cost for technicians and professionals (ISCO 3) of EUR 34/hour. 

132 

 
  
  
 
One-off costs for new equipment  
Recurrent costs for the maintenance of equipment 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 
361.7  
324.4  
11.0  

Difference to the baseline 

PO1b 
361.7  
324.4  
11.0  

PO2 
361.7  
324.4  
11.0  

PO3 
361.7  
324.4  
11.0  

Depending on the Member State, the additional costs for the PTI centres may be passed through to 
vehicle owners (i.e., citizens and businesses). As indicated under PMC1, this will depend on the way 
PTI charges are set in the Member State. 

3.3.2.  Adjustment costs to national public authorities  

Roadside inspection authorities will incur costs for the purchase of PN testing equipment, to be used 
as part of roadside inspections. It is assumed that one PN measurement device is needed per RSI unit, 
at a cost of EUR 5,000 each (which is the same cost used for the PN testing). In total, 131 RSI units 
would  need  to  purchase  PN  testing  equipment316.  The  one-off  adjustment  costs  for  measurement 
equipment are estimated at EUR 0.7 million in 2026.  

Recurrent maintenance and calibration costs are assumed at 5% of the capital cost, or EUR 250 per 
PN measurement device, based on stakeholders’ feedback. Total recurrent adjustment costs are thus 
estimated at EUR 32,750 per year from 2026 onwards. Expressed as present value over 2026-2050, 
the  total  recurrent  adjustment  costs  for  the  maintenance  of  new  PN  measurement  devices  are 
estimated at EUR 0.6 million relative to the baseline.  

An additional half day of training related to the use of PN measurement devices is assumed for the 
estimated 393 RSI inspectors across the EU in 2026. The one-off adjustment costs are estimated at 
EUR 48,616 in 2026. 

The total adjustment costs for national public authorities due to PMC3 are summarised in the tables 
below. 

Table 56: One-off and recurrent adjustment costs for national public authorities due to PMC3 in 2026, 2030, 2040 
and 2050 in the policy options (for all options) relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for new equipment  
Recurrent costs for the maintenance of equipment 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

2026 
0.74  
0.66  
0.03  
0.05  

2030 
0.03  
0.00  
0.03  
0.00  

2040 
0.03  
0.00  
0.03  
0.00  

2050 
0.03  
0.00  
0.03  
0.00  

Table 57: One-off and recurrent adjustment costs for national public authorities due to PMC3 in the policy options 
relative to the baseline, expressed as present value over 2026-2050 (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for new equipment  

Difference to the baseline 

PO1a 
1.29  
0.66  

PO1b 
1.29  
0.66  

PO2 
1.29  
0.66  

PO3 
1.29  
0.66  

316 Estimation based on approximately 691 thousand of RSIs performed in 2021-2022, an average time per inspection of 
30 minutes, and 3 inspectors per RSI unit. 

133 

 
  
  
  
 
for 

the  maintenance  of 

Recurrent  costs 
equipment 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

0.05  

0.59  

PO1a 

Difference to the baseline 

PO1b 

0.59  

0.05  

PO2 

0.59  

0.05  

PO3 

0.59  

0.05  

3.3.3.  Cost for vehicle owners (citizens and businesses) 

The adjustment costs incurred by testing centres may be passed through to vehicle owners in the form 
of higher PTI charges. In Member States where PTI charges are regulated, this may be more gradual 
than in those where prices are set by the market.  

Owners  of  faulty  LDVs/HDVs  vehicles  will  also  face  a  charge  for  repairing  the  non-compliant 
vehicle.  This  is  not  considered  to  be  regulatory  costs  but  is  relevant  in  terms  of  the  impact  on 
maintenance costs. Where a vehicle is found to be tampered with, the owner/holder will face a fine 
that is supposed to be proportionate and dissuasive, as set by the Member State in which the offence 
is detected. 

3.4.  PMC4 – Mandatory NOx testing of LDV and HDV at PTI, and HDVs at roadside (based 

on ongoing work of JRC317)  

This policy measure will introduce mandatory NOx emission testing during PTI for LDVs and HDVs 
(from Euro 5b and Euro VI respectively) and at RSIs (for HDVs from Euro VI). 

3.4.1.  Adjustment costs for PTI centres 

To introduce a NOx emission check during PTI requires that all PTI stations will be provided with 
new devices for the NOx measurement. The cost per NOx measurement equipment is estimated at 
EUR 15,000, which is the lower end of the range of estimates provided by stakeholders (between 
EUR 15 thousand and 40 thousand). The reason for using the lower bound estimate is the fact that 
this estimate is  more recent  and that experience  with  PN measurement device has shown a sharp 
decrease in prices as demand increased (even after the introduction of such tests in just three Member 
States).  A  similar  trend  is  expected  for  NOx-measurement  devices.  Since  the  PN  and  NOx 
measurement devices will most likely be combined in one piece of equipment in the future, these 
numbers may still overestimate the costs. Each of the 48,880 PTI centres in the EU are assumed to 
be equipped with two devices. The total one-off adjustment costs are estimated at EUR 1.5 billion in 
2026.  

Recurrent adjustment costs (i.e., maintenance and calibration costs) are assumed at 5% of the capital 
cost. Total recurrent adjustment costs are thus estimated at EUR 73.3 million per year from 2026 
onwards.  Expressed  as  present  value  over  2026-2050,  the  total  recurrent  adjustment  costs  for  the 
maintenance  and  calibration  of  new  equipment  are  estimated  at  EUR  1.3  billion  relative  to  the 
baseline.  

In terms of training, an additional half day training related to the use of NOx testing is assumed to 
take place for the 128,536 inspectors. The one-off adjustment costs for training are estimated at EUR 
15.9 million in 2026318. 

317 https://www.mdpi.com/1996-1073/16/14/5520 
318 Calculated using an hourly cost for technicians and associate professionals (ISCO 3) of EUR 34/hour. 

134 

 
  
 
No additional staff, and corresponding higher PTI cost, is expected as no difference is foreseen in 
terms of emissions testing time. 

The total adjustment costs for PTI centres expected as a result of this measure are summarised in the 
tables below.  

Table 58: One-off and recurrent adjustment costs for PTI centres due to PMC4 in 2026, 2030, 2040 and 2050 in 
the policy options (for all options) relative to the baseline (in million EUR, 2022 prices) 

Difference to the baseline 

Total adjustment costs 
One-off costs for equipment  
Recurrent costs for equipment 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

2026 
1,555.6 
1,466.4 
73.3 
15.9 

2030 
73.3 
0.0 
73.3 
0.0 

2040 
73.3 
0.0 
73.3 
0.0 

2050 
73.3 
0.0 
73.3 
0.0 

Table 59: One-off and recurrent adjustment costs for PTI centres due to PMC4 in the policy options, expressed 
as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for equipment  
Recurrent costs for equipment 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 
2,797.3  
1,466.4  
1,315.0  
15.9  

Difference to the baseline 
PO1b 
2,797.3  
1,466.4  
1,315.0  
15.9  

PO2 
2,797.3  
1,466.4  
1,315.0  
15.9  

PO3 
2,797.3  
1,466.4  
1,315.0  
15.9  

3.4.2.  Adjustment costs for national public authorities  

Roadside inspection authorities will incur costs for the purchase of NOx measurement equipment to 
be used as part of roadside inspections on HDVs.  

One NOx measurement device is assumed per RSI unit, at a cost of EUR 15,000 each (which is the 
same value used for the NOx measurement equipment used in PTI centres). In total, 131 RSI units 
would  need  to  purchase  the  equipment.  Thus,  the  one-off  adjustment  costs  for  the  measurement 
equipment are estimated at EUR 2 million in 2026.  

Recurrent maintenance and calibration costs are assumed at 5% of the capital cost. Total recurrent 
adjustment  costs  are  thus  estimated  at  EUR  98,250  per  year  from  2026  onwards  relative  to  the 
baseline. Expressed as present value over 2026-2050, they are estimated at EUR 1.8 million relative 
to the baseline. 

An  additional  half  day  of  training  related  to  the  use  of  NOx  testing  is  assumed  for  the  393  RSI 
inspectors. The one-off adjustment costs for training are estimated at EUR 48,616 in 2026. 

The total costs for national public authorities expected as a result of this measure are summarised in 
the tables below. 

Table 60: One-off and recurrent adjustment costs for national public authorities due to PMC4 in 2026, 2030, 2040 
and 2050 in the policy options (for all options) relative to the baseline (in million EUR, 2022 prices) 

Difference to the baseline 

Total adjustment costs 
One-off costs for equipment  
Recurrent costs for equipment 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

2026 
2.11 
1.97 
0.10 
0.05 

2030 
0.10 
0.00 
0.10 
0.00 

2040 
0.10 
0.00 
0.10 
0.00 

2050 
0.10 
0.00 
0.10 
0.00 

135 

 
  
  
  
Table  61:  One-off  and  recurrent  adjustment  costs  for  national  public  authorities  due  to  PMC4  in  the  policy 
options, expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for equipment  
Recurrent costs for equipment 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 
3.78 
1.97 
1.76 
0.05 

Difference to the baseline 
PO1b 
3.78 
1.97 
1.76 
0.05 

PO2 
3.78 
1.97 
1.76 
0.05 

PO3 
3.78 
1.97 
1.76 
0.05 

3.4.3.  Cost for vehicle owners (citizens and businesses) 

The adjustment costs incurred by testing centres may eventually be passed through to vehicle owners 
in the form of higher PTI charges. As in the previous cases, this will change from Member State to 
Member State. 

Owners of faulty vehicles will face a charge for repairing the non-compliant vehicle. However, this 
is not considered to be regulatory costs but is relevant in terms of the impact on maintenance costs. 

3.5.  PMC5  -  Mandatory  roadworthiness  testing  following  significant  modifications  of  the 

vehicle (e.g. change of class, propulsion system) 

3.5.1.  Administrative costs for citizens (vehicle owners) 

PMC5 would result in additional costs for some vehicle owners by introducing mandatory testing of 
all vehicles that have undergone significant modifications. The average cost of a PTI for citizens is 
estimated at EUR 39.1 per vehicle (i.e., calculated as the weighted average of the median by Member 
State for M1 and L vehicle types). PTI cost data has been collected from CITA General Questionnaire 
2020-21319, and national online information sources.  

Feedback  from  stakeholders  indicated  that  in  Spain  and  Germany  the  total  number  of  modified 
vehicles was around 245,000 and 200,000, respectively, in 2022. This represents an annual average 
of 0.6% of the total fleet. However, many stakeholders highlighted that PTI following a modification 
is already a requirement in their Member State320. Therefore, the share of 0.6% is applied only to the 
vehicle fleet from countries where this is not already implemented in the baseline. In addition, it has 
been assumed that 40%  of the cars registrations (M1 vehicle category)  and 100% of motorcycles 
registrations  (L  vehicle  category)  are  undertaken  by  citizens.  The  number  of  vehicles  affected  is 
estimated  at  0.44  million  in  2026,  0.45  million  in  2030  and  0.53  million  in  2050.  The  recurrent 
administrative costs, based on the number of vehicles affected and the cost per PTI, are estimated at 
EUR 17.1 million in 2026, EUR 17.7 million in 2030 and EUR 20.6 million in 2050. Expressed as 
present value over 2026-2050, they are estimated at EUR 336.3 million relative to the baseline.  

The total administrative costs for citizens due to PMC5 are summarised in the tables below. 

Table 62: Number of vehicle affected and recurrent administrative costs for citizens due to PMC5 in 2026, 2030, 
2040 and 2050 in the policy options (for all options) relative to the baseline (in million EUR, 2022 prices) 

Number of vehicles affected (million) 

Difference to the baseline 

2026 
0.44 

2030 
0.45 

2040 
0.50 

2050 
0.53 

319 https://citainsp.org/2021/06/28/cita-general-questionnaire-2020-21/ 
320 EU Member States where stakeholders identified PTI following modification as an existing requirement are: Croatia, 
Finland, Austria, Netherlands, Germany, Sweden and Spain. This requirement is also in place for Iceland.  

136 

 
  
  
 
Recurrent administrative cost 
Source: Ricardo et al. (2024), Impact assessment support study 

2026 
17.1 

Difference to the baseline 

2030 
17.7 

2040 
19.4 

2050 
20.6 

Table 63: Recurrent administrative costs for citizens due to PMC5 in the policy options, expressed as present value 
over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative cost 
Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 
336.3  

Difference to the baseline 
PO1b 
336.3  

PO2 
336.3  

PO3 
336.3  

3.5.2.  Administrative costs for businesses (vehicle owners) 

As explained above, PMC5 would result in additional costs for some vehicle owners by introducing 
mandatory testing of all vehicles that have undergone significant modifications. The average cost of 
a PTI for businesses is estimated at EUR 42.1 per vehicle (i.e., calculated as the weighted average of 
the median by Member State for M1, N1, N2/N3 and M2/M3 vehicle types). PTI cost data has been 
collected from CITA General Questionnaire 2020-21, and national online information sources.  

Feedback  from  stakeholders  indicated  that  in  Spain  and  Germany  the  total  number  of  modified 
vehicles was around 245,000 and 200,000, respectively, in 2022. This represents an annual average 
of 0.6% of the total fleet. However, many stakeholders highlighted that PTI following a modification 
is already a requirement in their Member State321. Therefore, the share of 0.6% is applied only to the 
vehicle fleet from countries where this is not already implemented in the baseline. In addition, it has 
been assumed that 60% of the cars registrations (M1 vehicle category) and 100% of vans, lorries and 
buses  registrations  (N1,  N2/N3  and  M2/M3  vehicle  category)  are  undertaken  by  businesses.  The 
number of vehicles affected is estimated at 0.64 million in 2026, 0.66 million in 2030 and 0.75 million 
in 2050. The recurrent administrative costs, based on the number of vehicles affected and the cost 
per PTI, are estimated at EUR 27 million in 2026, EUR 27.8 million in 2030 and EUR 31.6 million 
in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 524.2 million relative 
to the baseline.  

The total administrative costs for businesses due to PMC5 are summarised in the tables below. 

Table 64: Number of vehicle affected and recurrent administrative costs for businesses due to PMC5 in 2026, 2030, 
2040 and 2050 in the policy options (for all options) relative to the baseline (in million EUR, 2022 prices) 

Number of vehicles affected (million) 
Recurrent administrative cost 
Source: Ricardo et al. (2024), Impact assessment support study 

2026 
0.64 
27.0 

Difference to the baseline 

2030 
0.66 
27.8 

2040 
0.72 
30.2 

2050 
0.75 
31.6 

Table 65: Recurrent administrative costs for businesses due to PMC5 in the policy options, expressed as present 
value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

PO1a 
Recurrent administrative cost 
524.2  
Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

PO1b 
524.2  

PO2 
524.2  

PO3 
524.2  

321 EU Member States where stakeholders identified PTI following modification as an existing requirement are Croatia, 
Finland, Austria, Netherlands, Germany, Sweden and Spain. This requirement is also in place for Iceland.  

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3.5.3.  Benefits for PTI centres 

PMC5 would result in benefits for the PTI centres due to the mandatory testing of all vehicles that 
have  undergone  significant  modifications.  The  costs  for  vehicle  owners  (citizens  and  businesses) 
discussed above represent revenues for the PTI centres. The total revenues for PTI centres due to 
PMC5 are thus estimated at EUR 44.1 million in 2026, EUR 45.5 million in 2030 and EUR 52.3 
million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 860.5 million 
relative to the baseline. 

Table 66: Benefits for PTI centres due to PMC5 in 2026, 2030, 2040 and 2050 in the policy options (for all options) 
relative to the baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

Difference to the baseline 

2026 
44.1 

2030 
45.5 

2040 
49.6 

2050 
52.3 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 67: Benefits for PTI centres due to PMC5 in the policy options, expressed as present value over 2026-2050 
relative to the baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

Difference to the baseline 

PO1a 
860.5  

PO1b 
860.5  

PO2 
860.5  

PO3 
860.5  

Source: Ricardo et al. (2024), Impact assessment support study 

3.6.  PMC6 - Require the roadworthiness certificate in electronic format only 

3.6.1.  Administrative costs for national public authorities  

PMC6 requires that the roadworthiness certificate be issued in electronic format only. According to 
national experts from Member States such as Finland, Croatia and Slovenia the measure would entail 
some software development. Developing the software for electronic certificates is estimated in the 
range of EUR 500 thousand to EUR 1 million. Assuming one-off costs of EUR 500,000 per IT system 
for each of the 15 Member States with smaller volumes of inspections322, EUR 750,000 per IT system 
for each of the 7 Member States with medium volumes of inspections323 and EUR 1,000,000 per IT 
system  for  each  of  the  5  Member  States  with  higher  volumes  of  inspections324,  the  total  one-off 
administrative costs at EU27 level are estimated at EUR 17.8 million in 2026.   

Recurrent administrative costs for the maintenance and update of the system for electronic certificates 
are assumed at 5% of the investment costs, based on stakeholders’ feedback. They are estimated at 
EUR  887,500  from  2026  onwards.  Expressed  as  present  value  over  2026-2050,  the  recurrent 
administrative costs for national public administrations are estimated at EUR 15.9 million relative to 
the baseline.  

3.6.2.  Administrative costs savings for national public authorities 

In the baseline, the cost of a paper RW certificate is estimated at 1 EUR per certificate, covering the 
cost of printing and the time spent to print the document. Around 2% of the total RW certificates are 
issued in a digital format in the baseline, in two Member States (Finland and Estonia). The number 

322 Below 2% of the total number of inspections at EU level in 2026 by Member State. These are: BG, CY, EE, FI, HR, 
HU, IE, LT, LV, LU, MT, SI, SK, DK and CZ.    
323 Between 2% and 10% of the total number of inspections at EU level in 2026 by Member State. These are: AT, BE, 
EL, NL, PT, RO and SE.   
324 Above 10% of the total number of inspections at EU level in 2026 by Member State. These are:  DE, FR, IT, PL and 
ES.    

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of RW certificates issued in paper format in the baseline is estimated at 161.5 million in 2026, 167.3 
million in 2030 and 190.6 million in 2050. Thus, the administrative costs saving due to issuing the 
RW certificates in electronic format only are estimated at EUR 161.5 million in 2026, EUR 167.3 
million in  2030 and  EUR 190.6 million in  2050. Expressed as present  value over 2026-2050, the 
recurrent administrative costs savings for national public administrations are estimated at EUR 3.2 
billion relative to the baseline.  

Table 68: Costs and costs savings for national public authorities due to PMC6 in 2026, 2030, 2040 and 2050 in the 
policy options (for all options) relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off administrative costs 
Recurrent administrative costs 
Total administrative costs savings 
Recurrent administrative costs savings 
Source: Ricardo et al. (2024), Impact assessment support study 

2026 
18.6 
17.8 
0.9 
161.5 
161.5 

Difference to the baseline 

2030 
0.9 
0.0 
0.9 
167.3 
167.3 

2040 
0.9 
0.0 
0.9 
182.0 
182.0 

2050 
0.9 
0.0 
0.9 
190.6 
190.6 

Table 69: Costs and costs savings for national public authorities due to PMC6 in the policy options, expressed as 
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off administrative costs 
Recurrent administrative costs 
Total administrative costs savings 
Recurrent administrative costs savings 
Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 
33.7 
17.8 
15.9 
3,155.0 
3,155.0 

Difference to the baseline 
PO1b 
33.7 
17.8 
15.9 
3,155.0 
3,155.0 

PO2 
33.7 
17.8 
15.9 
3,155.0 
3,155.0 

PO3 
33.7 
17.8 
15.9 
3,155.0 
3,155.0 

3.7.  PMC7 - Provide electronic access to  relevant  data, including on PTI reports stored in 
national  databases,  to  the  registration  authorities  of  other  EU  Member  States  using  a 
common interface 

3.7.1.  Administrative costs for national public authorities  

The  measure  under  consideration  entails  costs  for  providing  access  to  relevant  data.  All  Member 
States already store the PTI information in their national vehicle register. The associated costs are 
however expected to be lower when existing systems (such as EUCARIS, ERRU or the MOVE-Hub) 
are used by all Member States. Most of the enforcement authorities are already connected to their 
local vehicle registration authority and could simply add this to the existing data exchange. Member 
States are free to use a EUCARIS offering or build their own solution to satisfy any legal obligations 
for data exchange. The costs and hence decisions will vary between Member States depending on the 
organisation of their national public authorities. If the national public authority that manages the road 
transport undertakings register (i.e., the connection to ERRU) also manages the PTI data then they 
can extend the solution they already have in place. If those two databases are in different national 
public authorities, it changes the decisions and the costs. 

According to EReg’s survey responses, requiring Member States to use an IT system for registration 
procedures that they are already using for other purposes would save costs compared to putting in 
place a new central hub. Either the EUCARIS peer-to-peer exchange system, or the hub-and-spoke 
system  of  MOVE-Hub  could  be  adapted  to  the  needs  of  PMC7,  limiting  the  additional  costs  of 

139 

 
  
  
implementing the measure and ensuring an effective exchange data mechanism. According to EReg, 
the creation of a central hub should not prevent the use of EUCARIS325. 

For the implementation  of this measure, one-off  administrative costs are  expected for developing 
common interfaces for accessing the data. The one-off administrative costs for the interconnection 
of national registers are estimated at around EUR 300,000 per Member State in 2026. Thus, the total 
one-off administrative costs are estimated at EUR 8.1 million for the 27 EU Member States in 2026.  

The recurrent administrative costs (i.e., service supply costs) for providing access to the relevant data 
are estimated at around 5% of the capital costs. They amount to EUR 405,000 per year from 2026 
onwards. Expressed as present value over 2026-2050, recurrent administrative costs are estimated at 
EUR 7.3 million.  

3.7.2.  Administrative costs savings for national public authorities  

According to EUCARIS, if all countries would exchange their registration data in a structured way 
via a common IT system, the number of situations when registration authorities would need to contact 
each other via different, less secure ways (e.g. e-mail) to get the data, would decrease significantly.  

PMC7 is expected to lead to time savings of around 15 minutes per re-registration of a vehicle in 
another  Member  State  because  of  less  need  of  reaching  out  to  other  National  Contact  Points  by 
phone/mail. Considering the 3.5 million re-registrations per year in the EU326, and the average labour 
cost for ISCO 2 (professionals) of 40.9 EUR/hour327, the administrative costs savings for national 
public authorities are estimated at EUR 35.8 million per year, or EUR 641.8 million expressed as 
present value over the 2026-2050 period relative to the baseline.  

Table 70: Costs and costs savings for national public authorities due to PMC7 in 2026, 2030, 2040 and 2050 in the 
policy options (for all options) relative to the baseline (in million EUR, 2022 prices) 

2026 
8.5 
Total administrative costs 
8.1 
One-off administrative costs 
0.4 
Recurrent administrative costs 
35.8 
Total administrative costs savings 
Recurrent administrative costs savings 
35.8 
Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 
2030 
0.4 
0.0 
0.4 
35.8 
35.8 

2040 
0.4 
0.0 
0.4 
35.8 
35.8 

2050 
0.4 
0.0 
0.4 
35.8 
35.8 

Table 71: Costs and costs savings for national public authorities due to PMC7 in the policy options, expressed as 
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off administrative costs 
Recurrent administrative costs 
Total administrative costs savings 
Recurrent administrative costs savings 
Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 
15.4 
8.1  
7.3  
641.8 
641.8  

Difference to the baseline 
PO1b 
15.4 
8.1  
7.3  
641.8 
641.8  

PO2 
15.4 
8.1  
7.3 
641.8 
641.8  

PO3 
15.4 
8.1  
7.3 
641.8 
641.8  

325 As reported in the evaluation report, the use of EUCARIS does not currently represent a significant cost for Member 
States. 
326  Source:  https://ggiforum.com/consulting/immigration-executive/127-cross-border-car-registration-within-the-eu-to-
be-simplified.html  
327 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 

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3.8.  PMC8  -  Harmonisation  and  regular  update  of  the  technical  data  in  the  vehicle 

registration documents (currently optional content) 

3.8.1.  Administrative costs for national public authorities  

PMC8 will harmonise and clarify (where necessary) the contents related to the technical data of the 
vehicle to be provided in the registration document, as indicated in annexes I and II of the Directive 
1999/37, and requires regular update.  

The measure would likely result in additional administrative costs for Member State authorities for 
the  harmonisation  across  MS,  redesigning  and  setting  up  the  new  template  for  the  registration 
documents.  This  is  accompanied  by  a  continuous  review  and  update  of  the  documents,  with  the 
addition of new items that may be needed in the future. Stakeholders provided a range of estimates 
for the one-off costs for harmonisation, from no cost to up to EUR 80,000, with an average of EUR 
26,667 per Member State. This range reflects the different views of Member States concerning the 
need  to  transition  to  digital  registration  documents  or  the  retention  of  physical  documents  (this 
decision is not part of the policy measure and is left to the choice of each MS). The total one-off 
administrative costs for the harmonisation of technical data in the vehicle registration documents are 
estimated at EUR 720,000 in 2026 for the 27 EU Member States relative to the baseline.  

In  addition,  recurrent  administrative  costs  are  expected  for  the  regular  update  of  the  vehicle 
registration documents with new items that may be found relevant in the future. Recurrent labour 
cost of 40.9 EUR/hour for ISCO 2 (professionals)328, working for this specific function an average 
of 2 hours per day along the 220 working days of a regular year, are assumed. The total recurrent 
administrative costs for updating the technical data in vehicle registers is estimated at EUR 485,849 
per year from 2026 onwards for all the EU countries. Expressed as present value over 2026-2050, the 
total recurrent administrative costs are estimated at EUR 8.7 million relative to the baseline (in 2022 
prices).  

The total administrative costs for national public authorities expected as a result of this measure are 
summarised in the tables below. 

Table 72: One-off and recurrent administrative costs for national public authorities due to PMC8 in the policy 
options (all options), in 2026, 2030, 2040 and 2050 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off  costs  to  support  the  harmonisation  of  vehicle 
registration documents 
Recurrent  costs  for  regular  updates  of  the  vehicle 
registration documents 
Source: Ricardo et al. (2024), Impact assessment support study 

2026 
1.2 

0.7 

0.5 

Difference to the baseline 

2030 
0.5 

0.0 

0.5 

2040 
0.5 

0.0 

0.5 

2050 
0.5 

0.0 

0.5 

Table 73: One-off and recurrent administrative costs for national public authorities due to PMC8 in the policy 
options, expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off costs to support the harmonisation of vehicle 
registration documents 

Difference to the baseline 

PO1a 
 9.4  
 0.7  

PO1b 
 9.4 
 0.7  

PO2 
 9.4 
 0.7  

PO3 
9.4 
 0.7  

328 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 

141 

 
  
  
 
Recurrent  costs  for  regular  updates  of  the  vehicle 
registration documents 
Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 
 8.7  

Difference to the baseline 

PO1b 
 8.7 

PO2 
 8.7  

PO3 
8.7 

3.8.2.  Administrative cost savings for national public authorities and citizens  

Harmonisation of vehicle registration documents could potentially reduce administrative costs related 
to cross-border vehicle registration and compliance, benefiting both national public authorities and 
citizens. However, these cost savings cannot be quantified with available data. 

3.9.  PMC9 – MSs to record odometer readings in a national database and make the records 

available to other MSs in the case of re-registration 

PMC9  requires  Member  States  to  record  odometer  readings  in  a  national  database  and  make  the 
records available to other MSs in the case of re-registration. Odometer readings for cars and vans 
(M1, N1) will need to be provided by garages, tyre and other repair service, in addition to PTI bodies, 
following every visit. OEMs will be required to provide odometer readings from connected vehicles. 

PMC9 is intended to replicate across the EU the approach already followed in the Netherlands and 
Belgium. However, in comparison to the Belgian Car-Pass system PMC9 does not require the issuing 
of a certificate as part of a vehicle transaction. This currently costs around EUR 10 in Belgium and 
provides the main source of revenue to support the operation of the system in the country. In the 
Dutch National Auto Pas system, the delivery of the vehicle report is free of charge. 

There is no requirement for the development of an EU wide dataset in PMC9 but Member States will 
need to share information on vehicle odometer readings from their respective national datasets when 
a cross-border sale of a vehicle takes place. 

The one-off and recurrent costs for the operation of a similar system established in each Member 
State  are  estimated  based  on  input  from  the  Belgian  Car-Pass  and  a  2018  European  Parliament 
study329.  PMC9  is  expected  to  lead  to  costs  for  national  public  authorities  for  establishing  and 
operating the system (including a relevant database with odometer readings covering all registered 
vehicles), for taking action when issues are identified, and for sharing data with other Member States 
when they receive requests. In addition, the measure is expected to lead to costs for garages/tyre and 
repair services for submitting the odometer readings (PTI centres already do so). No additional costs 
relative to the baseline are expected for OEMs due to this measure. 

3.9.1.  Administrative costs for national public authorities 

The initial cost to set up the database with the odometer readings and the overall system of monitoring 
was around EUR 1.5 million in 2006 for Car-Pass330. However, it is expected that this cost is lower 
today, given the decrease in the costs of IT solutions in the recent past. For the assessment of PMC9, 
the one-off administrative costs are assumed at  EUR 1 million for each of  the 25 Member States 
concerned (i.e., excluding Belgium and the Netherlands which introduced the system already and are 

329 European Parliament (2018), Odometer Manipulation in motor vehicles in Europe, 
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf  
330 Based on an interview with Car-Pass.  

142 

 
  
 
part of the baseline). Thus, the total one-off administrative costs are estimated at EUR 25 million in 
2026 relative to the baseline. 

Based on the 2018 European Parliament study331, the cost for operating the system is estimated at 
EUR 0.42 per vehicle (expressed in 2022 prices)332. The number of M1 and N1 vehicles relevant for 
PMC9 are projected at 254.7 million in 2026, 262.4 million in 2030 and 295.8 million in 2050. The 
recurrent  administrative costs are estimated at  EUR 108.1 million in 2026, EUR 111.4 million in 
2030 and EUR 125.6 million in 2050. Expressed as present value over 2026-2050, they are estimated 
at EUR 2.1 billion. 

Table 74: Administrative costs for national public administrations due to PMC9 in 2026, 2030, 2040 and 2050 in 
all policy options relative to the baseline (in million EUR, 2022 prices) 

Number of vehicles relevant for PMC9 (thousand),  
of which: 

M1 vehicles 
N1 vehicles 

Total administrative costs (in million EUR) 
One-off costs to set up the system 
Recurrent costs for operating the system 

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

2026 

2030 

2040 

2050 

254,666 

262,373 

285,115 

295,817 

224,997 
29,669 
133.1 
25.0 
108.1 

231,563 
30,811 
111.4 
0.0 
111.4 

251,316 
33,798 
121.0 
0.0 
121.0 

259,000 
36,817 
125.6 
0.0 
125.6 

Table 75: Administrative costs for national public administrations due to PMC9 in PO1a, PO1b, PO2 and PO3, 
expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off costs to set up the system 
Recurrent costs for operating the system 

PO1a 
2,122.1  
25.0  
2,097.1  

Difference to the baseline 

PO1b 
2,122.1  
25.0  
2,097.1  

PO2 
2,122.1  
25.0  
2,097.1  

PO3 
2,122.1  
25.0  
2,097.1  

Source: Ricardo et al. (2024), Impact assessment support study 

3.9.2.  Administrative costs for garages, motor vehicle dealers, tyre and repair stations, etc. 

The costs for the garages, motor vehicle dealers, tyre and repair stations, etc. will relate to possible 
software updates to allow them to transfer their data to the central national database and the time 
needed  to  record  the  odometer  readings.  Based  on  input  from  Car-Pass  system  manager  and  the 
European Parliament study333, the costs for software updates are estimated at EUR 229 per garage in 
2022 prices334. In PMC9 these costs are relevant for 651,351 companies (470,765 repair shops and 
garages across the EU335 and 180,586 motor vehicle dealers336), excluding those in Belgium and the 

331 European Parliament (2018), Odometer Manipulation in motor vehicles in Europe, 
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf  
332  The  cost  estimate  from  the  2018  European  Parliament  study  is  EUR  0.37  per  vehicle  in  2018  prices.  Using  the 
harmonised index of consumer prices (HICP) from Eurostat, this is equivalent to EUR 0.42 per vehicle in 2022 prices.  
333 European Parliament (2018), Odometer Manipulation in motor vehicles in Europe, 
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf 
334 The cost was estimated at EUR 200 per garage in 2018 prices. Using the harmonised index of consumer prices (HICP) 
from Eurostat, this is equivalent to EUR 229 per garage in 2022 prices. 
335  Eurostat,  Structural  business  statistics,  Enterprise  statistics  by  size  class  and  NACE  Rev.2  activity  (from  2021 
onwards) [SBS_SC_OVW], Maintenance and repair of motor vehicles. Estimates for Ireland are based on 2020 data. 
336  Eurostat,  Structural  business  statistics,  Enterprise  statistics  by  size  class  and  NACE  Rev.2  activity  (from  2021 
onwards) [SBS_SC_OVW], Sale of cars and light motor vehicles. Estimates for Ireland are based on 2020 data. 

143 

 
  
  
 
Netherlands,  which  implemented  the  measure  already  and  are  part  of  the  baseline.  Total  one-off 
administrative costs are thus estimated at EUR 149.2 million in 2026.  

The maintenance costs for the software are estimated at 10% of the one-off costs, or EUR 1.4 million 
per year from 2026 onwards. In addition, in order to calculate the costs related to the time needed to 
record the odometer readings, the European Parliament study assumed that 90% of the readings from 
garages will be done automatically via the IT system and only 10% of them will be encoded manually 
through a dedicated portal. Manual encoding is expected to take half a minute. Assuming an average 
cost per hour for technicians and associate professionals (ISCO level 3) of EUR 34, manual encoding 
is  estimated  at  EUR  0.28  per  encoding.  In  addition  to  the  odometer  readings  during  PTI,  it  is 
estimated that 1.5 readings per vehicle would take place per year. Furthermore, the share of connected 
vehicles is projected to increase over time from around 10% currently337 to 20% in 2026, 60% in 
2030 and 100% by 2040. No manual encoding is needed for the connected vehicles. Based on these 
assumptions  and  the  projected  M1  and  N1  vehicles  fleet  size  in  the  affected  MS,  the  recurrent 
administrative costs for garages, motor vehicle dealers, tyre and repair stations are estimated at EUR 
23.6 million in 2026, EUR 19.4 million in 2030 and EUR 14.9 million in 2050. Expressed as present 
value over 2026-2050, they are estimated at EUR 310.8 million relative to the baseline.  

For the purpose of the ‘one in one out approach’, the average annual recurrent administrative costs 
over 2026-2035 are estimated at EUR 19.5 million per year338. Considering the 651,351 companies 
relevant for PMC9, the average annual cost per company is estimated at EUR 29.9. In addition, as 
explained above, the one-off administrative costs are estimated at EUR 149.2 million in 2026. 

Table 76: Administrative costs for garages, motor vehicle dealers, tyre and repair stations due to PMC9 in 2026, 
2030, 2040 and 2050 in all policy options relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off costs for updating the software 
Recurrent costs for operating the system 

Difference to the baseline 

2026 
172.7 
149.2 
23.6 

2030 
19.4 
0.0 
19.4 

2040 
14.9 
0.0 
14.9 

2050 
14.9 
0.0 
14.9 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 77: Administrative costs for garages, motor vehicle dealers, tyre and repair stations due to PMC9 in PO1a, 
PO1b, PO2 and PO3, expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 
prices) 

PO1a 
460.0  
149.2  
310.8  
Source: Ricardo et al. (2024), Impact assessment support study 

Total administrative costs 
One-off costs for updating the software 
Recurrent costs for operating the system 

Difference to the baseline 

PO1b 
460.0  
149.2  
310.8  

PO2 
460.0  
149.2  
310.8  

PO3 
460.0  
149.2  
310.8  

3.9.3.  Reduction of odometer fraud and cost savings for citizens and businesses (vehicle owners) 

PMC9 directly targets odometer tampering by aiming to replicate the key elements of the Car-Pass 
system adopted in Belgium since 2006 and more recently in the Netherlands.  

The  requirement  for  mandatory  recording  and  reporting  to  a  national  central  database  of  vehicle 
tyre 
mileage,  whenever  a  vehicle  undergoes 
changes/replacement339, allows to create a long record of a vehicle’s mileage since its first time of 

repair/maintenance  or 

the  case  of 

in 

337 https://www.car-pass.be/en/news/car-pass-annual-report-2022  
338 This is calculated as a simple average over 2026-2035, non discounted.  
339 This is in addition to the time of the PTI, which is part of the baseline. 

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registration. This allows to easily identify any tampering with the odometer. For example, the Car-
Pass system led within a year340 to a very significant drop in the level of odometer fraud in the case 
of  second-hand  vehicles  registered  in  Belgium,  from  13%  to  no  more  than  2%341.  Similar 
effectiveness levels have been reported for the Dutch system, that shares many common elements 
with the Car-Pass system (albeit with no requirement for the issuing of a certificate). However, as 
explained by the manager of the Car-Pass system during the stakeholders’ consultation, there are still 
important  limitations when it comes to  cross-border vehicle sales since access  to  mileage records 
from other countries is often limited or not available at all. Implementing the system across the EU 
is  thus  expected to  help reduce odometer fraud in  the Member States where such a system  is  not 
currently in place, both in terms of domestic sales of used vehicles, as well as in terms of cross-border 
sales where odometer tampering has been found to be more common.  

The total volume of second hand vehicle sales (M1 and N1 vehicles) by citizens and businesses in 
the  25  Member  States  affected  by  PMC9  (excluding  Belgium  and  the  Netherlands,  which  have 
already implemented the system) is projected at around 62.3 million in 2026, 65.5 million in 2030 
and 71 million in 2050342 of which second hand cross border sales are estimated at 28.1 million in 
2026, 29.5 million in 2030 and 31.7 million in 2050343. The average share of odometer tampering in 
national second-hand car sales is estimated at 4.8%344 and in cross border second hand car sales at 
11.3%345,  and  they  are  assumed  to  remain  constant  over  time  in  the  baseline  scenario.  Thus,  the 
number of national second-hand vehicle sales with mileage fraud is projected at 1.63 million in 2026, 
1.71 million in 2030 and 1.90 million in 2050 in the baseline scenario, and that of cross border vehicle 
sales with mileage fraud at 3.18 million in 2026, 3.35 million in 2030 and 3.64 million in 2050.  

For assessing the benefits of PMC9 for citizens and businesses, the reduction in the level of odometer 
fraud is assumed at 97% for domestic sales of second-hand vehicles, based on the experience with 
Car-Pass346,  and  at  90%  for  the  cross-border  vehicle  sales.  If  frequent  odometer  recording  is 
implemented, and odometer history data is exchanged between Member States before re-registration, 
it is reasonable to assume that odometer fraud can be reduced at a similar level as in Belgium and the 
Netherlands. Furthermore, the rapid deployment of connected cars can be expected to significantly 
support the effectiveness of the measure. 

The national mileage fraud avoidance in terms of number of vehicles is estimated at 1.58 million in 
2026, 1.66 million in 2030 and 1.84 million in 2050 while the cross-border mileage fraud avoidance 
at 2.87 million in 2026, 3.01 million in 2030 and 3.28 million 2050. The average cost of mileage 
fraud, due to higher purchase price and maintenance costs incurred, is estimated at EUR 2,119 per 
vehicle  in  2022  prices  as  explained  in  detail  in  section  2  of  Annex  4.  The  total  costs  savings  for 
citizens and businesses are estimated at EUR 9.4 billion in 2026, EUR 9.9 billion in 2030 and EUR 

340 EPRS_STU(2018)615637_EN.pdf (europa.eu) 
341 The introduction of the system was supported by an extensive information campaign. 
342 Projections of second hand vehicle sales are derived based on projections for new car sales from the PRIMES-
TREMOVE baseline and available data on the ratio of second hand car to new car sales for selected countries from:  
https://www.bain.com/insights/the-outlook-for-the-european-used-car-market-brief/ and https://www.regitra.lt/lt/atviri-
duomenys/?datayear=2017&dataquery=. The ratio of second hand car to new car sales is assumed to remain constant 
over time. For MS without relevant data, a ratio of second hand to new car sales of 4 has been assumed for EU12 
countries and 3.5 for EU15 countries.  
343  Projections 
data 
https://www.carvertical.com/gb/transparency-index/metrics with some data gaps filled using the median value.  
344 Source: https://www.carvertical.com/blog/research-what-countries-have-the-highest-percentage-of-cars-with-a-fake-
mileage 
345 Source: 
https://www.europarl.europa.eu/RegData/etudes/STUD/2018/615637/EPRS_STU%282018%29615637_EN.pdf 
346 EPRS_STU(2018)615637_EN.pdf (europa.eu) 

second-hand 

developed 

border 

based 

cross 

sales 

are 

the 

for 

on 

from 

145 

 
 
10.8 billion in  2050. Expressed  as present  value over 2026-2050, they  are estimated at  EUR  184 
billion.  

Table 78: Costs savings for citizens and businesses due to PMC9 in 2026, 2030, 2040 and 2050 in all policy options 
relative to the baseline (in million EUR, 2022 prices) 

Difference to the baseline 

Volume of second hand national sales in 
the affected MS (million vehicles) 
Volume of second hand cross border 
sales in the affected MS (million 
vehicles) 
National second hand sales with mileage 
fraud (million vehicles) 
Cross border sales with mileage fraud 
(million vehicles) 
National mileage fraud avoidance 
(million vehicles) 
Cross border mileage fraud avoidance 
(million vehicles) 
Costs savings from fraud avoidance 
(EUR million), of which: 

National 
Cross border 

2026 

34.17 

28.10 

1.63 

3.18 

1.58 

2.87 

9,423.8 

3,350.8 
6,073.0 

Source: Ricardo et al. (2024), Impact assessment support study 

2030 

35.92 

29.54 

1.71 

3.35 

1.66 

3.01 

9,907.1 

3,522.6 
6,384.5 

2040 

39.90 

31.39 

1.90 

3.59 

1.85 

3.23 

2050 

39.33 

31.70 

1.90 

3.64 

1.84 

3.28 

10,751.7 

10,847.6 

3,913.0 
6,838.7 

3,899.1 
6,948.4 

Table  79:  Costs  savings  for citizens  and  businesses  due  to  PMC9  in PO1a,  PO1b,  PO2  and  PO3,  expressed  as 
present value over 2026-2050 relative to the baseline (in billion EUR, 2022 prices) 

Consumer 
savings 
avoidance, of which: 

from 

fraud 

National 
Cross border 

PO1a 

184.0 

65.9 
118.1 

Difference to the baseline 
PO1b 

PO2 

184.0 

65.9 
118.1 

184.0 

65.9 
118.1 

PO3 

184.0 

65.9 
118.1 

Source: Ricardo et al. (2024), Impact assessment support study 

As shown in the table below, these cost savings are expected to be more significant for citizens and 
businesses in Central and Eastern European countries where the level of odometer fraud has been 
found to be higher in general and where cross-border sales of second-hand vehicles are higher than 
average.  

Table 80: Estimated fraud avoidance and costs savings for citizens and businesses  due to  PMC9 in 2030 in  all 
policy options relative to the baseline  

National and cross border 
mileage fraud avoidance 
(thousand vehicles) 

Share of national and cross 
border mileage fraud 
avoidance in the total second 
hand vehicles sales (%) 

Savings for citizens and 
businesses from fraud 
avoidance (million EUR, in 
2022 prices) 

AT 
BG 
CY 
CZ 
DE 
DK 
EE 
EL 
ES 
FI 

145,990 
90,667 
24,238 
148,959 
477,055 
52,426 
43,122 
149,818 
381,502 
55,609 

8% 
8% 
10% 
9% 
4% 
5% 
15% 
8% 
7% 
5% 

146 

309.4 
192.2 
51.4 
315.7 
1,011.1 
111.1 
91.4 
317.5 
808.6 
117.9 

 
  
  
  
National and cross border 
mileage fraud avoidance 
(thousand vehicles) 

Share of national and cross 
border mileage fraud 
avoidance in the total second 
hand vehicles sales (%) 

Savings for citizens and 
businesses from fraud 
avoidance (million EUR, in 
2022 prices) 

FR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
PL 
PT 
RO 
SE 
SI 
SK 
EU level 

733,433 
48,286 
201,515 
62,778 
753,224 
161,193 
30,226 
30,430 
11,455 
395,864 
59,152 
325,840 
199,491 
24,382 
67,736 
4,675,346 
Source: Ricardo et al. (2024), Impact assessment support study 

6% 
8% 
11% 
8% 
7% 
15% 
12% 
19% 
8% 
9% 
3% 
13% 
10% 
6% 
6% 
7% 

1,554.5 
102.3 
427.1 
133.1 
1,596.4 
341.6 
64.1 
64.5 
24.3 
839.0 
125.4 
690.6 
422.8 
51.7 
143.6 
9,907.1 

To allocate the benefits due to the reduction of odometer fraud between citizens and businesses, the 
second hand M1 vehicle sales have been split between citizens and businesses using the share of new 
vehicle registered by citizens (i.e., 40%). For N1 vehicles it has been assumed that all benefits accrue 
to businesses. The tables below provide the split of the benefits between citizens and businesses at 
EU level. 

Table 81: Costs savings for citizens due to PMC9 in 2026, 2030, 2040 and 2050 in all policy options relative to the 
baseline (in million EUR, 2022 prices) 

Difference to the baseline 

Volume of second hand national sales in 
the affected MS (million vehicles) 
Volume of second hand cross border 
sales in the affected MS (million 
vehicles) 
National second hand sales with mileage 
fraud (million vehicles) 
Cross border sales with mileage fraud 
(million vehicles) 
National mileage fraud avoidance 
(million vehicles) 
Cross border mileage fraud avoidance 
(million vehicles) 
Costs savings from fraud avoidance 
(EUR million), of which: 

National 
Cross border 

2026 

12.24 

10.00 

0.59 

1.14 

0.57 

1.03 

3,380.8 

1,204.2 
2,176.7 

Source: Ricardo et al. (2024), Impact assessment support study 

2030 

12.87 

10.51 

0.62 

1.20 

0.60 

1.08 

3,554.2 

1,265.9 
2,288.3 

2040 

14.37 

11.11 

0.69 

1.27 

0.67 

1.15 

3,841.0 

1,411.1 
2,429.9 

2050 

14.06 

11.15 

0.68 

1.29 

0.66 

1.16 

3,856.7 

1,398.4 
2,458.3 

147 

 
  
 
 
  
Table 82: Costs savings for citizens due to PMC9 in PO1a, PO1b, PO2 and PO3, expressed as present value over 
2026-2050 relative to the baseline (in billion EUR, 2022 prices) 

Consumer savings from fraud avoidance, 
of which: 

National 
Cross border 

PO1a 

65.7 

23.7 
42.0 

Difference to the baseline 
PO1b 

PO2 

65.7 

23.7 
42.0 

65.7 

23.7 
42.0 

PO3 

65.7 

23.7 
42.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 83: Costs savings for businesses due to PMC9 in 2026, 2030, 2040 and 2050 in all policy options relative to 
the baseline (in million EUR, 2022 prices) 

Difference to the baseline 

Volume of second hand national sales in 
the affected MS (million vehicles) 
Volume of second hand cross border 
sales in the affected MS (million 
vehicles) 
National second hand sales with mileage 
fraud (million vehicles) 
Cross border sales with mileage fraud 
(million vehicles) 
National mileage fraud avoidance 
(million vehicles) 
Cross border mileage fraud avoidance 
(million vehicles) 
Costs savings from fraud avoidance 
(EUR million), of which: 

National 
Cross border 

2026 

21.92 

18.10 

1.04 

2.04 

1.01 

1.84 

6,043.0 

2,146.6 
3,896.4 

Source: Ricardo et al. (2024), Impact assessment support study 

2030 

23.05 

19.03 

1.10 

2.15 

1.07 

1.93 

6,352.9 

2,256.7 
4,096.2 

2040 

25.54 

20.28 

1.22 

2.31 

1.18 

2.08 

6,910.6 

2,501.8 
4,408.8 

2050 

25.26 

20.56 

1.22 

2.35 

1.18 

2.12 

6,990.9 

2,500.7 
4,490.1 

Table 84: Costs savings for businesses due to PMC9 in PO1a, PO1b, PO2 and PO3, expressed as present value 
over 2026-2050 relative to the baseline (in billion EUR, 2022 prices) 

Consumer savings from fraud avoidance, 
of which: 

National 
Cross border 

PO1a 

118.3 

42.2 
76.1 

Difference to the baseline 
PO1b 

PO2 

118.3 

42.2 
76.1 

118.3 

42.2 
76.1 

PO3 

118.3 

42.2 
76.1 

Source: Ricardo et al. (2024), Impact assessment support study 

3.10.  PM1 - RSI for heavy/powerful motorcycles (L category > 125cm3) as alternative measure, 
in Member States where they are not subject to PTI (i.e., using available opt-out) 

3.10.1.  Administrative costs for national public authorities  

PM1  will  require  that  those  Member  States  (BE,  FI,  IE,  NL,  MT,  PT)347  that  do  not  have  a  PTI 
requirement  for  motorcycles  introduce  roadside  inspections  for  motorcycles  over  125  cc  as  an 

347  Until  the  end  of  2023,  France  had  not  introduced  mandatory  PTI  for  motorcycles  but  the  French  authorities  had 
announced the intention to do so. For this reason, for the purposes of the analysis it was assumed that France would not 
be affected by the proposed measure. Denmark does not have mandatory PTI but it has introduced roadside inspections, 
and it is thus assumed to be part of the baseline. In the case of Portugal, current requirements cover only motorcycles 
over 250cc.  

148 

 
  
  
  
 
alternative.  The  roadside  inspections  are  expected  to  cover  5%  of  the  number  of  motorcycles 
registered every year. 

The average duration of a roadside inspection for heavy goods vehicles is around 25-30 minutes348 
but in the case of motorcycles it can be reasonably expected that this will be much shorter, given the 
size of the vehicle and the list of parameters to be inspected. It is assumed that, on average349, it will 
take 10 minutes which translates into an average cost of EUR 5.7 per inspection (assuming an hourly 
cost  of  EUR  34  for  technicians  and  associate  professionals  –  ISCO  3).  The  number  of  roadside 
inspections for motorcycles in PM1 is estimated at 80,443 in 2026, 82,566 in 2030 and 104,321 in 
2050 for the 6 Member States concerned. The recurrent administrative costs are estimated at EUR 
0.46 million in 2026, EUR 0.47 million in 2030 and EUR 0.59 million in 2050. Expressed as present 
value over 2026-2050, they are estimated at EUR 9.1 million relative to the baseline.  

3.10.2.  Adjustment costs for national public authorities  

Under PM1 it is assumed that the national public authorities of the 6 MS affected by the measure 
purchase  additional  equipment  to  support  the  additional  inspections.  For  a  5%  share  of  the 
motorcycles fleet, one extra RSI unit per MS is expected to be sufficient. With an estimated cost of 
EUR  20,000  per  unit  (according  to  input  from  stakeholders),  the  one-off  adjustment  costs  are 
estimated at EUR 120,000 in 2026.  

Recurrent adjustment costs (i.e., maintenance costs) are assumed to be around 10% of the capital 
costs and estimated at EUR 12,000 per year from 2026 onwards. Expressed as present value over 
2026-2050, they are estimated at EUR 0.2 million relative to the baseline. 

Table 85: Costs for national public authorities due to PM1 in 2026, 2030, 2040 and 2050 in policy options PO1a 
and PO2 relative to the baseline (in million EUR, 2022 prices) 

Additional number of roadside inspections  
Administrative costs (million EUR) 
Recurrent administrative costs 
Total adjustment costs (million EUR) 
One-off costs for equipment 
Recurrent maintenance costs 
Source: Ricardo et al. (2024), Impact assessment support study 

2026 
80,443 
0.46 
0.46 
0.13 
0.12 
0.01 

Difference to the baseline 

2030 
82,566 
0.47 
0.47 
0.01 
0.00 
0.01 

2040 
93,459 
0.53 
0.53 
0.01 
0.00 
0.01 

2050 
104,321 
0.59 
0.59 
0.01 
0.00 
0.01 

Table 86: Costs for national public authorities due to PM1 in PO1a and PO2, expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Administrative costs  
Recurrent administrative costs 
Total adjustment costs  
One-off costs for equipment 
Recurrent maintenance costs 
Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 
9.12  
9.12  
0.34  
0.12  
0.22  

Difference to the baseline 
PO1b 

PO2 
9.12  
9.12  
0.34  
0.12  
0.22  

PO3 

348 SWD(2012)206 
349 This includes the larger share of inspections where there are no specific issues identified on the basis of an initial 
inspection (where the duration can be even shorter than 10 minutes) and the smaller number of inspections that may 
require more extensive testing.  

149 

 
  
  
 
 
  
  
  
  
  
  
  
  
 
3.10.3.  Administrative cost for citizens (vehicle owners) 

Vehicle owners will experience some costs for the time spent for cooperating on roadside inspections 
with  the  public  authorities.  As  explained,  the  average  time  required  for  a  roadside  inspection  is 
estimated at 10 minutes. Considering an average hourly labour cost of EUR 29.5 and the number of 
roadside inspections, the administrative costs for citizens are estimated at EUR 0.40 million in 2026, 
EUR 0.41 million in 2030 and EUR 0.51 million in 2050. Expressed as present value over 2026-
2050, they are estimated at EUR 7.9 million relative to the baseline.  

Where a vehicle is found to be defective, the authorities may request the owner/holder of the vehicle 
to pay a charge corresponding to the cost of the test, in addition to the cost of repair. It is not possible 
to quantify the costs incurred in the form of such a charge, but they are expected to be limited. The 
cost of repair would have to be borne by the vehicle owner anyway; the RSI only helps identify the 
defects earlier. 

The tables below summarise the costs expected for citizens due to PM1.  

Table 87: Recurrent administrative costs for citizens due to PM1 in 2026, 2030, 2040 and 2050 in  policy options 
PO1a and PO2 relative to the baseline (in million EUR, 2022 prices) 

Additional number of roadside inspections  
Administrative costs (million EUR) 
Recurrent administrative costs 
Source: Ricardo et al. (2024), Impact assessment support study 

2026 
80,443 
0.40 
0.40 

Difference to the baseline 

2030 
82,566 
0.41 
0.41 

2040 
93,459 
0.46 
0.46 

2050 
104,321 
0.51 
0.51 

Table 88: Recurrent administrative costs for citizens due to PM1 in PO1a and PO2, expressed as  present value 
over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Administrative costs  
Recurrent administrative costs 
Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 
7.92  
7.92  

Difference to the baseline 
PO1b 

PO2 
7.92  
7.92  

PO3 

3.11.  PM2 - Mandatory PTI for motorcycles above 125cm3 (remove current opt-out) 

This measure introduces removing the current opt-out from the mandatory PTI for motorcycles.  

When  motorcycles  are  not  regularly  tested,  this  has  a  non-negligeable  impact  on  road  safety.  A 
comparison between the countries that apply PTI (ES, IT, DE) and FR that only introduced PTI for 
motorcycles in April 2024, is provided in the table below. The figures indicate the number of fatalities 
of occupants of powered two-wheelers in comparison to the fleet size of those vehicles in the four 
Member  States.  While  the  number  of  fatalities  is  highest  in  these  Member  States  (with  542 
motorcycle fatalities in DE, 417 in ES, 615 in FR, and 698 in IT, in 2019), the ratios below indicate 
that PTI for these vehicles probably has a noticeable impact. In fact, the differences are significant 
between the countries that apply PTI to both motorcycles and mopeds (ES and IT), to motorcycles 
only (DE) and FR that only introduced PTI for motorcycles in April 2024. 

Table 89: Fatalities of occupants of powered two wheelers (i.e., motorcycles and mopeds) per 1000 powered two 
wheelers 

DE 
ES 
FR 
IT 

2010 
0.19 
0.10 
0.28 
0.13 

2011 
0.20 
0.08 
0.29 
0.12 

2012 
0.17 
0.07 
0.28 
0.11 

2013 
0.16 
0.07 
0.28 
0.10 

2014 
0.16 
0.07 
0.29 
0.09 

2015 
0.17 
0.08 
0.29 
0.10 

2016 
0.14 
0.08 
0.29 
0.09 

2017 
0.15 
0.08 
0.26 
0.09 

2018 
0.16 
0.08 
0.25 
0.08 

2019 
0.13 
0.08 
0.25 
0.08 

150 

 
  
  
 
 
  
  
 
Source: CARE database and Statistical Pocketbook "EU transport in figures” 

3.11.1.  Adjustment costs for PTI centres 

PM2 implies that the capacity of PTI centres in the MS where PTI is not in place (BE, FI, IE, NL, 
MT, PT, DK)350 should be increased. The way that PTI services are organised in each Member States 
differ. The level of extra capacity and the associated costs that may arise to meet the extra demand 
are estimated recognising that there may be some differences among Member States.  

The additional number of inspections in the 7 MS is estimated at 733,056 in 2026, 751,660 in 2030 
and 941,911 in 2050351.  

Additional  PTI  lanes  to  deliver  these  inspections  will  be  needed.  Assuming  a  typical  PTI  lane 
operating 10 hours a day for 220 days, a total of up to 4,620 motorcycle inspections can be delivered. 
On the basis of the projected number of inspections, around 159 additional PTI lanes will be needed 
in 2026 and 45 additional ones by 2050 (204 additional PTI lanes in total over 2026-2050 relative to 
the baseline). The cost per PTI lane is estimated at EUR 20,000. The one-off adjustment costs are 
thus estimated at EUR 3.2 million in 2026, EUR 20,000 in 2030 and EUR 40,000 in 2050 relative to 
the  baseline.  Expressed  as  present  value  over  2026-2050,  they  are  estimated  at  EUR  3.8  million 
relative to the baseline.  

Recurrent maintenance costs for the PTI lanes are assumed at 10% of the capital costs (i.e., EUR 
2,000 per lane). They are estimated at EUR 318,000 in 2026, EUR 326,000 in 2030, going up to EUR 
408,000 in 2050 due to the additional PTI lanes added over time in line with the projected growth in 
the number of inspections. Expressed as present value over 2026-2050, the recurrent adjustment costs 
for the maintenance of the PTI lanes are estimated at EUR 6.3 million relative to the baseline.  

The average duration of a PTI inspection for motorcycles is around 20 minutes. The labour costs per 
inspection  are  estimated  at  EUR  11.3,  assuming  an  hourly  cost  of  EUR  34  for  technicians  and 
associate  professionals  (ISCO  3).  To  deliver  the  estimated  additional  number  of  inspections,  the 
recurrent adjustment costs are estimated at EUR 8.3 million in 2026, EUR 8.5 million in 2030 and 
EUR 10.7 million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 
165.5 million relative to the baseline.  

The number of additional inspectors that need to be trained for performing the PTIs in the 7 Member 
States concerned by PM2 is estimated at 167 in 2026, and 48 additional ones by 2050 (215 inspectors 
to  be  trained  in  total  over  2026-2050  relative  to  the  baseline).  They  are  estimated  based  on  the 
projected number of additional PTIs in the 7 Member States and the average number of PTIs per 
inspector (i.e., 4,380). Assuming a two-day training for the additional inspectors, at an hourly cost of 
EUR 34 for technicians and associate professionals – ISCO 3), the total one-off adjustment costs for 
training are estimated at EUR 82,634 in 2026, EUR 495 in 2030 and EUR 990 in 2050. Expressed as 
present value over 2026-2050, they are estimated at EUR 98,875 relative to the baseline. 

350 France has not introduced mandatory PTI for motorcycles up to now but the French authorities have announced the 
intention to do so. For this reason, for the purposes of the analysis it is assumed that France will not be affected by the 
proposed measure.  
351 This is estimated as the number of motorcycles in the baseline from the PRIMES-TREMOVE model, multiplied by 
the average number of inspections per motorcycle over its lifetime (estimated at 8) and divided by the average age of a 
motorcycle (18 years). The average number of inspections per motorcycle is calculated based on the assumed frequency 
and average age. 

151 

 
 
 
The tables below summarise the costs expected for PTI centres due to PM2. 

Table 90: Adjustment costs for PTI centres due to PM2 in 2026, 2030, 2040 and 2050 in policy option PO1b relative 
to the baseline (in million EUR, 2022 prices) 

Additional number of inspections  
Total adjustment costs 
One-off costs for the additional PTI lanes 
Recurrent costs for the maintenance of the PTI lanes 
Recurrent labour costs for inspections 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

2026 
733,056 
11.88 
3.18 
0.32 
8.30 
0.08 

2030 
751,660 
8.86 
0.02 
0.33 
8.51 
0.00 

2040 
847,034 
10.00 
0.04 
0.37 
9.60 
0.00 

2050 
941,911 
11.12 
0.04 
0.41 
10.67 
0.00 

Table  91:  Adjustment  costs  for  PTI  centres  due  to  PM2  in  PO1b,  expressed  as  present  value  over  2026-2050 
relative to the baseline (in million EUR, 2022 prices) 

Difference to the baseline 

PO1a 

Total adjustment costs 
One-off costs for the additional PTI lanes 
Recurrent costs for the maintenance of the PTI lanes 
Recurrent labour costs for inspections 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

PO1b 
175.7 
3.8 
6.3 
165.5 
0.1 

3.11.2.  Enforcement costs for national public authorities 

PO2 

PO3 

The  introduction  of  mandatory  PTI  will  also  imply  some  extra  costs  for  the  authorities  that  are 
responsible for monitoring the operation of the system, evaluating the quality of the PTI inspections. 
The Dutch authorities (RDW) reported that around EUR 4.5 per PTI is charged to vehicle owners to 
cover  the  costs  of  monitoring  by  authorities.  The  Dutch  system  includes  random  inspections  of 
vehicles done by RDW as a way to check the quality of PTI inspections. This is not an approach 
adopted in other Member States and it is not a requirement of the Directive. As such, the cost of EUR 
4.5 per PTI is not considered representative of the typical monitoring costs. For the calculations, an 
average  monitoring  cost  of  EUR  2.25  per  PTI  is  assumed  (50%  of  the  cost  provided  by  RDW). 
Recurrent enforcement costs are thus estimated at EUR 1.6 million in 2026, EUR 1.7 million in 2030 
and EUR 2.1 million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 
32.9 million relative to the baseline. 

Table 92: Enforcement costs for national public authorities due to PM2 in 2026, 2030, 2040 and 2050 in policy 
option PO1b relative to the baseline (in million EUR, 2022 prices) 

Recurrent enforcement costs 
Source: Ricardo et al. (2024), Impact assessment support study 

2026 
1.6 

Difference to the baseline 

2030 
1.7 

2040 
1.9 

2050 
2.1 

152 

 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
Table 93: Enforcement costs for national public authorities due to PM2 in PO1b, expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent enforcement costs 
Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 

Difference to the baseline 

PO1b 
32.9  

PO2 

PO3 

3.11.3.  Administrative costs for citizens (vehicle owners) 

Mandatory PTI for motorcycles translate into additional costs for vehicles owners in the Member 
States affected. Using the median of the charges per PTI test from the other Member States, estimated 
at  EUR  20.1,  the  recurrent  administrative  costs  for  citizens  are  estimated  at  EUR  14.8  million  in 
2026, EUR 15.1 million in 2030 and EUR 19 million in 2050. Expressed as present value over the 
2026-2050 period, they are estimated at EUR 294.1 million.  

Motorcycle owners with identified defective motorcycles will incur costs to repair their motorcycles 
while they will also need to spend some time to travel to PTI centres, thus incurring some extra costs. 
However, these may vary significantly by vehicle and were not possible to quantify.  

The tables below summarise the costs for citizens expected for PM2 in PO1b.  

Table 94: Administrative costs for citizens (vehicle owners) due to PM2 in 2026, 2030, 2040 and 2050 in policy 
option PO1b relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 
Source: Ricardo et al. (2024), Impact assessment support study 

2026 
14.8 

Difference to the baseline 

2030 
15.1 

2040 
17.1 

2050 
19.0 

Table 95: Administrative costs for citizens (vehicle owners) due to PM2 in PO1b, expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 
Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 

3.11.4.  Benefits for PTI centres 

Difference to the baseline 

PO1b 
294.1  

PO2 

PO3 

PM2 would result in benefits for the PTI centres in the 7 MS affected, due to the mandatory PTI for 
heavy/powerful  motorcycles.  The  costs  for  vehicle  owners  (citizens)  discussed  above  represent 
revenues for the PTI centres. The total revenues for PTI centres due to PM2 are estimated at EUR 
14.8 million in 2026, EUR 15.1 million in 2030 and EUR 19 million in 2050. Expressed as present 
value over 2026-2050, they are estimated at EUR 294.1 million relative to the baseline. 

Table 96: Benefits for PTI centres due to PM2 in 2026, 2030, 2040 and 2050 in policy option PO1b relative to the 
baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

Difference to the baseline 

2026 
14.8 

2030 
15.1 

2040 
17.1 

2050 
19.0 

Source: Ricardo et al. (2024), Impact assessment support study 

153 

 
  
 
 
 
  
  
 
 
 
  
Table 97: Benefits for PTI centres due to PM2 policy option PO1b, expressed as  present value over 2026-2050 
relative to the baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

Difference to the baseline 

PO1a 

PO1b 
294.1  

PO2 

PO3 

Source: Ricardo et al. (2024), Impact assessment support study 

3.12.  PM3  -  Extend  PTI  to  all  motorcycles  (i.e.,  including  from  50cm3  =  all  L3e,  L4e,  plus 

tricycles (L5e) and heavy quadricycles (L7e)) 

3.12.1.  Adjustment costs for PTI centres 

PM3 extends the type of motorcycles covered by PTI to those from 50cm3 in the eight Member States 
where such requirement is currently not in place (BE, FI, IE, NL, MT, PT, DK, CY352).  

The additional number of inspections in the 8 MS affected is estimated at 845,522 in 2026, 869,017 
in 2030 and 1,097,479 in 2050353.  

Similarly to PM2, additional PTI lanes to deliver these inspections will be needed. Assuming a typical 
PTI lane operating 10 hours a day for 220 days, a total of up to 4,620 motorcycle inspections can be 
delivered. On the basis of the projected number of inspections, around 183 additional PTI lanes will 
be needed in 2026 and 55 additional ones by 2050 (238 additional PTI lanes in total over 2026-2050 
relative to the baseline). The cost per PTI lane is estimated at EUR 20,000. The one-off adjustment 
costs are estimated at EUR 3.7 million in 2026, EUR 20,000 in 2030 and EUR 60,000 in 2050 relative 
to the baseline. Expressed as present value over 2026-2050, they are estimated at EUR 4.4 million 
relative to the baseline.  

Recurrent maintenance costs for the PTI lanes are assumed at 10% of the  capital costs (i.e., EUR 
2,000 per lane). They are estimated at EUR 366,000 in 2026, EUR 376,000 in 2030, going up to EUR 
476,000 in 2050 due to the additional PTI lanes added over time in line with the projected growth in 
the number of inspections. Expressed as present value over 2026-2050, the recurrent adjustment costs 
for the maintenance of the PTI lanes are estimated at EUR 7.3 million relative to the baseline.  

The average duration of a PTI inspection for motorcycles is around 20 minutes. The labour costs per 
inspection  are  estimated  at  EUR  11.3,  assuming  an  hourly  cost  of  EUR  34  for  technicians  and 
associate  professionals  (ISCO  3).  To  deliver  the  estimated  additional  number  of  inspections,  the 
recurrent adjustment costs are estimated at EUR 9.6 million in 2026, EUR 9.8 million in 2030 and 
EUR 12.4 million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 
192.1 million relative to the baseline.  

The number of additional inspectors that need to be trained for performing the PTIs in the 8 Member 
States concerned by PM3 is estimated at 193 in 2026, and 58 additional ones by 2050 (251 inspectors 
to  be  trained  in  total  over  2026-2050  relative  to  the  baseline).  They  are  estimated  based  on  the 
projected number of additional PTIs in the 8 Member States and the average number of PTIs per 
inspector (i.e., 4,380). Assuming a two-day training for the additional inspectors, at an hourly cost of 
EUR 34 for technicians and associate professionals – ISCO 3), the total one-off adjustment costs for 

352 In Cyprus motorcycles above 125cm3 are already covered.  
353 This is estimated as the number of motorcycles in the baseline from the PRIMES-TREMOVE model, multiplied by 
the average number of inspections per motorcycle over its lifetime (estimated at 8) and divided by the average age of a 
motorcycle (18 years). The average number of inspections per motorcycle is calculated based on the assumed frequency 
and average age. 

154 

 
  
 
 
 
 
 
 
 
 
training are estimated at EUR 95,499 in 2026, EUR 495 in 2030 and EUR 1,484 in 2050. Expressed 
as present value over 2026-2050, they are estimated at EUR 115,102 relative to the baseline. 

The tables below summarise the costs expected for PTI centres due to PM3. 

Table 98: Adjustment costs for PTI centres due to PM3 in 2026, 2030, 2040 and 2050 in policy option PO3 relative 
to the baseline (in million EUR, 2022 prices) 

Additional number of inspections  
Total adjustment costs 
One-off costs for the additional PTI lanes 
Recurrent costs for the maintenance of the PTI lanes 
Recurrent labour costs for inspections 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

2026 
845,522 
13.70 
3.66 
0.37 
9.58 
0.10 

2030 
869,017 
10.24 
0.02 
0.38 
9.84 
0.00 

2040 
985,326 
11.65 
0.06 
0.43 
11.16 
0.00 

2050 
1,097,479 
12.97 
0.06 
0.48 
12.43 
0.00 

Table 99: Adjustment costs for PTI centres due to PM3 in PO3, expressed as present value over 2026-2050 relative 
to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for the additional PTI lanes 
Recurrent costs for the maintenance of the PTI lanes 
Recurrent labour costs for inspections 
One-off costs for training 
Source: Ricardo et al. (2024), Impact assessment support study 

3.12.2.  Enforcement cost for national public authorities 

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 
203.9 
4.4 
7.3 
192.1 
0.1 

The  introduction  of  mandatory  PTI  will  also  imply  some  extra  costs  for  the  authorities  that  are 
responsible for monitoring the operation of the system, evaluating the quality of the PTI inspections. 
The Dutch authorities (RDW) reported that around EUR 4.5 per PTI is charged to vehicle owners to 
cover  the  costs  of  monitoring  by  authorities.  The  Dutch  system  includes  random  inspections  of 
vehicles done by RDW as a way to check the quality of PTI inspections. This is not an approach 
adopted in other Member States and it is not a requirement of the Directive. As such, the cost of EUR 
4.5 per PTI is not considered representative of the typical monitoring costs. For the calculations, an 
average  monitoring  cost  of  EUR  2.25  per  PTI  is  assumed  (50%  of  the  cost  provided  by  RDW). 
Recurrent enforcement costs are thus estimated at EUR 1.9 million in 2026, EUR 2 million in 2030 
and EUR 2.5 million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 
38.1 million relative to the baseline. 

Table 100: Enforcement costs for national public authorities due to PM3 in 2026, 2030, 2040 and 2050 in policy 
option PO3 relative to the baseline (in million EUR, 2022 prices) 

Recurrent enforcement costs 
Source: Ricardo et al. (2024), Impact assessment support study 

2026 
1.9 

Difference to the baseline 

2030 
2.0 

2040 
2.2 

2050 
2.5 

155 

 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
Table 101: Enforcement costs for national public authorities due to PM3 in PO3, expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent enforcement costs 
Source: Ricardo et al. (2024), Impact assessment support study 

3.12.3.  Administrative cost for citizens (vehicle owners) 

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 
38.1  

Mandatory PTI for motorcycles translate into additional costs for vehicles owners in the Member 
States affected. Using the median of the charges per PTI test from the other Member States, estimated 
at EUR 20.1, the recurrent administrative costs for citizens are estimated at EUR 17 million in 2026, 
EUR 17.5 million in 2030 and EUR 22.1 million in 2050. Expressed as present value over the 2026-
2050 period, they are estimated at EUR 341.3 million.  

Motorcycle owners with identified defective motorcycles will incur costs to repair their motorcycles 
while they will also need to spend some time to travel to PTI centres, thus incurring some extra costs. 
However, these may vary significantly by vehicle and were not possible to quantify them.  

The tables below summarise the costs for citizens (vehicle owners) expected for PM3 in PO3. 

Table 102: Administrative costs for citizens (vehicle owners) due to PM3 in 2026, 2030, 2040 and 2050 in policy 
option PO3 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 
Source: Ricardo et al. (2024), Impact assessment support study 

2026 
17.0 

Difference to the baseline 

2030 
17.5 

2040 
19.8 

2050 
22.1 

Table 103: Administrative costs for citizens (vehicle owners) due to PM3 in PO3, expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 
Source: Ricardo et al. (2024), Impact assessment support study 

3.12.4.  Benefits for PTI centres 

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 
341.3  

PM3 would result in benefits for the PTI centres in the 8 MS affected, due to the extension of PTI to 
all motorcycles. The costs for vehicle owners (citizens) discussed above represent revenues for the 
PTI centres. The total revenues for PTI centres due to PM3 are estimated at EUR 17 million in 2026, 
EUR 17.5 million in 2030 and EUR 22.1 million in 2050. Expressed as present value over 2026-
2050, they are estimated at EUR 341.3 million relative to the baseline. 

Table 104: Benefits for PTI centres due to PM3 in 2026, 2030, 2040 and 2050 in policy option PO3 relative to the 
baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

Difference to the baseline 

2026 
17.0 

2030 
17.5 

2040 
19.8 

2050 
22.1 

Source: Ricardo et al. (2024), Impact assessment support study 

156 

 
  
 
 
 
  
  
 
 
 
  
Table 105: Benefits for PTI centres due to PM3 in policy option PO3, expressed as present value over 2026-2050 
relative to the baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

Source: Ricardo et al. (2024), Impact assessment support study 

3.13.  PM4 – Mandatory PTI for light trailers (O1 and O2 categories) 

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 
341.3  

PM4 requires the mandatory PTI for light trailers (O1 and O2 categories). Eleven Member States 
would be affected by PM4: 7 Member States where there is currently no requirement for PTI for 
either O1 or O2 (DK, EL, FI, FR, NL, IE, PT) and 4 Member States where there is currently only a 
requirement for PTI for O2 (PL, SK, BE and ES).  

3.13.1.  Adjustment costs for PTI centres  

Assuming a frequency scheme of 4/2/2 the additional number of inspections due to PM4 in the 11 
MS is estimated at 1.3 million in 2026, 1.4 million in 2030 and 1.6 million in 2050354, of which for 
O1 category 724,302 inspections in 2026, 753,381 in 2030 and 830,560 in 2050 and for O2 category 
597,825 inspections in 2026, 638,053 in 2030 and 734,593 in 2050. 

Additional PTI lanes to deliver these inspections may be needed, although it is possible that extra 
utilisation  of  the  existing  capacity  may  allow  to  cover  at  least  part  of  the  extra  demand.  For  the 
assessment, it has been assumed that additional PTI lanes would be needed for inspections of O2 
category  trailers  only355.  Assuming  a  typical  PTI  lane  operating  for  220  days  and  allowing  the 
inspection of 28 trailers per day, a total of up to 6,160 inspections can be delivered for O2 trailers per 
year by a PTI lane. On the basis of the projected number of inspections, around 97 additional PTI 
lanes will be needed in 2026 and 22 additional ones by 2050 (119 additional PTI lanes in total over 
2026-2050 relative to the baseline). The cost of an additional PTI lane for trailers is estimated at EUR 
10,000  per  lane.  The  one-off  adjustment  costs  are  thus  estimated  at  EUR  970,000  in  2026,  EUR 
20,000 in 2030 and no extra costs in 2050 relative to the baseline. Expressed as present value over 
2026-2050, they are estimated at EUR 1.1 million relative to the baseline.  

Recurrent maintenance costs for the PTI lanes are assumed at 10% of the capital costs (i.e., EUR 
1,000 per lane). They are estimated at EUR 97,000 in 2026, EUR 104,000 in 2030, going up to EUR 
119,000 in 2050 due to the additional PTI lanes added over time in line with the projected growth in 
the number of inspections. Expressed as present value over 2026-2050, the recurrent adjustment costs 
for the maintenance of the PTI lanes are estimated at EUR 2 million relative to the baseline.  

The  average  duration  of  a  PTI  inspection  for  trailers  is  around  15  minutes.  The  labour  costs  per 
inspection are estimated at EUR 8.5, assuming an hourly cost of EUR 34 for technicians and associate 
professionals  (ISCO  3).  To  deliver  the  estimated  additional  number  of  inspections,  the  recurrent 

354 This is estimated as the number of trailers in the baseline, multiplied by the average number of inspections per trailer 
over its lifetime (estimated at 8) and divided by the average age of a trailer (18 years).  
355 For the inspection of O2 trailers a rolling brake test equipment will be needed (not needed for O1 trailers) which, 
given the expected volume of trailers to be tested may lead to the need of extra capacity. Some stakeholders indicated 
that the inspections can be carried out with the existing equipment but for the assessment it is considered that due to the 
significant extra volume of inspections expected, extra investment would be needed in PTI lanes for O2 trailers. In the 
case  of  O1  trailers visual  inspection  is  expected  to  be  sufficient  and  thus  no  additional PTI  lanes  are  expected  to  be 
needed.  The  feedback  received  from  stakeholders  in  the  context  of  the  stakeholders’  survey  indicated  that  no  extra 
equipment is needed for O1 trailers. No stakeholder mentioned the need for extra space and the costs associated to it. 
Thus, although additional costs for O1 trailers are possible, they are not considered significant and not estimated. 

157 

 
  
 
 
 
 
adjustment costs are estimated at EUR 11.2 million in 2026, EUR 11.8 million in 2030 and EUR 13.3 
million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 222.3 million 
relative to the baseline.  

No training costs are expected since the inspections required are similar to those of other vehicles. 

Table 106: Adjustment costs for PTI centres due to PM4 in 2026, 2030, 2040 and 2050 in policy option PO3 relative 
to the baseline (in million EUR, 2022 prices) 

Additional number of inspections, of which: 

for O1 category 
for O2 category 

Total adjustment costs 
One-off costs for the additional PTI lanes 
Recurrent costs for the maintenance of the PTI lanes 

Recurrent labour costs for inspections 

2026 
1,322,127 
724,302 
597,825 
12.3 
1.0 

0.1 

11.2 

Difference to the baseline 

2030 
1,391,434 
753,381 
638,053 
11.9 
0.0 

0.1 

11.8 

2040 
1,513,772 
810,970 
702,803 
13.0 
0.0 

0.1 

12.9 

2050 
1,565,153 
830,560 
734,593 
13.4 
0.0 

0.1 

13.3 

Source: Ricardo et al. (2024), Impact assessment support study 

Table  107:  Adjustment  costs  for  PTI  centres  due  to  PM4  in  PO3,  expressed  as  present  value  over  2026-2050 
relative to the baseline (in million EUR, 2022 prices) 

Difference to the baseline 

PO1a 

PO1b 

PO2 

Total adjustment costs 
One-off costs for the additional PTI lanes 
Recurrent costs for the maintenance of the PTI lanes 

Recurrent labour costs for inspections 

Source: Ricardo et al. (2024), Impact assessment support study 

3.13.2.  Enforcement costs for national public authorities 

PO3 
225.4 
1.1 
2.0 

222.3 

Similarly to PM2 and PM3, the introduction of mandatory PTI will also imply some extra costs for 
the  authorities  that  are  responsible  for  monitoring  the  operation  of  the  system  and  evaluating  the 
quality of the PTI inspections. The approach for estimating the recurrent enforcement costs is similar 
to that explained under PM3. However, lower costs per trailer are assumed for monitoring in this case 
(EUR  1.5  per  trailer  inspection  versus  EUR  2.25  per  motorcycle  inspection).  The  recurrent 
enforcement costs for the 11 Member States affected by PM4 are estimated at EUR 2 million in 2026, 
EUR 2.1 million in 2030 and EUR 2.3 million in 2050. Expressed as present value over 2026-2050, 
they are estimated at EUR 39.2 million.  

Table 108: Enforcement costs for national public authorities due to PM4 in 2026, 2030, 2040 and 2050 in policy 
option PO3 relative to the baseline (in million EUR, 2022 prices) 

Recurrent enforcement costs 

2026 
2.0 

Difference to the baseline 

2030 
2.1 

2040 
2.3 

2050 
2.3 

Source: Ricardo et al. (2024), Impact assessment support study 

158 

 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
  
Table 109: Enforcement costs for national public authorities due to PM4 in PO3, expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent enforcement costs 

Source: Ricardo et al. (2024), Impact assessment support study 

3.13.3.  Administrative cost for businesses (vehicle owners)  

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 
39.2 

Mandatory PTI for trailers translate into additional costs for vehicles owners in the Member States 
affected. To calculate the costs, it is assumed that all O2 trailers and half of the O1 trailers are owned 
by business. Charges for PTI for trailers are expected to be no greater than those for motorcycles, 
considering also that there is no emissions test. Assuming a fee per PTI test for trailers of EUR 20.1, 
the recurrent administrative costs for businesses are estimated at EUR 19.3 million in 2026, EUR 
20.4 million in 2030 and EUR 23.1 million in 2050. Expressed as present value over the 2026-2050 
period, they are estimated at EUR 385.1 million. 

The tables below summarise the administrative costs for businesses expected for PM4.  

Table 110: Administrative costs for businesses (vehicle owners) due to PM4 in 2026, 2030, 2040 and 2050 in policy 
option PO3 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 

Difference to the baseline 

2026 
19.3 

2030 
20.4 

2040 
22.3 

2050 
23.1 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 111: Administrative costs for businesses (vehicle owners) due to PM4 in PO3, expressed as present value 
over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 

Source: Ricardo et al. (2024), Impact assessment support study 

3.13.4.  Administrative cost for citizens (vehicle owners)  

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 
385.1 

As explained above, mandatory PTI for trailers translate into additional costs for vehicles owners in 
the Member States affected. To calculate the costs citizens, it is assumed that half of the O1 trailers 
are  owned  by  citizens.  Assuming  a  charge  per  PTI  test  for  trailers  of  EUR  20.1,  the  recurrent 
administrative costs for citizens are estimated at EUR 7.3 million in 2026, EUR 7.6 million in 2030 
and  EUR  8.4  million  in  2050.  Expressed  as  present  value  over  the  2026-2050  period,  they  are 
estimated at EUR 141.5 million. 

The tables below summarise the administrative costs for citizens expected for PM4.  

Table 112: Administrative costs for citizens (vehicle owners) due to PM4 in 2026, 2030, 2040 and 2050 in policy 
option PO3 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 

Difference to the baseline 

2026 
7.3 

2030 
7.6 

2040 
8.2 

2050 
8.4 

Source: Ricardo et al. (2024), Impact assessment support study 

159 

 
  
 
 
 
  
  
 
 
 
  
Table 113: Administrative costs for citizens (vehicle owners) due to PM4 in PO3, expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 

Source: Ricardo et al. (2024), Impact assessment support study 

3.13.5.  Benefits for PTI centres 

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 
141.5 

PM4 would result in benefits for the PTI centres in the MS affected, due to the mandatory PTI for 
light  trailers.  The  costs  for  vehicle  owners  (citizens  and  businesses)  discussed  above  represent 
revenues for the PTI centres. The total revenues for PTI centres due to PM4 are estimated at EUR 
26.6 million in 2026, EUR 28 million in 2030 and EUR 31.5 million in 2050. Expressed as present 
value over 2026-2050, they are estimated at EUR 526.6 million relative to the baseline. 

Table 114: Benefits for PTI centres due to PM4 in 2026, 2030, 2040 and 2050 in policy option PO3 relative to the 
baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

Difference to the baseline 

2026 
26.6 

2030 
28.0 

2040 
30.5 

2050 
31.5 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 115: Benefits for PTI centres due to PM4 in policy option PO3, expressed as present value over 2026-2050 
relative to the baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 
526.6  

3.14.  PM5 – Annual emission testing for light commercial vehicles (N1) instead of the currently 

required 4-2-2 frequency 

PM5 includes a requirement for annual emission testing for light commercial vehicles (N1) instead 
of the currently required 4-2-2 frequency. It assumes additional emission testing in all Member States. 
The  assessment  of  PM5  (included  in  PO1b,  PO2  and  PO3)  takes  into  account  the  synergies  with 
PMC3 on a proposed PN testing at PTI and with PMC4 on a new NOx test.  

3.14.1.  Adjustment costs for PTI centres  

The additional number of emission testing for internal combustion light commercial vehicles due to 
PM5 is estimated at 14.3 million in 2026, 14.2 million in 2030 and 1.2 million in 2050 relative to the 
baseline356. The decrease in the number of emission testing is driven by the decrease in the number 
of internal combustion light commercial vehicles over time. This is due to the Regulation on CO2 
standards for LDVs that is included in the baseline.  

PM5 is expected to lead to one-off adjustment costs for additional emission testing equipment. Based 
on stakeholders’ feedback, the price for new PN measurement equipment is estimated at EUR 5,000 
per equipment and that for new NOx measurement equipment at EUR 15,000. One tool per inspector 
is required.  

356  The  number  of  inspections  is  estimated  based  on  the  projected  number  of  internal  combustion  light  commercial 
vehicles from the PRIMES-TREMOVE model.  

160 

 
  
 
 
 
  
  
 
 
 
 
The average number of full PTI inspections per inspector is estimated at 2,920 per year. However, 
emission testing is estimated to take only around 20% of the time of a full PTI inspection (i.e., around 
6 minutes). Thus, it is estimated that up to 14,600 emission inspections per year can be delivered per 
inspector.  Assuming  that  one  emission  testing  equipment  per  inspector  is  needed,  the  required 
number of additional PN and NOx measurement equipment due to PM5 is estimated at 979 in 2026. 
Total one-off adjustment costs for equipment are thus estimated at EUR 19.6 million in 2026 relative 
to  the  baseline.  Recurrent  adjustment  costs  for  the  calibration  and  maintenance  of  PN  and  NOx 
equipment are estimated at 5% of the capital costs (i.e., EUR 250 per PN equipment and EUR 750 
per NOx equipment), equivalent to EUR 979,000 per year from 2026 onwards. Expressed at present 
value over 2026-2050, the recurrent adjustment costs are estimated at EUR 17.6 million.  

Training of additional inspectors will also be required due to PM5. The number of inspectors to be 
trained  in  2026  is  estimated  at  979.  Assuming  a  two-day  training  for  the  additional  inspectors, 
including for the PN and NOx testing,  at an hourly cost of EUR 34 for technicians and associate 
professionals – ISCO 3), the total one-off adjustment costs for training are estimated at EUR 484,425 
in 2026. 

Combined, the average duration of the new PN and NOx emission tests is around 6 minutes. The 
labour costs per emission testing are estimated at EUR 3.4, assuming an hourly cost of EUR 34 for 
technicians  and  associate  professionals  (ISCO  3).  To  deliver  the  estimated  additional  number  of 
emission testing, the recurrent adjustment costs are estimated at EUR 48.6 million in 2026, EUR 48.2 
million in 2030 and EUR 3.9 million in 2050357. Expressed as present value over 2026-2050, they 
are estimated at EUR 610.1 million relative to the baseline.  

Table 116: Adjustment costs for PTI centres due to PM5 in  2026, 2030, 2040 and 2050 in policy options PO1b, 
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Additional number of emission testing 
Total adjustment costs 
One-off costs for equipment 
Recurrent  costs  for 
equipment 
Recurrent labour costs for PN and NOx tests 
One-off costs for training 

the  maintenance  of 

Difference to the baseline 

2026 
14,287,176 
69.6 
19.6 

2030 
14,187,947 
49.2 
0.0 

2040 
8,012,878 
28.2 
0.0 

1.0 

48.6 
0.5 

1.0 

48.2 
0.0 

1.0 

27.2 
0.0 

2050 
1,156,079 
4.9 
0.0 

1.0 

3.9 
0.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 117: Adjustment costs for PTI centres due to PM5 in PO1b, PO2 and PO3, expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for equipment 
Recurrent costs for the maintenance of equipment 
Recurrent labour costs for PN and NOx tests 
One-off costs for training 

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

PO1a 
0.0 
0.0 
0.0 
0.0 
0.0 

PO1b 
647.7 
19.6 
17.6 
610.1 
0.5 

PO2 
647.7 
19.6 
17.6 
610.1 
0.5 

PO3 
647.7 
19.6 
17.6 
610.1 
0.5 

3.14.2.  Administrative cost for businesses (vehicle owners)  

The introduction of annual emission testing for N1 vehicles will result in recurrent administrative 
costs for vehicle owners (i.e., businesses in case of N1 vehicles) due to the testing charges. Taking 

357 The labour costs decrease over time due to the decreasing number of internal combustion light commercial vehicles. 

161 

 
  
  
 
into account feedback from stakeholder interviews, the new emission test (involving PN and NOx 
testing) is expected to cover 20% (6 minutes) of the total PTI duration. Considering the median charge 
per vehicle of EUR 40.5 per N1 vehicle and the 20% share of the time covering the PN and NOx 
testing, the recurrent administrative costs for vehicle owners are estimated at 115.8 million in 2026, 
EUR 115 million in 2030 and EUR 9.4 million in 2050. Expressed as present value over the 2026-
2050 period, they are estimated at EUR 1.5 billion relative to the baseline.  

The tables below summarise the impact of PM5 (included in PO1b, PO2 and PO3) on businesses. 

Table 118: Administrative costs for businesses (vehicle owners) due to PM5 in 2026, 2030, 2040 and 2050 in policy 
options PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 

Difference to the baseline 

2026 
115.8 

2030 
115.0 

2040 
64.9 

2050 
9.4 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 119: Administrative costs for businesses (vehicle owners) due to PM5 in PO1b, PO2 and PO3 expressed as 
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 

Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 

3.14.3.  Benefits for PTI centres 

Difference to the baseline 
PO1b 
1,454.8  

PO2 
1,454.8  

PO3 
1,454.8  

PM5  would  result  in  benefits  for  the  PTI  centres  due  to  the  annual  emission  testing  for  light 
commercial vehicles (N1) instead of the currently required 4-2-2 frequency. The costs for vehicle 
owners (businesses) discussed above represent revenues for the PTI centres. The total revenues for 
PTI centres due to PM5 are estimated at EUR 115.8 million in 2026, EUR 115 million in 2030 and 
EUR 9.4 million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 1.5 
billion relative to the baseline. 

Table 120: Benefits for PTI centres due to PM5 in 2026, 2030, 2040 and 2050 in policy options PO1b, PO2 and 
PO3 relative to the baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

2026 
115.8 

Difference to the baseline 
2040 
2030 
64.9 
115.0 

2050 
9.4 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 121: Benefits for PTI centres due to PM5 in policy options PO1b, PO2 and PO3, expressed as present value 
over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

PO1a 

Difference to the baseline 
PO2 
PO1b 
1,454.8  
1,454.8  

PO3 
1,454.8  

Source: Ricardo et al. (2024), Impact assessment support study 

3.15.  PM6 – Mandatory yearly testing for vehicles that are 10-year-old or older 

Currently,  11  MS  do  not  require  annual  PTI  testing  of  light-duty  vehicles  after  10  years  of  their 
registration (CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT, SK). All these Member States currently 
require an inspection every two years which means that the proposed measure will double the number 
of inspections for vehicles over 10 years.  

The  assessment  of  PM6  (included  in  PO1b,  PO2  and  PO3)  takes  into  account  the  synergies  with 
PMC3 on a proposed PN testing at PTI and with PMC4 on a new NOx test. It also takes into account 

162 

 
  
  
 
  
  
 
the synergies with  PMC1 concerning the PTI of electric vehicles  and PMC2 on updates to  cover 
General Safety Regulation Requirements. However, no additional costs are expected in relation to 
PMC1 and PMC2 given that the relevant update of the tools already used will need to take place 
irrespective of the frequency of the test. 

Furthermore,  the  costs  related  to  PM5  (included  in  PO1b,  PO2  and  PO3)  for  emission  testing 
associated to N1 vehicles aged 10 years or older overlap with PM6 and are thus not considered under 
the assessment of PM6, to avoid double-counting in estimating the costs of PO1b, PO2 and PO3.  

3.15.1.  Adjustment costs for PTI centres  

The additional number of PTIs for M1 vehicles category due to PM6 is estimated at 41.1 million in 
2026, 42.1 million in 2030 and 47.5 million in 2050 and for N1 vehicle category at 4.3 million in 
2026, 4.5 million in 2030 and 5.2 million in 2050. 

PM6 is expected to lead to one-off adjustment costs for inspection centres for the additional emission 
testing equipment and for additional PTI lanes. As explained in PMC3 and PMC4, the cost per new 
PN testing equipment is assumed at EUR 5,000 and for NOx testing at EUR 15,000 per equipment. 
In addition, based on an interview with TUV Rheinland, the cost of a new PTI lane is assumed at 
EUR 50,000.  

Based on the capacity of a PTI lane to process 3,080 inspections of M1 and N1 vehicles per year, the 
additional  inspections  will  require  14,746  new  PTI  lanes  across  the  EU27  in  2026  and  2,359 
additional ones by 2050 (17,105 new PTI lanes in total over 2026-2050). Of this, the new PTI lanes 
for M1 vehicles represent 13,353 in 2026 and 2,057 additional ones by 2050 (15,410 new PTI lanes 
over 2026-2050). Each new lane for M1 vehicles in 2026 will also require one set of PN and NOx 
testing  equipment358.  Additional  PN  testing  and  NOx  testing  equipment  is  assumed  only  for  M1 
vehicles categories as the costs for such equipment related to N1 vehicles is already reflected in PM5. 
Thus, the one-off costs for equipment are estimated at EUR 1 billion in 2026, EUR 4.9 million in 
2030 and EUR 1.7 million in 2050. Expressed as present value over 2026-2050, they are estimated 
at EUR 1.1 billion.  

Recurrent maintenance costs for the PTI lanes are assumed at 10% of the capital costs (i.e., EUR 
5,000 per lane). In addition, annual maintenance costs to calibrate, repair and update the additional 
PN and NOx equipment for M1 vehicles inspections is estimated at 5% of the initial cost (around 
EUR 250 for PN-PTI equipment and 750 EUR for NOx equipment). Total recurrent adjustment costs 
for equipment are thus estimated at EUR 87.1 million in 2026, EUR 89 million in 2030, going up to 
EUR 98.9 million in 2050 due to the additional PTI lanes added over time in line with the projected 
growth in the number of inspections. Expressed as present value over 2026-2050, they are estimated 
at EUR 1.7 billion relative to the baseline.  

Training of additional inspectors will also be required due to PM6. On average an inspector performs 
2,920 PTI inspectors per year. Thus, PM6 is expected to require an additional 14,746 inspectors to 
be trained in 2026. Assuming a two-days training to cover the knowledge related to emission testing, 
but  also  testing  of  electric  vehicles  and  GSR  software  update,  and  an  hourly  cost  of  EUR  34  for 

358 Additional equipment for PN testing and NOx testing is only assumed in 2026 and should accommodate the additional 
number  of  inspections.  This  is  because  of  the  increase  in  the  share of  zero-emission  vehicles  over  time  and  thus  the 
decrease in the number of PN and NOx testing relative to 2026. 

163 

 
 
technicians  and  associate  professionals  –  ISCO  3),  the  one-off  adjustment  costs  for  training  are 
estimated at EUR 7.3 million in 2026.  

The  average  duration  of  a  PTI  inspection  is  30  minutes.  The  labour  costs  per  PTI  inspection  are 
estimated at EUR 17, assuming an hourly cost of EUR 34 for technicians and associate professionals 
(ISCO 3). To deliver the estimated additional number of inspections, the recurrent adjustment costs 
are estimated at EUR 771.7 million in 2026, EUR 792.1 million in 2030 and EUR 895.2 million in 
2050. Expressed as present value over 2026-2050, they are estimated at EUR 14.9 billion relative to 
the baseline.  

Table 122: Adjustment costs for PTI centres due to PM6 in 2026, 2030, 2040 and 2050 in policy options PO1b, 
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Additional  number  of 
which: 

inspections,  of 

for M1 category 
for N1 category 

Total adjustment costs 
One-off costs for equipment 
Recurrent costs for equipment 
Recurrent labour costs for inspections 
One-off costs for training 

Difference to the baseline 

2026 

2030 

2040 

2050 

45,416,666 

46,614,893 

50,581,135 

52,682,848 

41,125,717 
4,290,949 
1,870.5 
1,004.4 
87.1 
771.7 
7.3 

42,134,669 
4,480,224 
886.0 
4.9 
89.0 
792.1 
0.0 

45,715,359 
4,865,776 
962.4 
7.5 
95.5 
859.5 
0.0 

47,462,922 
5,219,925 
995.7 
1.7 
98.9 
895.2 
0.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 123: Adjustment costs for PTI centres due to PM6 in PO1b, PO2 and PO3, expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total one-off adjustment costs 
One-off costs for equipment 
Recurrent costs for equipment 
Recurrent labour costs for inspections 
One-off costs for training 

PO1a 

Difference to the baseline 

PO1b 
17,680.8 
1,090.6 
1,664.7 
14,918.2 
7.3 

PO2 
17,680.8 
1,090.6 
1,664.7 
14,918.2 
7.3 

PO3 
17,680.8 
1,090.6 
1,664.7 
14,918.2 
7.3 

Source: Ricardo et al. (2024), Impact assessment support study 

3.15.2.  Administrative cost for citizens (vehicle owners)  

The introduction of annual testing for M1 and N1 vehicles that are aged 10 years or older will result 
in recurrent administrative costs for vehicle owners due to testing charges. Considering the median 
charge per M1 vehicle of EUR 41.7, and the fact  that around 40% of M1 vehicles  are owned by 
citizens, the recurrent administrative costs for citizens are estimated at EUR 686.5 million in 2026, 
EUR 703.4 million in 2030 and EUR 792.3 million in 2050. Expressed as present value over 2026-
2050, they are estimated at EUR 13.2 billion relative to the baseline.  

Table 124: Administrative costs for citizens (vehicle owners) due to PM6 in 2026, 2030, 2040 and 2050 in policy 
options PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs for citizens 

Difference to the baseline 

2026 
686.5 

2030 
703.4 

2040 
763.2 

2050 
792.3 

Source: Ricardo et al. (2024), Impact assessment support study 

164 

 
  
  
 
 
 
 
 
  
Table 125: Administrative costs for citizens (vehicle owners) due to PM6 in  PO1b,  PO2 and PO3 expressed as 
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs for citizens 

Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 

Difference to the baseline 

PO1b 
13,241.7  

PO2 
13,241.7  

PO3 
13,241.7  

3.15.3.  Administrative cost for businesses (vehicle owners)  

The introduction of annual testing for N1 and M1 vehicles that are aged 10 years or older will result 
in recurrent administrative costs for vehicle owners due to testing charges. Considering the median 
charge per M1 vehicle of EUR 41.7 and per N1 vehicle of EUR 40.5, and the fact that around 60% 
of M1 vehicles and 100% of N1 vehicles are owned by businesses, the recurrent administrative costs 
for businesses are estimated at EUR 1,203.7 million in 2026, EUR 1,236.6 million in 2030 and EUR 
1,400 million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 23.3 
billion relative to the baseline.  

Table 126: Administrative costs for businesses (vehicle owners) due to PM6 in 2026, 2030, 2040 and 2050 in policy 
options PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs for businesses 

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

2026 
1,203.7 

2030 
1,236.6 

2040 
1,341.9 

2050 
1,400.0 

Table 127: Administrative costs for businesses (vehicle owners) due to PM6 in PO1b, PO2 and PO3 expressed as 
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs for businesses 

Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 

3.15.4.  Benefits for PTI centres 

Difference to the baseline 

PO1b 
23,295.9  

PO2 
23,295.9  

PO3 
23,295.9  

PM6 would result in benefits for the PTI centres in the 11 MS affected due to the mandatory yearly 
testing for M1 and N1 vehicles that are aged 10 years or older. The costs for vehicle owners (citizens 
and businesses) discussed above represent revenues for the PTI centres. The total revenues for PTI 
centres due to PM6 are estimated at EUR 1.89 billion in 2026, EUR 1.94 billion in 2030 and EUR 
2.19 billion in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 36.5 
billion relative to the baseline. 

Table 128: Benefits for PTI centres due to PM6 in 2026, 2030, 2040 and 2050 in policy options PO1b, PO2 and 
PO3 relative to the baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

2026 
1,890.2 

Difference to the baseline 
2040 
2030 
2,105.1 
1,940.0 

2050 
2,192.4 

Source: Ricardo et al. (2024), Impact assessment support study 

165 

 
  
 
  
  
 
  
Table 129: Benefits for PTI centres due to PM6 in PO1b, PO2 and PO3, expressed as present value over 2026-
2050 relative to the baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

PO1a 

Difference to the baseline 
PO2 
PO1b 
36,537.6  
36,537.6  

PO3 
36,537.6  

Source: Ricardo et al. (2024), Impact assessment support study 

3.16.  PM7 - PTI certificates issued in any EU MS is recognised by the MS of registration, plus 

further harmonisation of test methods 

PM7 requires that the Member State of registration recognises a PTI certificate issued by another 
Member State. This requires that the stringency of roadworthiness testing be more even across the 
EU than today. In addition to other relevant measures (such as PMC1, PMC2, PMC3 and others that 
improve the quality of PTI), this measure includes further harmonisation of test methods notably in 
the field of brake and suspension testing. 

3.16.1.   Adjustment costs for national public authorities  

Several Member States have reported that their existing systems are capable of transferring data from 
other national systems or have mechanisms in place that make such transfers negligible in terms of 
costs. Therefore, no costs are expected for national public authorities due to PM7. Consequently, this 
measure focuses on Member States identified as having lower-stringency roadworthiness systems359, 
which will need additional investments in the PTI centres.  

3.16.2.   Adjustment costs for PTI centres 

PTI  centres  in  the Member States with  lower-stringency roadworthiness  systems  identified above 
will need to acquire new equipment to enhance their capacity, including an advanced brake testing 
device and a suspension tester360.  

Based on input from stakeholders, the advanced testing of HDV braking and of suspension (damping 
efficiency of shock absorbers) will lead to additional equipment costs. For HDV brake testing using 
extrapolation methods, VSG Italy indicated a cost range of EUR 2,000 to 3,000 for the necessary air 
pressure sensor and a few hundred EUR per year for maintenance. For the assessment, an average 
one-off cost of EUR 2,500 is assumed per PTI centre and EUR 250 annual maintenance costs. The 
purchase cost of a suspension tester for light vehicles is around EUR 10,000 and the maintenance 
costs are assumed at EUR 1,000 per year per tester. Considering the 11 Member States with lower-
stringency  roadworthiness  systems,  29,922  of  the  48,880  PTI  centres  would  have  to  invest  into 
advanced brake testing equipment and 28,322361 into suspension testers. In addition, for advanced 
lighting testing, there is currently no method defined for advanced headlamp testing and stakeholders 
were not able to provide an indication of costs. The same one-off and maintenance costs as for braking 
have therefore been used, although it is assumed that all PTI centres will require new equipment and 
the  costs  will  not  occur  before  2030  (as  no  test  procedure  has  been  defined  yet).  Total  one-off 
adjustment  costs  are  estimated  at  EUR  358  million  in  2026  and  EUR  122.2  million  in  2030. 
Expressed as present value over 2026-2050, they are estimated at EUR 476.7 million relative to the 
baseline. 

359 Based on a recent survey of national authorities conducted by the Commission services, these are: Bulgaria, Cyprus, 
Greece, Hungary, Italy, Lithuania, Malta, Poland, Romania, Slovenia and the Netherlands. 
360 Suspension testing is an optional element of PTI today. 
361 Hungary already applies special equipment for testing the damping of shock absorbers. 

166 

 
  
 
 
Recurrent adjustment costs for maintenance are estimated at EUR 35.8 million per year for 2026-
2029 and at EUR 48 million per year from 2030 onwards, or EUR 814.5 million expressed as present 
value over 2026-2050 relative to the baseline.  

In conjunction with the introduction of new equipment, it is essential to provide training to inspectors 
to enhance their proficiency in utilising these new methods. The number of inspectors that would 
need  such  training  in  the  11  Member  States  with  lower-stringency  roadworthiness  systems  is 
estimated at 65,976. Assuming an average of 4 hours of training at  an hourly cost of EUR 34 for 
technicians  and  associate  professionals  (ISCO  3),  the  one-off  adjustment  costs  for  training  are 
estimated at EUR 9 million in 2026. 

The adjustment costs for PTI centres due to PM7 are summarised in the tables below.  

Table 130: Adjustment costs for PTI centres due to PM7 in 2026, 2030, 2040 and 2050 in policy option PO3 relative 
to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for equipment 
Recurrent costs for equipment 
One-off costs for training 

2026 
402.8 
358.0 
35.8 
9.0 

Difference to the baseline 
2040 
2030 
48.0 
170.2 
0.0 
122.2 
48.0 
48.0 
0.0 
0.0 

2050 
48.0 
0.0 
48.0 
0.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table  131:  Adjustment  costs  for  PTI  centres  due  to  PM7  in  PO3,  expressed  as  present  value  over  2026-2050 
relative to the baseline (in million EUR, 2022 prices) 

PO1a 

Difference to the baseline 
PO2 
PO1b 

Total adjustment costs 
One-off costs for equipment 
Recurrent costs for equipment 
One-off costs for training 

Source: Ricardo et al. (2024), Impact assessment support study 

3.16.3.  Adjustment costs savings for citizens (vehicle owners)  

PO3 
1,300.2 
476.7 
814.5 
9.0 

Due to PM7, citizens (i.e., vehicle owners) are expected to avoid driving unnecessary solely for the 
purpose  of  a  mandatory  PTI.  This  particularly  affects  foreigners  and  tourists  who  have  vehicles 
stationed in a country different from their Member State of registration. 

There is no data available for the number of vehicles registered in one Member State that are located 
in a different Member State and would benefit from such option. According to a 2011 IA study362, 
1,000 vehicles  registered in  the Netherlands and 1,000 vehicles registered in  Sweden stationed in 
Spain,  representing (on  average) 0.015% of the  total  fleet  of these countries. Assuming the same 
share at the EU level and using the PRIMES-TREMOVE baseline projections for the vehicle fleet, 
up to 967,379 vehicles may be stationed in a different MS than their registration country in 2026, 
996,705 in 2030 and 1,112,669 in 2050. This represents an upper estimate since for a large number 
of Member State pairs the number of vehicles should be much lower than the pair considered, given 
that not all MS attract the same numbers of nationals of other countries for relatively long periods of 
time. 

362 Europe Economics (2011), Report of contribution to impact assessment of policy options to improve the EU  system 
of PTI and of roadside vehicle testing 

167 

 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
The  cost  savings  from  avoiding  a  trip  back  to  the  country  of  vehicle  registration  for  a  PTI  are 
estimated  based  on  the  following  assumptions.  The  average  distance  between  European  cities  is 
around  1,200  km363.  The  travel  cost  for  light  vehicles  is  estimated  at  EUR  0.44  per  km  in  2022 
prices364. Assuming an average PTI frequency of around 0.43 times per year, the recurrent adjustment 
cost savings for citizens are estimated at EUR 221.5 million in 2026, EUR 228.2 million in 2030 and 
EUR 254.8 million in 2050. Expressed as present value over 2026-2050, the cost saving amount to 
EUR 4.3 billion relative to the baseline. 

The total cost savings for citizens (vehicle owners) due to PM7 are summarised in the tables below.  

Table 132: Adjustment costs savings for citizens (vehicle  owners) due to PM7 in 2026, 2030, 2040 and 2050 in 
policy option PO3 relative to the baseline (in million EUR, 2022 prices) 

Adjustment  costs  savings 
citizens 

for 

2026 

221.5 

Difference to the baseline 
2040 
2030 

228.2 

247.9 

2050 

254.8 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 133: Adjustment costs savings for citizens (vehicle owners) due to PM7 in PO3 expressed as present value 
over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

PO1a 

Difference to the baseline 
PO2 
PO1b 

Adjustment  costs  savings 
citizens 

for 

Source: Ricardo et al. (2024), Impact assessment support study 

PO3 

4,289.3 

3.17.  PM8 - PTI certificate issued in any EU MS is recognised by the MS of registration for a 
period of up to 6 months (for passenger cars only), on the condition that the next PTI is 
conducted in the MS of registration  

3.17.1.   Adjustment costs for national public authorities 

Several Member States have reported that their existing systems are capable of transferring data from 
other national systems or have mechanisms in place that make such transfers negligible in terms of 
costs. Therefore, no costs are expected for national public authorities due to PM8.  

3.17.2.  Adjustment costs for PTI centres 

PM8 is not expected to lead to any cost for PTI centres, considering that there are no changes to the 
PTI requirements. Some increase in the demand for PTI services make take place in specific Member 
States with higher number of nationals from other Member States. However, this is not expected to 
be at a level that would require additional investments.  

3.17.3.  Adjustment costs savings for citizens (vehicle owners) 

In PM8, after a PTI certificate is issued in other EU MS than that of the MS of registration, the next 
PTI needs to be conducted in the MS of registration. Therefore, in PM8 it is assumed that the transport 
activity avoided is half of that in PM7. All other assumptions used for the estimation of costs savings 
are the same  as  in  PM7. The recurrent  adjustment  cost  savings for citizens are estimated at  EUR 

363 Source: www.engineeringtoolbox.com on the distance among EU cities across the EU  and took the  median value 
among all pairs.  
364 Source: https://www.eurodev.com/blog/mileage-reimbursement-in-europe-2022  

168 

 
  
  
 
 
 
 
110.7 million in 2026, EUR 114.1 million in  2030 and EUR 127.4 million in 2050. Expressed as 
present value over 2026-2050, the cost saving amount to EUR 2.1 billion relative to the baseline. 

The total cost savings for citizens (vehicle owners) due to PM8 are summarised in the tables below.  

Table 134: Adjustment costs savings for citizens (vehicle  owners) due to PM8 in 2026, 2030, 2040 and 2050 in 
policy options PO1b and PO2 relative to the baseline (in million EUR, 2022 prices) 

Adjustment costs savings for citizens 

Difference to the baseline 

2026 
110.7 

2030 
114.1 

2040 
123.9 

2050 
127.4 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 135: Adjustment costs savings for citizens (vehicle  owners) due to PM8 in PO1b  and PO2, expressed as 
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Adjustment costs savings for citizens 

Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 

Difference to the baseline 

PO1b 
2,144.6  

PO2 
2,144.6  

PO3 

3.18.  PM9 - PTI in another MS recognised by MS of registration based on bilateral agreements 

This measure would require that the PTI certificate issued in any other EU MS is recognised by the 
MS of registration on the basis of bilateral agreements. 

3.18.1.  Adjustment costs for national public authorities 

National  authorities  will  incur  costs  associated  with  establishing  bilateral  agreements,  modifying 
national law as required and implementing procedures to facilitate inspections in another Member 
State.  PM9  is  expected  to  lead  to  one-off  adjustment  costs,  mainly  for  designing  the  bilateral 
agreements.  It  is  not  expected  that  agreements  will  be  signed  among  all  pairs  of  Member  states. 
Assuming  that  each  Member  State  establishes  three  bilateral  agreements,  a  total  number  of  41 
agreements would be established365. Total one-off adjustment costs are estimated at EUR 1.4 million 
in 2026 (EUR 35,265 per agreement or EUR 53,550 per Member State), expressed in 2022 prices. 
The estimation is based on the bilateral agreements already in place between the Netherlands and 
Spain, as well as between the Netherlands and Belgium. 

The total adjustment costs for national public authorities due to PM9 are summarised in the tables 
below.  

Table 136: Adjustment costs for national public authorities due to PM9 in 2026, 2030, 2040 and 2050 in policy 
option PO1a relative to the baseline (in million EUR, 2022 prices) 

One-off adjustment costs for setting up  
bilateral agreements  

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

2026 

1.4 

2030 

0.0 

2040 

0.0 

2050 

0.0 

365 The total number of agreements is derived by multiplying the number of agreements by MS with the total number of 
MS and dividing by 2. 

169 

 
  
  
 
 
  
 
Table 137: Adjustment costs for national public authorities due to PM9 in PO1a expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 

One-off adjustment costs for setting up  
bilateral agreements  

Source: Ricardo et al. (2024), Impact assessment support study 

1.4 

3.18.2.  Adjustment cost savings for citizens (vehicle owners)  

The cost savings for citizens (vehicle owners) due to the bilateral agreements, as a result of avoided 
travel costs for performing the PTI tests, are estimated at EUR 1.19 million per bilateral agreement 
(expressed in 2022 prices)366. Considering the 41 bilateral agreements assumed to be signed, the total 
recurrent  adjustment costs savings are estimated at EUR 49 million per year from 2026 onwards. 
Expressed as present value over 2026-2050, they are estimated at EUR 878.2 million relative to the 
baseline. 

The total cost savings for citizens (vehicle owners) expected as a result of PM9 are summarised in 
the tables below.  

Table 138: Adjustment costs savings for citizens (vehicle owners) due to PM9 in 2026, 2030, 2040 and 2050 in 
policy option PO1a relative to the baseline (in million EUR, 2022 prices) 

Recurrent adjustment costs  savings 
for citizens 

2026 

49.0 

Difference to the baseline 
2040 
2030 

49.0 

49.0 

2050 

49.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 139: Adjustment costs savings for citizens (vehicle owners) due to PM9 in PO1a, expressed as present value 
over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent adjustment costs savings 
for citizens 

PO1a 

878.2 

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 
PO2 
PO1b 

PO3 

3.19.  PM10 - More advanced testing of noise for motorcycles 

PM10 requires that all Member States perform noise testing for motorcycles at PTI, inspired by the 
procedure for pass-by noise test described in the UN Regulation no. 41. Few MSs (DE, ES, HR and 
SK) are already measuring L-vehicles noise emissions at PTI.  

3.19.1.  Adjustment costs for PTI centres 

For the calculation of the adjustment costs incurred by the PTI centres it is assumed that only the 
proportion of PTI centres with a test track will be concerned by the measure.  

The number of PTI centres with a test track is estimated by applying the projected share of L3-L4 
vehicles in the total vehicle stock in 2026 (i.e., 6.2%)367 to the total number of PTI centres in the 

366 Europe Economics (2011), Report of contribution to impact assessment of policy options to improve the EU system 
of PTI and of roadside vehicle testing 
367 The projected vehicles stock is based on the baseline projections from the PRIMES-TREMOVE model.  

170 

 
  
 
 
 
  
  
 
 
 
 
affected MS. Thus,  2,827 inspection centres are  estimated  to  have a test  track, out  of the total  of 
45,585 PTI centres in the affected MS (excluding DE, ES, HR and SK).  

The cost for purchasing a noise measurement device is estimated at EUR 800 per device (i.e., the 
average of the estimates provided by stakeholders, that is between EUR 600 and EUR 1,000), and 2 
devices  are  assumed  to  be  needed  for  each  PTI  centre  with  a  test  track.  Thus,  the  total  one-off 
adjustment  costs  for  the  purchase  of  new  equipment  are  estimated  at  EUR  4.5  million  in  2026. 
Recurrent adjustment costs for the maintenance and calibration of devices are assumed at 5% of the 
capital cost, or EUR 226,160 per year from 2026 onwards. Expressed as present value over 2026-
2050, the recurrent adjustment costs for equipment are estimated at EUR 4.1 million relative to the 
baseline.  

The  additional  noise  testing  will  imply  longer  PTI  sessions  and  for  this  reason  would  result  in 
additional labour costs for the PTI centres. It is assumed that the noise measurement takes around 15 
minutes, and the hourly cost is EUR 34 for technicians and associate professionals (ISCO 3). The 
number of noise tests is estimated at 6.9 million in 2026, 7.2 million in 2030 and 8.6 million in 2050. 
The recurrent adjustment costs are estimated at EUR 58.6 million in 2026, EUR 61.6 million in 2030 
and EUR 73.4 million in 2050. Expressed as present value over 2026-2050, they are estimated at 
EUR 1.2 billion.  

The  number  of  additional  inspectors  that  need  to  be  trained  for  performing  the  noise  testing  is 
estimated at 1,575 in 2026. They are estimated based on the projected number of additional noise 
tests and the average number of PTIs per inspector (i.e., 4,380). Assuming half a day of training, at 
an hourly cost of EUR 34 for technicians and associate professionals (ISCO 3)368, the total one-off 
adjustment costs for training are estimated at EUR 194,834 in 2026. 

The total adjustment costs for PTI centres expected due to PM10 are summarised in the tables 
below. 

Table 140: Adjustment costs for PTI centres due to PM10 in 2026, 2030, 2040 and 2050 in policy options PO1b, 
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for equipment 
Recurrent costs for equipment 
Recurrent labour costs for inspections 
One-off costs for training 

Difference to the baseline 

2026 
63.6 
4.5 
0.2 
58.6 
0.2 

2030 
61.8 
0.0 
0.2 
61.6 
0.0 

2040 
66.4 
0.0 
0.2 
66.2 
0 

2050 
73.7 
0.0 
0.2 
73.4 
0.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 141: Adjustment costs for PTI centres due to PM10 in PO1b, PO2 and PO3, expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for equipment  
Ongoing costs for equipment 
Ongoing costs for additional staff 
One-off costs for training 

PO1a 

Difference to the baseline 
PO1b 
1,170.6  
4.5  
4.1  
1,161.8  
0.2  

PO2 
1,170.6  
4.5  
4.1  
1,161.8  
0.2  

PO3 
1,170.6  
4.5  
4.1  
1,161.8  
0.2  

Source: Ricardo et al. (2024), Impact assessment support study 

368 Data Sources: Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs 

171 

 
  
  
 
 
 
 
 
 
3.19.2.  Costs for vehicle owners 

Depending on the Member State, the additional costs for the PTI centres may be passed through to 
vehicle owners (i.e., citizens). As indicated under PMC1, this will depend on the way PTI charges 
are set in the Member State.  

The limitation to PTI centres equipped with a test track will mean that some vehicle’ owners will 
have to travel further than to the closest PTI centre, which means higher costs in terms of time spent 
for PTI and fuel consumed to get to the testing location. However, these costs are not expected to be 
significant. 

Owners  of  faulty  L3-L4  vehicles  will  face  a  charge  for  repairing  the  non-compliant  vehicles. 
However,  this  is  not  considered  to  be  regulatory  costs  but  is  relevant  in  terms  of  the  impact  on 
maintenance costs. 

3.20.  PM11 - Data governance: further define the procedures and the means of access to vehicle 

technical information by testing centres free of charge 

PM11 is expected to result in one-off administrative costs for national public authorities and OEMs 
for adapting the IT systems  and their interconnection. This  could  for instance concern the testing 
centres that are not digitally connected yet. Additional recurrent administrative costs are expected to 
maintain the IT systems. 

According to EUCARIS, using the same procedure as for the exchange of eCoC data369 could reduce 
additional costs but costs are still expected during the transition. ACEA expects costs similar to the 
introduction of Commission Implementing Regulation (EU) 2019/621 for PM11. EReg mentioned 
costs for PTI centres that are not digitally connected, with varying impacts by Member State, and 
negligible costs for those already digitally connected. 

3.20.1.  Administrative costs for national public authorities  

Based on the NL and SI case studies and stakeholders’ interviews, the one-off cost for the adaptation 
of  the  IT  system  is  estimated  at  EUR  300,000  to  EUR  1,000,000  per  country,  depending  on  the 
volume of PTI inspections per country. Assuming one-off costs of EUR 300,000 per IT system for 
each of the 15 Member States with smaller volumes of inspections370, EUR 500,000 per IT system 
for each of the 7 Member States with medium volumes of inspections371 and EUR 1,000,000 per IT 
system  for  each  of  the  5  Member  States  with  higher  volumes  of  inspections372,  the  total  one-off 
administrative costs at EU27 level are estimated at EUR 13 million in 2026. Recurrent administrative 
costs for maintenance are estimated at around 10% of the capital costs, or EUR 1.3 million per year 
from 2026 onwards. Expressed as present value over 2026-2050, the recurrent administrative costs 
are estimated at EUR 23.3 million relative to the baseline. 

369 EUR-Lex - 32021R0133 - EN - EUR-Lex (europa.eu)  
370 Below 2% of the total number of inspections at EU level in 2026 by Member State. These are: BG, CY, EE, FI, HR, 
HU, IE, LT, LV, LU, MT, SI, SK, DK and CZ.    
371 Between 2% and 10% of the total number of inspections at EU level in 2026 by Member State. These are: AT, BE, 
EL, NL, PT, RO and SE.   
372 Above 10% of the total number of inspections at EU level in 2026 by Member State. These are:  DE, FR, IT, PL and 
ES.    

172 

 
 
 
 
 
 
Table 142: Administrative costs for national public administrations due to PM11 in 2026, 2030, 2040 and 2050 in 
policy options PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off costs for IT systems 
Recurrent costs for maintenance of the IT systems 

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

2026 
14.3 
13.0 
1.3 

2030 
1.3 
0.0 
1.3 

2040 
1.3 
0.0 
1.3 

2050 
1.3 
0.0 
1.3 

Table 143: Administrative costs for national public administrations due to PM11 in PO2 and PO3, expressed as 
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off costs for IT systems 
Recurrent costs for maintenance of the IT systems 

Source: Ricardo et al. (2024), Impact assessment support study 

3.20.2.  Administrative costs for OEM  

Difference to the baseline 

PO1a 

PO1b 

PO2 
36.3  
13.0  
23.3  

PO3 
36.3  
13.0  
23.3  

OEMs will also need to make adjustments to their own IT systems to ensure access to the relevant 
data. According to one manufacturer, the one-off costs are expected to be around EUR 1 million per 
OEM.  The  total  one-off  administrative  costs  are  estimated  at  EUR  20  million  in  2026  for  the  20 
OEMs in the EU.  

Recurrent administrative costs are estimated at 10% of the capital costs or EUR 100,000 per OEM. 
For the 20 OEMs, they amount to EUR 2 million per year from 2026 onwards. Expressed as present 
value over 2026-2050, they are estimated at EUR 35.9 million relative to the baseline. 

Table 144: Administrative costs for OEMs due to PM11 in 2026, 2030, 2040 and 2050 in policy options PO2 and 
PO3 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off costs for IT systems 
Recurrent costs for maintenance of the IT systems 

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

2026 
22.0 
20.0 
2.0 

2030 
2.0 
0.0 
2.0 

2040 
2.0 
0.0 
2.0 

2050 
2.0 
0.0 
2.0 

Table 145: Administrative costs for OEMs due to PM11 in PO2 and PO3, expressed as present value over 2026-
2050 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off costs for IT systems 
Recurrent costs for maintenance of the IT systems 

Source: Ricardo et al. (2024), Impact assessment support study 

3.20.3.  Administrative costs for PTI centres 

Difference to the baseline 

PO1a 

PO1b 

PO2 
55.9  
20.0  
35.9  

PO3 
55.9  
20.0  
35.9  

For PTI centres, the one-off administrative costs for the adaptation of the IT systems are estimated at 
EUR 1,000 per centre. Total one-off administrative costs would amount to EUR 48.9 million in 2026, 
for the 48,880 PTI centres across the EU.  

Recurrent  administrative costs for the maintenance of the IT systems are estimated at 10% of the 
capital costs, or EUR 100 per PTI centre. Total recurrent administrative costs are estimated at EUR 

173 

 
  
  
 
 
 
 
 
 
  
  
 
 
 
 
 
 
4.9 million per year from 2026 onwards, or EUR 87.7 million expressed as present value over 2026-
2050 relative to the baseline.  

Table 146: Administrative costs for PTI centres due to PM11 in 2026, 2030, 2040 and 2050 in policy options PO2 
and PO3 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off costs for IT systems 
Recurrent costs for maintenance of the IT systems 

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

2026 
53.8 
48.9 
4.9 

2030 
4.9 
0.0 
4.9 

2040 
4.9 
0.0 
4.9 

2050 
4.9 
0.0 
4.9 

Table 147: Administrative costs for PTI centres due to PM11 in PO2 and PO3, expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off costs for IT systems 
Recurrent costs for maintenance of the IT systems 

Source: Ricardo et al. (2024), Impact assessment support study 

3.20.4.  Administrative cost savings for PTI centres 

Difference to the baseline 

PO1a 

PO1b 

PO2 
136.5  
48.9  
87.7  

PO3 
136.5  
48.9  
87.7  

The access to relevant technical information is also expected to bring some limited time savings for 
PTI centres. Time savings of 3 minutes are assumed per PTI. This represents 10% of the average of 
30 minutes per PTI for a passenger car. No potential for higher time saving per inspection is estimated 
due  to  PM11  because  most  of  the  time  during  a  PTI  is  allocated  to  the  visual  inspection  or  the 
emissions and other testing. Furthermore, not all PTI centres are expected to benefit of this measure, 
as  access  to  relevant  information  is  often  already  available.  It  is  expected  that  only  30%  of  PTIs 
would  benefit  of  PM11.  Assuming  an  average  cost  per  hour  for  technicians  and  associate 
professionals (ISCO level 3) of EUR 34, the recurrent administrative costs savings for PTI centres 
are estimated at EUR 84.1 million in 2026, EUR 87.1 million in 2030 and EUR 99.3 million in 2050. 
Expressed as present value over 2026-2050, they amount to EUR 1.6 billion relative to the baseline.  

Table 148: Administrative costs savings for PTI centres due to PM11 in 2026, 2030, 2040 and 2050 in policy options 
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

2026 
84.1 
Source: Ricardo et al. (2024), Impact assessment support study 

Recurrent administrative costs savings 

Difference to the baseline 

2030 
87.1 

2040 
94.8 

2050 
99.3 

Table 149: Administrative costs savings for PTI centres due to PM11 in PO2 and PO3, expressed as present value 
over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs savings 

Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 

PO1b 

PO2 
1,643.4  

PO3 
1,643.4  

Difference to the baseline 

3.21.  PM12 – NOx, PM, and noise measurement by remote sensing in RSI of all vehicles (with 

option for simplified PTI if vehicle passed recent RSI) 

PM12  (included  in  PO1b,  PO2  and  PO3)  requires  NOx,  PM,  and  noise  measurement  by  remote 
sensing in technical roadside inspections of all vehicle types, and optional plume chasing in technical 
roadside inspections of commercial vehicles. It also includes the option for simplified PTI (i.e., no 
emission/noise testing) if the vehicle passed a recent RSI (including by remote sensing). 

174 

 
  
  
 
 
 
 
 
 
  
  
 
 
The introduction of this measure will require the purchase, maintenance and periodic calibration of 
remote  sensing  equipment  (for  NOx  and  PM)  and  acoustic  camera  equipment  by  national  public 
authorities.  It  will  also  imply  additional  costs  for  vehicles  and  testing  equipment  for  the  plume 
chasing option, as well as costs for training of inspectors to use the new equipment. In addition, it 
will also imply some extra costs for additional emissions tests for the owners of vehicles (businesses 
or citizens) identified as high emitters by the remote sensing or plume chasing measurements and 
some extra adjustment costs for the PTI centres that will need to deliver these additional tests.  

On the other hand, PM12 is expected to lead to costs savings for citizens and businesses (vehicle 
owners) that successfully pass the remote sensing or plume chasing measurement by avoiding some 
costs associated with PTI.  

3.21.1.  Adjustment costs for national public authorities  

Remote sensing  

Roadside  inspection  authorities  are  expected  to  incur  costs  for  the  purchase  of  remote  sensing 
equipment for measuring NOx and PM emissions of all vehicle types. 250 remote sensing devices 
would be needed in EU27 to be able to analyse via remote sensing at least 30% of the road fleet373.  

The capital cost of a remote sensing equipment, based on stakeholders’ consultation, is assumed at 
EUR 85,000. In addition, maintenance and calibration costs are assumed at 5% of the capital costs, 
and the cost for the processing and data management at EUR 24,000 per year per device. 

The  total  one-off  adjustment  costs  for  remote  sensing  equipment  are  thus  estimated  at  EUR  21.3 
million in 2026. Recurrent adjustment costs for maintenance and calibration, and for the processing 
and data management are estimated at EUR 7.1 million from 2026 onwards. Expressed as present 
value  over  2026-2050,  recurrent  adjustment  costs  amount  to  EUR  126.7  million  relative  to  the 
baseline. 

In addition, one day of training for the use of NOx and PM remote sensing equipment is assumed for 
the 393 RSI inspectors. With an hourly cost for technicians and associate professionals (ISCO 3) of 
EUR 34/hour374, and assuming 7.3 working hours per day, the one-off adjustment costs for training 
are estimated at EUR 97,231 in 2026. 

Plume chasing (optional) 

PM12 gives the possibility of implementing plume chasing to measure NOx and PM emissions of 
HDVs  (from  Euro  VI).  The  cost  of  plume  chasing  equipment  is  assumed  at  EUR  32,500  per 
equipment,  based  on  input  from  stakeholders.  Assuming  on  average  two  equipped  vehicles  per 
Member State for 26 Member States (Denmark has already implemented the system), the one-off 
adjustment costs are estimated at EUR 1.7 million in 2026. 

The maintenance and calibration costs are assumed at EUR 1,625 per equipment per year (5% of the 
capital cost), based on inputs from stakeholders, resulting in total maintenance costs of EUR 84,500 
per year from 2026 onwards for the 26 Member States relevant for PM13 (excluding Denmark). In 
addition, labour costs are estimated assuming one inspector per plume chasing vehicle and four days 

373  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 
374 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 

175 

 
 
per week of plume chasing375. Considering on average 44 working weeks per year and an hourly cost 
for  technicians  and  associate  professionals  (ISCO  3)  of  EUR  34/hour,  the  total  labour  costs  are 
estimated at EUR 2.26 million per year from 2026 onwards. Thus, total recurrent adjustment costs 
for  maintenance  of  equipment  and  labour  costs  amount  to  EUR  2.3  million  per  year  from  2026 
onwards, or EUR 42.1 million expressed as present value over 2026-2050.  

In addition, two days of training are assumed for the 52 inspectors. With an hourly cost for technicians 
and associate professionals (ISCO 3) of EUR 34/hour376, and assuming 7.3 working hours per day, 
the one-off adjustment costs for training are estimated at EUR 25,730.  

Acoustic cameras 

Acoustic  cameras  would  need  to  be  added  to  remote  sensing  equipment  to  measure  noise  at  the 
roadside. The one-off cost per acoustic camera is assumed at EUR 2,000377, and the maintenance cost 
at 5% of the capital cost. Thus, total one-off adjustment costs for equipment are estimated at EUR 
500,000 in  2026 and the recurrent  adjustment costs at  EUR 25,000 per year  from  2026 onwards. 
Expressed as present value over 2026-2050, the recurrent adjustment costs for acoustic cameras are 
estimated at EUR 448,389.  

In  addition,  a  half-day  training  would  be  needed  for  393  RSI  inspectors,  for  using  the  acoustic 
cameras. The one-off adjustment costs for training are estimated at EUR 48,616. 

The total adjustment costs for national public authorities expected due to PM12 are summarised in 
the tables below. 

Table 150: Adjustment costs for national public authorities due to PM12 in 2026, 2030, 2040 and 2050 in policy 
options PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for remote sensing equipment  
Recurrent costs for maintenance and data  
management for remote sensing equipment 
One-off costs for plume chasing equipment  
Recurrent costs for maintenance and staff for  
plume chasing equipment 
One-off costs for acoustic cameras 
Recurrent maintenance costs for acoustic cameras 
One-off costs for training (for remote sensing, plume  
chasing and acoustic cameras) 

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

2030 
9.4 
0.0 

7.1 

0.0 

2.3 

0.0 
0.03 

0.0 

2040 
9.4 
0.0 

7.1 

0.0 

2.3 

0.0 
0.03 

0.0 

2050 
9.4 
0.0 

7.1 

0.0 

2.3 

0.0 
0.03 

0.0 

2026 
33.0 
21.3 

7.1 

1.7 

2.3 

0.5 
0.03 

0.2 

Table 151: Adjustment costs for national public authorities due to  PM12 in PO1b, PO2 and PO3 expressed as 
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for remote sensing equipment  
Recurrent costs for maintenance and data  
management for remote sensing equipment 

PO1a 

Difference to the baseline 

PO1b 
192.9  
21.3  
126.7  

PO2 
192.9  
21.3  
126.7  

PO3 
192.9  
21.3  
126.7  

375 Four days per week of plume chasing, with an average of 44 working weeks per year, and 52 vehicles at a rate of 25 
unique licence plates measured per day, would cover around 3% of the HDVs fleet in the 26 MS relevant for PM12. 
376 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 
377 Average of the stakeholders’ input, ranging between EUR 1,000 and EUR 3,000 per device. 

176 

 
  
  
 
 
 
 
One-off costs for plume chasing equipment  
Recurrent costs for maintenance and staff for  
plume chasing equipment 
One-off costs for acoustic cameras 
Recurrent maintenance costs for acoustic cameras 
One-off costs for training 

PO1a 

Difference to the baseline 

PO1b 
1.7  
42.1  

0.5  
0.4  
0.2  

PO2 
1.7  
42.1  

0.5  
0.4  
0.2  

PO3 
1.7  
42.1  

0.5  
0.4  
0.2  

Source: Ricardo et al. (2024), Impact assessment support study 

3.21.2.  Administrative costs for citizens (vehicle owners) 

The remote sensing is expected to lead to an identification of a  share of high emitters among M1 
internal  combustion  engine  (ICE)  vehicles.  The  results  will  need  to  be  verified  via  roadside 
inspections (limited to 0.5% of the fleet) or sent for extra emissions tests in PTI centres. Owners of 
these M1 vehicles - around 40% of which are citizens - will incur costs for these additional emissions 
tests.  These  have  been  estimated  to  be  around  0.86%  of  the  internal  combustion  engine  vehicles 
fleet378. Considering the fee for an emission test at 20% of the total PTI fee for an M1 vehicle (EUR 
41.7), the cost per extra emission test is estimated at EUR 8.3. The recurrent administrative costs for 
citizens are estimated at EUR 6.5 million in 2026, EUR 5.8 million in 2030 and EUR 0.3 million in 
2050. The costs decrease over time as the share of zero-emission vehicles increases over time in the 
baseline scenario. Expressed as present value over 2026-2050, the administrative costs for the citizens 
are estimated at EUR 72.2 million relative to the baseline.  

Table 152: Administrative costs for citizens due to PM12 in 2026, 2030, 2040 and 2050 in policy options PO1b, 
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Extra PTI emission tests following the identification of high 
emitters by remote sensing 
Recurrent administrative costs (in million EUR) 

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

2026 
781,040 

2030 
713,217 

2040 
340,538 

2050 
40,325 

6.5 

5.8 

2.8 

0.3 

Table 153: Administrative costs for citizens due to PM12 in PO1b, PO2 and PO3 expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs  

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

PO1a 

PO1b 
72.2  

PO2 
72.2  

PO3 
72.2  

3.21.3.  Administrative costs for businesses (vehicle owners) 

Similar  to  citizens,  business  that  own  M1,  N1  and  heavy  duty  vehicles  will  incur  extra  costs  for 
emissions testing if the vehicles are identified as high emitters via the use of remote sensing or plume 
chasing  and  are  sent  for  PTI  due  to  the  0.5%  limit  in  the  capacity  for  roadside  inspections.  It  is 
estimated that, on average, 0.86% of the M1 internal combustion engine vehicles will need an extra 
emission test, 1.62% of the N1 internal combustion engine vehicles and 1.26% of the heavy duty 
(N2/N3/M2/M3) internal combustion engine vehicles379. Assuming that an emission test  will cost 
20% of the full PTI fee per vehicle (EUR 41.7 for M1, EUR 40.5 for N1, EUR 61.6 for N2/N3 and 
EUR 70.8 for M2/M3) and the fact that around 60% of M1 vehicles and 100% of N1, N2/N3 and 
M2/M3  vehicles  are  owned  by  businesses,  the  recurrent  administrative  costs  for  businesses  are 

378 More explanations are provided in section 4.2.12 of Annex 4. 
379 More explanations are provided in section 4.2.12 of Annex 4. 

177 

 
  
 
 
 
 
 
  
  
 
 
estimated at EUR 14.8 million in 2026, EUR 14.0 million in 2030 and EUR 1.2 million in 2050. 
Expressed as present value over 2026-2050, they are estimated at EUR 175 million relative to the 
baseline.  

Table 154: Administrative costs for businesses due to PM12 in 2026, 2030, 2040 and 2050 in policy options PO1b, 
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Extra PTI emission tests following the identification of 
high  emitters  by  remote  sensing  or  plume  chasing,  of 
which: 

for HDVs 
for LDVs 

Recurrent administrative costs (in million EUR) 

Difference to the baseline 

2026 

2030 

2040 

2050 

1,748,404 

1,644,389 

858,688 

134,284 

88,279 
1,660,125 
14.8 

89,827 
1,554,562 
14.0 

71,883 
786,805 
7.4 

33,635 
100,649 
1.2 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 155: Administrative costs for businesses due to PM12 in PO1b, PO2 and PO3 expressed as present value 
over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 

Difference to the baseline 

PO1a 
0.0  

PO1b 
175.0  

PO2 
175.0  

PO3 
175.0  

Source: Ricardo et al. (2024), Impact assessment support study 

3.21.4.  Administrative costs savings for citizens (vehicle owners) 

In  PM12,  passing  a  remote  sensing  test  allows  a  simplified  PTI  for  vehicle  owners  within  the 
following 6 months. This is expected to result in administrative costs savings related to inspections, 
as they do not have to undertake the emissions and/or noise tests.  

The emissions and noise tests represent a relatively small share of the total charge for an inspection, 
estimated at around 20% of the total PTI fee380. Around 30% of the EU fleet would be subject to 
remote sensing in PM12 and it is assumed that a share of non high emitters (90% on average for M1 
vehicles) that go through a remote sensing test would benefit of costs savings. Using the estimated 
numbers of PTI tests per year for M1 vehicles that are not high emitters and pass a remote sensing, 
half of them is assumed to benefit from the measure (i.e., those that are expected to go through a PTI 
within  six  months).  In  addition,  it  is  assumed  that  around  40%  of  the  M1  vehicles  are  owned  by 
citizens. Thus, the number of PTI emission/noise tests avoided by citizens due to PM12 is estimated 
at 6.4 million in 2026, 5.8 million in 2030 and 329,684 in 2050. The reason for the decreasing number 
of  PTI  tests  avoided  over  time  is  the  increasing  share  of  zero-emission  vehicles  in  the  baseline 
scenario. Based on the charge per PTI test381 and the share of costs saved (i.e., 20% as explained 
above), the recurrent administrative costs savings for citizens are estimated at EUR 53.4 million in 
2026, EUR 48.8 million in 2030 and EUR 2.8 million in 2050. Expressed as present value over 2026-
2050, they are estimated at EUR 591.9 million relative to the baseline. 

Table 156: Administrative costs savings for citizens due to PM12 in 2026, 2030, 2040 and 2050 in policy options 
PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Number  of  PTI  emission  and  noise  tests 
avoided 

Difference to the baseline 

2026 
6,396,137 

2030 
5,848,537 

2040 
2,788,026 

2050 
329,684 

380 Based on the analysis of the PTI charges available.  
381 The median PTI charge at EU level for M1 vehicles is EUR 41.7 per PTI. 

178 

 
  
  
  
 
Recurrent  administrative  costs  savings  (in 
million EUR) 

Difference to the baseline 

2026 
53.4 

2030 
48.8 

2040 
23.3 

2050 
2.8 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 157: Administrative costs savings for citizens due to  PM12 in PO1b, PO2 and PO3 expressed as present 
value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent 
savings  

administrative 

costs 

PO1a 

Difference to the baseline 
PO2 
PO1b 
591.9  
591.9  

PO3 
591.9  

Source: Ricardo et al. (2024), Impact assessment support study 

3.21.5.  Administrative costs savings for businesses (vehicle owners) 

Similar to citizens, in PM12 passing a remote sensing test allows a simplified PTI for businesses (i.e., 
vehicle  owners)  within  the  following  6  months.  This  is  expected  to  result  in  administrative  costs 
savings related to inspections, as they do not have to undertake the emissions and noise tests.  

The emissions  and noise tests  represent  a relatively small  share of the total fee for an inspection, 
estimated at around 20% of the total PTI charge382. Around 30% of the EU fleet would be subject to 
remote sensing in PM12 and it is assumed that a share of non high emitters (90% on average for M1 
and  N1  vehicles  and  85%  on  average  for  N2-N3  and  M2-M3  vehicles)  that  go  through  a  remote 
sensing test would benefit of costs savings. Using the estimated numbers of PTI tests per year for 
LDVs and HDVs that are not high emitters and pass a remote sensing, half of them is assumed to 
benefit from the measure (i.e., those that are expected to go through a PTI within six months). In 
addition, it is assumed that around 60% of the M1 vehicles are owned by businesses, and 100% of 
the  N1,  N2-N3  and  M2-M3  vehicles.  Thus,  the  number  of  PTI  emission/noise  tests  avoided  by 
businesses due to PM12 is estimated at 12.7 million in 2026, 11.9 million in 2030 and EUR 1 million 
in 2050. The reason for the decreasing number of PTI tests avoided over time is the increasing share 
of zero-emission vehicles in the baseline scenario. Based on the charge per PTI test383 and the share 
of costs saved (i.e., 20% as explained above), the recurrent administrative costs savings for businesses 
are estimated at EUR 109.4 million in 2026, EUR 102.6 million in 2030 and EUR 10.1 million in 
2050. Expressed as present value over 2026-2050, they are estimated at EUR 1.3 billion relative to 
the baseline. 

Table 158: Administrative costs savings for businesses due to PM12 in 2026, 2030, 2040 and 2050 in policy options 
PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Number of PTI emission and noise tests avoided, 
of which: 

for HDVs 
for LDVs 

Recurrent  administrative  costs  savings  (in 
million EUR) 

Difference to the baseline 

2026 
12,689,889 

2030 
11,863,044 

2040 
6,166,765 

2050 
1,032,002 

956,206 
11,733,683 
109.4 

969,249 
10,893,795 
102.6 

768,250 
5,398,515 
54.4 

359,122 
672,880 
10.1 

Source: Ricardo et al. (2024), Impact assessment support study 

382 Based on the analysis of the PTI charges available.  
383 The median PTI charge at EU level for M1 vehicles is EUR 41.7 per PTI, for N1 vehicles EUR 40.5 per PTI, for 
N2/N3 EUR 61.6 and for M2/M3 EUR 70.8 per PTI. 

179 

 
  
  
 
  
 
Table 159: Administrative costs savings for businesses due to PM12 in PO1b, PO2 and PO3 expressed as present 
value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent 
savings  

administrative 

costs 

PO1a 

Difference to the baseline 
PO2 
PO1b 
1,287.3  
1,287.3  

PO3 
1,287.3  

Source: Ricardo et al. (2024), Impact assessment support study 

3.21.6.  Adjustment costs for PTI centres 

The additional emission tests for internal combustion vehicles (M1, N1, N2/N3 and M2/M3) due to 
PM12 (i.e. vehicles that are found as high emitters during remote sensing or plume chasing and are 
sent for emission test in a PTI centre) are estimated at 2.5 million in 2026, 2.4 million in 2030 and 
174,609 in 2050 relative to the baseline384. The decrease in the number of emission testing is driven 
by the increase in the number of zero-emission vehicles over time in the baseline.  

PM12 is expected to lead to recurrent adjustment costs for the PTI for the additional emissions tests. 
Due to the small share of the fleet affected it is assessed that no additional emission testing equipment 
will be needed and that the available PTI lanes will be able to serve the additional demand. As such, 
the only additional costs concern the labour costs for inspectors.  

Combined, the average duration of new PN and NOx emission tests is estimated at around 6 minutes. 
The labour costs per emission testing are estimated at EUR 3.4, assuming an hourly cost of EUR 34 
for technicians and associate professionals (ISCO 3). To deliver the estimated additional number of 
emission testing, the recurrent adjustment costs are estimated at EUR 8.6 million in 2026, EUR 8.0 
million in 2030 and EUR 0.6 million in 2050385. Expressed as present value over 2026-2050, they 
are estimated at EUR 99 million relative to the baseline.  

Table 160: Adjustment costs for PTI centres due to PM12 in 2026, 2030, 2040 and 2050 in policy options PO1b, 
PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Additional number of tests 
Recurrent adjustment costs (in million EUR) 

2026 
2,529,443 
8.6 

Difference to the baseline 

2030 
2,357,606 
8.0 

2040 
1,199,226 
4.1 

2050 
174,609 
0.6 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 161: Adjustment costs for PTI centres due to PM12 in PO1b, PO2 and PO3 expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent adjustment costs  

PO1a 

Difference to the baseline 

PO1b 
99.0  

PO2 
99.0  

PO3 
99.0  

Source: Ricardo et al. (2024), Impact assessment support study 

3.21.7.  Benefits for PTI centres 

PM12 would also  result in  benefits  for the PTI centres  due to  the  vehicles that are found as high 
emitters during remote sensing or plume chasing and are sent for emission test in a PTI centre. The 
costs for vehicle owners (citizens and businesses) discussed above represent revenues for the PTI 

384 The number of inspections is estimated based on the projected number of internal combustion engine vehicles from 
the baseline scenario, developed with the PRIMES-TREMOVE model, and the estimated share of vehicles identified as 
high emitters using remote sensing or plume chasing (for HDVs) and not checked via roadside inspections (0.86% for 
M1, 1.62% for N1 and 1.26% for N2/N3 and M2/M3 vehicles).  
385 The labour costs decrease over time due to the decreasing number of internal combustion engine vehicles. 

180 

 
  
 
  
  
 
 
centres. The total revenues for PTI centres due to PM12 are estimated at EUR 21.4 billion in 2026, 
EUR 19.7 billion in 2030 and EUR 1.6 billion in 2050. Expressed as present value over 2026-2050, 
they are estimated at EUR 247.2 billion relative to the baseline. 

Table 162: Benefits for PTI centres due to PM12 in 2026, 2030, 2040 and 2050 in policy options PO1b, PO2 and 
PO3 relative to the baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

Difference to the baseline 

2026 
21.4 

2030 
19.7 

2040 
10.2 

2050 
1.6 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 163: Benefits for PTI centres due to PM12 in PO1b, PO2 and PO3 expressed as present value over 2026-
2050 relative to the baseline (in million EUR, 2022 prices) 

Revenues for PTI centres 

PO1a 

Difference to the baseline 

PO1b 
247.2  

PO2 
247.2  

PO3 
247.2  

Source: Ricardo et al. (2024), Impact assessment support study 

3.22.  PM13 – Mandatory inspection of cargo securing 

PM13 introduces mandatory standards in relation to cargo securing inspections. Currently 5 Member 
States (EE, FR, IE, LV and LU) do not require either minimum training or specify test requirements 
relating to cargo securing during RSI in their national transposition of Directive 2014/47/EC. N2 and 
N3 vehicles in these Member States represent around 13% of the EU-wide fleet. 14 Member States386, 
covering 67% of the N2/N3 fleet, do not specify minimum training requirements for cargo securing.  

3.22.1.  Adjustment costs for national public authorities  

PM13 is expected to lead to one-off adjustment costs for national public authorities for training in 
the 14 MS which currently do not require minimum training of inspectors. Training for cargo securing 
is assumed to take 3 hours, with 264 roadside inspectors requiring training. Assuming an hourly cost 
for technicians and associate professionals (ISCO 3) of EUR 34/hour387, the total one-off adjustment 
costs for training are estimated at EUR 26,916 in 2026.  

In addition, retraining of inspectors is foreseen on a biennial basis. Assuming 3 hours of training for 
the 264 roadside inspectors, the recurrent adjustment costs for training are estimated at EUR 26,916 
per year every second year after 2026. Expressed as present value over 2026-2050, they are estimated 
at EUR 224,549.   

3.22.2.  Administrative costs for national public authorities 

Recurrent administrative costs are expected for national public authorities, covering the labour costs 
for the additional cargo securing inspections. It is assumed that Member States that do not have in 
place minimum testing requirements for cargo securing do not perform cargo securing inspections. 
Based on stakeholders’ interviews, a cargo securing inspection takes on average 20 minutes. Cargo 
securing inspections are expected to cover 5% of the N2/N3 fleet in the Member States affected by 
the measure (EE, FR, IE, LV, LU). Assuming an hourly cost for technicians and professionals (ISCO 
3)  of  EUR  34/hour388,  the  recurrent  administrative  costs  for  national  public  authorities  in  the  5 
Member States are estimated at EUR 0.48 million in 2026, EUR 0.51 million in 2030 and EUR 0.63 

386 BE, DK, DE, EE, FR, IE, LV, LU, BG, FI, IT, NL, PL and PT.  
387 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 
388 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 

181 

 
  
  
 
 
million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 9.8 million 
relative to the baseline.  

Table 164: Adjustment and administrative costs for national public authorities due to PM13 in 2026, 2030, 2040 
and 2050 in policy options PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for training 
Recurrent costs for training 
Recurrent administrative costs 

2026 
0.03 
0.03 
0.00 
0.48 

Difference to the baseline 
2040 
2030 
0.03 
0.03 
0.00 
0.00 
0.03 
0.03 
0.57 
0.51 

2050 
0.03 
0.00 
0.03 
0.63 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 165: Adjustment and administrative costs for national public authorities due to PM13 in PO1b, PO2 and 
PO3 expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off costs for training 
Recurrent costs for training 
Recurrent administrative costs 

PO1a 

Difference to the baseline 
PO2 
PO1b 
0.25 
0.25 
0.03 
0.03 
0.22 
0.22 
9.84 
9.84 

PO3 
0.25 
0.03 
0.22 
9.84 

Source: Ricardo et al. (2024), Impact assessment support study 

3.22.3.  Administrative costs for businesses (vehicle owners)  

From  the  vehicle  owner  point  of  view,  there  will  be  some  extra  cost  for  the  additional  time  for 
cooperating on the cargo securing inspections. Considering an average hourly labour cost of EUR 
21.9  for  drivers389,  the  average  time  per  inspection  (20  minutes)  and  the  number  of  roadside 
inspections, the recurrent administrative costs for businesses (vehicle owners) are estimated at EUR 
0.42 million in 2026, EUR 0.44 million in 2030 and EUR 0.55 million in 2050. Expressed as present 
value over 2026-2050, they are estimated at EUR 8.5 million relative to the baseline. 

Table 166: Administrative costs for businesses (vehicle owners) due to PM13 in 2026, 2030, 2040 and 2050 in policy 
options PO1b, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Number of additional inspections 
Recurrent  administrative  costs  (in  million 
EUR) 

Difference to the baseline 

2026 
42,477 

0.42 

2030 
44,813 

0.44 

2040 
50,414 

0.50 

2050 
55,526 

0.55 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 167: Administrative costs for businesses (vehicle owners) due to PM13 in PO1b, PO2 and PO3 expressed as 
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 

Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 

Difference to the baseline 
PO2 
PO1b 
8.5 
8.5 

PO3 
8.5 

There may also be costs for subsequent adjustments following these inspections, which may result in 
additional time and potential cost if the vehicle has to be taken to a garage for repair. These costs are 
difficult to estimate, and they do not represent costs directly arising from the implementation of the 

389 Part of ISCO 8 (Plant and machine operators and assemblers). 

182 

 
  
  
 
 
 
 
  
  
 
 
measure  but  are  a  consequence  of  the  fact  that  specific  vehicles  may  not  be  compliant  with  the 
proposed minimum requirements. 

3.23.  PM14 - Extend the scope of application of roadside inspections to light commercial (N1) 

vehicles  

PM14 extends the scope of application of roadside inspections to N1 vehicles, and sets 2% as target 
for the share of inspections of the N1 vehicle fleet. The extension of roadside inspections to cover 
N1 vehicles is expected to lead to administrative costs for 22 Member States. On the basis of the 
information  available,  few  Member  States  (ES,  HU,  SE,  SK  and  FI)  already  conduct  roadside 
inspections for N1 vehicles, although without a certain target set and thus checking a low number of 
vehicles. For the purposes of the assessment it is assumed that these five Member States will not be 
affected. To perform the inspections, additional roadside inspection units will be needed in the 22 
Member States resulting in adjustment costs for national public authorities.  

3.23.1.  Administrative costs for national public authorities  

Performing  inspections  for  2%  of  the  N1  vehicle  fleet  in  the  Member  States  affected  by  PM14 
translates  into  479,626  additional  inspections  in  2026,  497,627  in  2030  and  588,721  additional 
inspections  in  2050.  With  an  assumed  average  duration  of  20  minutes  per  roadside  inspection, 
assuming  an  average  wage  of  EUR  34  EUR/hour  for  ISCO  3  (technicians  and  associate 
professionals),  the  cost  per  inspection  is  estimated  at  EUR  11.3.  Thus,  the  total  recurrent 
administrative costs are estimated at EUR 5.4 million in 2026, EUR 5.6 million in 2030 and EUR 6.7 
million in 2050. Expressed as present value over 2026-2050, they are estimated at EUR 107.5 million 
relative to the baseline.  

3.23.2.  Adjustment costs for national public authorities  

The  extra  inspections  will  be  delivered  by  an  estimated  total  of  182  inspectors390  in  around  61 
roadside inspection units (assuming three inspectors per roadside inspection unit). These units will 
need to be equipped with relevant equipment. The one-off cost of the roadside equipment is around 
EUR 50,000, and the maintenance cost is estimated at 10% of the capital cost. Thus, the total one-off 
adjustment  costs  for  the  61  roadside  inspection  units  are  estimated  at  EUR  3.1  million  in  2026. 
Recurrent adjustment costs amount at EUR 305,000 per year from 2026 onwards, or EUR 5.5 million 
expressed as present value over 2026-2050.  

Additional training costs may also arise for the additional inspectors. Assuming one-day training per 
inspector  and  an  average  wage  of  EUR  34  EUR/hour  for  ISCO  3  (technicians  and  associate 
professionals), the one-off adjustment costs for training are estimated at EUR 45,028 in 2026.  

Table 168: Adjustment and administrative costs for national public authorities due to PM14 in 2026, 2030, 2040 
and 2050 in policy options PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Additional number of inspections 
Recurrent administrative costs 
Total adjustment costs 
One-off costs for equipment  
Recurrent costs for equipment 

Difference to the baseline 

2026 
479,626 
5.4 
3.4 
3.1 
0.3 

2030 
497,627 
5.6 
0.3 
0.0 
0.3 

2040 
547,848 
6.2 
0.3 
0.0 
0.3 

2050 
588,721 
6.7 
0.3 
0.0 
0.3 

390  Estimated  assuming  that  each  inspector  performs  roadside  inspections  on  average  4  hours/day  for  a  total  of  220 
days/year.  

183 

 
  
 
One-off costs for training 

Difference to the baseline 

2026 
0.05 

2030 
0.00 

2040 
0.00 

2050 
0.00 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 169: Adjustment and administrative  costs for national public  authorities due to  PM14 in PO2 and PO3 
expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Difference to the baseline 

Recurrent administrative costs 
Total adjustment costs 
One-off costs for equipment  
Recurrent costs for equipment 
One-off costs for training 

PO1a 

PO1b 

PO2 
107.5  
8.6  
3.1  
5.5  
0.05  

PO3 
107.5  
8.6  
3.1  
5.5  
0.05  

Source: Ricardo et al. (2024), Impact assessment support study 

3.23.3.  Administrative costs for businesses (vehicle owners) 

Business (vehicle owners) will incur some costs due to the time spent for cooperating on inspections. 
Considering  the  average  duration  of  20  minutes  per  roadside  inspection,  and  the  average  hourly 
labour cost of EUR 21.9 for drivers391, the recurrent administrative costs for businesses are estimated 
at EUR 10.5 million in 2026, EUR 10.9 million in 2030 and EUR 12.9 million in 2050. Expressed as 
present value over 2026-2050, they are estimated at EUR 208 million relative to the baseline. 

There may also be costs for the repairs needed as a result of these inspections. These costs are difficult 
to estimate and they do not represent costs directly arising from the implementation of the measure 
but a consequence of the fact that the specific vehicles are non-compliant.  

Table 170: Administrative costs for businesses (vehicle owners) due to PM14 in 2026, 2030, 2040 and 2050 in policy 
options PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Number of additional inspections 
Recurrent  administrative  costs  (in  million 
EUR) 

Difference to the baseline 

2026 
479,626 

10.5 

2030 
497,627 

10.9 

2040 
547,848 

12.0 

2050 
588,721 

12.9 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 171: Administrative costs for businesses (vehicle owners) due to PM14 in PO2 and PO3 expressed as present 
value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 

Source: Ricardo et al. (2024), Impact assessment support study 

PO1a 

PO1b 

PO2 
208.0 

PO3 
208.0 

Difference to the baseline 

3.24.  PM15  -  Extend  the  scope  of  application  of  roadside  inspections  to  2-  and  3-wheeled 

vehicles (L-vehicles from L3) 

PM15  extends  the  scope  of  application  of  roadside  inspections  to  2-  and  3-wheeled  vehicles  (L-
vehicles from L3) and establishes a threshold of 1% of the vehicle fleet for roadside inspections. 

391 Part of ISCO 8 (Plant and machine operators and assemblers).  

184 

 
  
  
 
 
 
 
 
 
 
 
 
 
  
  
 
 
 
3.24.1.  Administrative costs for national public authorities  

The measure is expected to lead to additional costs for the enforcement authorities responsible for 
roadside  inspections.  This  will  mainly  cover  the  need  to  deploy  more  inspectors  to  conduct  the 
additional number of inspections, together  with  the additional mobile units needed to  support  the 
increased number of roadside inspections. Few Member States (SE, SI, AT, FI, DK, HU, RO) already 
perform such inspections although they do not report the exact number of inspections of motorcycles 
separately and do not indicate a specific target. In the absence of more specific data it is assumed that 
these Member States will not be affected by PM15.  

Establishing a 1% threshold for roadside inspections of L3 vehicles for the 20 Member States would 
result in 169,098 additional roadside inspections in 2026, 176,228 in 2030 and 227,291 additional 
inspections in 2050. An average of 10 minutes per inspection is assumed. With an average wage of 
EUR 34 EUR/hour for ISCO 3 (technicians and associate professionals), the cost per inspection is 
estimated at EUR 5.7. The total recurrent administrative costs for inspections are estimated at EUR 
0.96 million in 2026, EUR 1 million in 2030 and EUR 1.29 million in 2050. Expressed as present 
value over 2026-2050, they are estimated at EUR 19.5 million relative to the baseline.  

3.24.2.  Adjustment costs for national public authorities  

The  additional  volume  of  RSI  will  require  the  purchase  of  additional  mobile  inspection  units  to 
support the extra inspections. On the basis of the additional number of inspections to be conducted it 
is estimated that a total of 32 inspectors will be needed for the 20 Member States. With an average 
of 3 inspectors per unit, each Member State will need a minimum of one additional set of roadside 
equipment for testing of motorcycles. The one-off cost per equipment is estimated at EUR 20,000, 
and the recurrent maintenance cost at 10% of the initial cost. Thus, the total one-off adjustment costs 
amount to EUR 400,000 in 2026 and the recurrent adjustment costs at EUR 40,000 per year from 
2026  onwards.  Expressed  as  present  value  over  2026-2050,  the  recurrent  adjustment  costs  are 
estimated at EUR 717,422. 

Additional training costs may also arise for the additional inspectors. Assuming one-day training per 
inspector  and  an  average  wage  of  EUR  34  EUR/hour  for  ISCO  3  (technicians  and  associate 
professionals), the one-off adjustment costs for training are estimated at EUR 7,917 in 2026 for the 
32 inspectors.  

Table 172: Adjustment and administrative costs for national public authorities due to PM15 in 2026, 2030, 2040 
and 2050 in policy option PO3 relative to the baseline (in million EUR, 2022 prices) 

Additional number of inspections 
Recurrent administrative costs 
Total adjustment costs 
One-off costs for equipment  
Recurrent costs for equipment 
One-off costs for training 

Difference to the baseline 

2026 
169,098 
0.96 
0.45 
0.40 
0.04 
0.01 

2030 
176,228 
1.00 
0.04 
0.00 
0.04 
0.00 

2040 
199,644 
1.13 
0.04 
0.00 
0.04 
0.00 

2050 
227,291 
1.29 
0.04 
0.00 
0.04 
0.00 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 173: Adjustment and administrative costs for national public authorities due to PM15 in PO3 expressed as 
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 
Total adjustment costs 
One-off costs for equipment  

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 
19.52  
1.13  
0.40  

185 

 
  
  
 
 
 
 
 
 
 
 
 
Difference to the baseline 

PO1a 

PO1b 

PO2 

Recurrent costs for equipment 
One-off costs for training 

Source: Ricardo et al. (2024), Impact assessment support study 

3.24.3.  Administrative costs for citizens (vehicle owners) 

PO3 
0.72  
0.01  

Citizens  (motorcycle  owners)  will  incur  some  costs  due  to  the  time  spent  for  cooperating  on 
inspections. Considering the average duration of 10 minutes per roadside inspection, and the average 
hourly labour cost of EUR 29.5, the recurrent administrative costs for citizens are estimated at EUR 
0.8 million in 2026, EUR 0.9 million in 2030 and EUR 1.1 million in 2050. Expressed as present 
value over 2026-2050, they are estimated at EUR 16.9 million relative to the baseline. 

There may also be costs for the repairs needed as a result of these inspections. These costs are difficult 
to estimate and they do not represent costs directly arising from the implementation of the measure 
but are a consequence of the fact that the specific vehicles are non-compliant.  

Table 174: Administrative costs for citizens (vehicle owners) due to PM15 in 2026, 2030, 2040 and 2050 in policy 
option PO3 relative to the baseline (in million EUR, 2022 prices) 

Number of additional inspections 
Recurrent  administrative  costs  (in  million 
EUR) 

Difference to the baseline 

2026 
169,098 

0.8 

2030 
176,228 

0.9 

2040 
199,644 

1.0 

2050 
227,291 

1.1 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 175: Administrative costs for citizens (vehicle owners) due to PM15 in PO3 expressed as present value over 
2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative costs 

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 
16.9 

3.25.  PM16  -  Introduce  issuing  the  registration  certificates  in  digital  format  to  gradually 

replace current paper (and smart card) documents 

PM16 requires to issue the Registration Certificate (Annex I) for all vehicles types in digital format. 
The measure is expected to lead to administrative costs for national public authorities for setting up 
and operating the system, but also to administrative costs savings.  

3.25.1.  Administrative costs for national public authorities 

Based on stakeholders’ interviews392, the one-off cost for the adaptation of the IT system is estimated 
at  EUR  300,000  to  EUR  1,000,000  per  country,  depending  on  the  volume  of  new  registrations. 
Assuming one-off costs of EUR 300,000 per IT system for each of the 16 Member States with smaller 
volumes of new registrations393, EUR 500,000 per IT system for each of the 6 Member States with 

392  Different  agencies,  such  as  the  Centre  for  Vehicles  of  Croatia  and  the  Norwegian  Public  Roads  Administration, 
anticipate various software and resource requirements, while DGT Spain foresees significant time and resource costs for 
implementation.  TÜV  Rheinland  expects  additional  IT  development  and  management  costs  but  considers  them  not 
significant due to existing data availability. 
393 Below 2% of the total number of new registrations at EU level in 2026 by Member State. These are: BG, CY, DK, 
EE, FI, HR, HU, IE, LT, LV, LU, MT, PT, SE, SI and SK. 

186 

 
  
 
 
 
 
 
 
  
  
 
 
 
 
medium volumes of new registrations394 and EUR 1,000,000 per IT system for each of the 5 Member 
States with  higher volumes of new registrations395, the total  one-off administrative costs at  EU27 
level are estimated at EUR 12.8 million in 2026. Recurrent administrative costs for maintenance are 
estimated  at  around  10%  of  the  capital  costs,  or  EUR  1.3  million  per  year  from  2026  onwards. 
Expressed as present value over 2026-2050, the recurrent administrative costs are estimated at EUR 
23 million relative to the baseline. Since certain Member States (e.g. DE, ES, FI) have started to work 
on the implementation of digital registration documents, the actual costs incurred by these Member 
States may be lower than estimated here. 

Table 176: Administrative costs for national public administrations due to PM16 in 2026, 2030, 2040 and 2050 in 
policy options PO1a, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off costs for IT systems 
Recurrent costs for maintenance of the IT systems 

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

2026 
14.1 
12.8 
1.3 

2030 
1.3 
0.0 
1.3 

2040 
1.3 
0.0 
1.3 

2050 
1.3 
0.0 
1.3 

Table  177:  Administrative  costs  for  national  public  administrations  due  to  PM16  in  PO1a,  PO2  and  PO3, 
expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off costs for IT systems 
Recurrent costs for maintenance of the IT systems 

Source: Ricardo et al. (2024), Impact assessment support study 

Difference to the baseline 

PO1b 

PO1a 
35.8  
12.8  
23.0  

PO2 
35.8  
12.8  
23.0  

PO3 
35.8  
12.8  
23.0  

3.25.2.  Administrative cost savings for national public authorities  

PM16 is expected to bring administrative costs savings for national public authorities, by avoiding 
the costs of printing, distribution and handling of paper/plastic documents.  

Considering  that  the  information  related  to  registration  certificates  is  already  stored  in  national 
databases, the costs savings due to PM16 are limited to the time spent for preparing and printing the 
documents and the costs of delivering the documents. It is assumed that around 2 minutes of work 
per document could be saved, at an average cost per hour for technicians and associate professionals 
(ISCO level 3) of EUR 34, plus EUR 2 per document for paper and mail cost. 

Recurrent administrative costs savings are estimated at EUR 75.4 million in 2026, EUR 79.3 million 
in 2030 and EUR 86.3 million in 2050. Expressed as present value over 2026-2050, they are estimated 
at EUR 1.4 billion relative to the baseline. 

Table 178: Administrative costs savings for national public administrations due to PM16 in 2026, 2030, 2040 and 
2050 in policy options PO1a, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative cost savings 

Difference to the baseline 

2026 
75.4 

2030 
79.3 

2040 
85.2 

2050 
86.3 

Source: Ricardo et al. (2024), Impact assessment support study 

394 Between 2% and 10% of the total number of new registrations at EU level in 2026 by Member State. These are: AT, 
BE, CZ, EL, NL and RO. 
395 Above 10% of the total number of new registrations at EU level in 2026 by Member State. These are:  DE, FR, IT, PL 
and ES.       

187 

 
  
  
 
 
 
  
 
Table 179: Administrative costs savings for national public administrations due to PM16 in PO1a, PO2 and PO3, 
expressed as present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Recurrent administrative cost savings 

PO1a 
1,429.5  

Difference to the baseline 
PO2 
PO1b 
1,429.5  

PO3 
1,429.5  

Source: Ricardo et al. (2024), Impact assessment support study 

3.26.  PM17 - Add new data to the vehicle register – minimum mandatory set (including among 
others:  country  of  1st  registration,  registration  status,  PTI  status,  changes  due  to 
transformation) 

PM17 provides  for increasing  the set  of data to  be included in  the national  vehicle registers. The 
additional data that could be included is detailed in Annex 7 (section 2).  

3.26.1.  Administrative costs for national public authorities 

A consensus has been reached among 18 vehicle authorities (including 15 from EU Member States) 
regarding  a  minimum  set  of  items  for  the  vehicle  registers396.  This  data  set  comprises  94  items, 
including  mandatory  and  optional  data  elements  referred  to  in  the  VRD  Directive  (Directive 
1999/37/EC), as well as a number of additional elements.  

In several Member States, some of these items might already be part of their registration databases, 
making the costs associated with aligning their datasets with EReg's recommendations negligible. 
For instance, according to EReg, inspection data is registered by Registration Authorities in most 
MS, with the exception of HR, FR, IE and LT397. Other MS will have to include new data items in 
their vehicle registers. The Slovenian authorities, that provided input to the stakeholders’ consultation 
survey, estimated the one-off costs of adding the minimum dataset to its vehicle register at around 
EUR 50,000. Based on the hourly wage rate for clerks (ISCO 4) in Slovenia, of EUR 14.7/hour, the 
one-off costs are equivalent to 2.1 full-time equivalents working 220 days per year, 7.3 hours per 
day.  

For the assessment of PM17, it should be acknowledged that not all Member States would need to 
update their databases or integrate new data, as many of them already store most of these data items. 
The Member States that store fewer data items than the average were identified, pointing to a cluster 
of  countries  with  insufficient  data  registration  standards.  This  low-standard  data  storage  group 
includes eight countries: BE, FR, EL, HU, IE, LT, PL and PT. For the purpose of the assessment, it 
is assumed that this specific group will bear one-off administrative costs for harmonising the dataset. 
The one-off administrative costs are derived drawing on input from Slovenia, assuming 2.1 full-time 
equivalents  working  220  days  per  year,  7.3  hours  per  day.  Using  the  hourly  wage  rate  for  clerks 
(ISCO 4)398 in each of the 8 concerned Member States, the one-off administrative costs are provided 
in the table below. At EU level, they are estimated at EUR 494,593 in 2026. 

396 EReg (2021), EReg Topic Group XXI Harmonisation of registration procedures and data quality, Proposal on the 
registration  of  vehicle  data,  available  at:  https://www.ereg-association.eu/media/2742/final-report-topic-group-xxi-
proposal-on-the-registration-of-vehicle-data.pdf  
397 EReg (2021), ibid.  
398 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 

188 

 
  
 
 
Table 180: One-off administrative costs for national public authorities, by Member State, due to PM17 in 2026 in 
policy options PO1a, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Low-standard data storage group  

Average hourly wage for 
clerks (ISCO 4), in 2022 
prices 

One-off 
administrative costs 
(EUR) 

BE 
IE 
EL 
FR 
LT 
HU 
PL 
PT 
Total 

31.6 
31.0 
16.3 
30.1 
8.7 
9.1 
8.4 
11.7 

106,427 
104,390 
54,870 
101,353 
29,294 
30,551 
28,372 
39,336 
494,593 

Source: Ricardo et al. (2024), Impact assessment support study 

In addition, recurrent administrative costs are expected for the continuous data updates and broader 
maintenance  of  the  dataset  for  all  EU  Member  States.  The  effort  for  data  updates  and  broader 
maintenance is assumed at 25% of the one-off costs, or around 0.5 full-time equivalents per Member 
State. Assuming 220 working days per year, 7.3 working hours per day at an hourly wage rate for 
clerks (ISCO 4)399, the recurrent administrative costs by national public authority are provided in the 
table  below.  At  EU  level,  they  are  estimated  at  EUR  440,680  per  year  from  2026  onwards,  or 
expressed as present value over 2026-2050 at EUR 7.9 million relative to the baseline.  

Table 181: Recurrent administrative costs for national public authorities, by Member State, due to PM17 in 2026, 
2030, 2040 and 2050 in policy options PO1a, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Average hourly wage for 
clerks (ISCO 4), in 2022 
prices 

Recurrent 
administrative costs 
(EUR) 

BE 
BG 
CZ 
DK 
DE 
EE 
IE 
EL 
ES 
FR 
HR 
IT 
CY 
LV 
LT 
LU 
HU 
MT 
NL 
AT 
PL 
PT 

31.6 
4.8 
12.1 
45.1 
33.2 
12.7 
31.0 
16.3 
21.0 
30.1 
10.2 
27.6 
14.5 
9.9 
8.7 
34.0 
9.1 
15.6 
31.1 
32.2 
8.4 
11.7 

25,340 
3,823 
9,709 
36,152 
26,624 
10,149 
24,855 
13,064 
16,794 
24,132 
8,189 
22,102 
11,637 
7,940 
6,975 
27,187 
7,274 
12,523 
24,874 
25,749 
6,755 
9,366 

399 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs. 

189 

 
  
  
 
RO 
SI 
SK 
FI 
SE 
Total 

Average hourly wage for 
clerks (ISCO 4), in 2022 
prices 

Recurrent 
administrative costs 
(EUR) 

7.3 
14.7 
11.2 
30.1 
35.9 

5,849 
11,785 
8,930 
24,142 
28,761 
440,680 

Source: Ricardo et al. (2024), Impact assessment support study 

The total administrative costs at EU level for national public authorities, expected as a result of PM17, 
are summarised in the tables below.  

Table 182: Administrative costs for national public authorities due to PM17 in 2026, 2030, 2040 and 2050 in policy 
options PO1a, PO2 and PO3 relative to the baseline (in million EUR, 2022 prices) 

Total administrative costs 
One-off administrative costs 
Recurrent administrative costs 

2026 
0.9 
0.5 
0.4 

Difference to the baseline 
2030 
0.4 
0.0 
0.4 

2040 
0.4 
0.0 
0.4 

2050 
0.4 
0.0 
0.4 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 183: Administrative costs for national public authorities due to PM17 in PO1a, PO2 and PO3 expressed as 
present value over 2026-2050 relative to the baseline (in million EUR, 2022 prices) 

Total adjustment costs 
One-off administrative costs 
Recurrent administrative costs 

PO1a 
8.4 
0.5 
7.9 

Difference to the baseline 
PO1b 

PO2 
8.4 
0.5 
7.9 

PO3 
8.4 
0.5 
7.9 

Source: Ricardo et al. (2024), Impact assessment support study 

Increased  and  more  accessible  data  to  authorities  and  inspection  centres  would  facilitate  re-
registration and RSI.  

3.27.  Summary of costs and costs savings by option and by measure  

The summary of recurrent and one-off costs and costs savings by stakeholder group, by option and 
by measure, expressed as present value over 2026-2050, and for 2026, 2030 and 2050 relative to the 
baseline are provided in the tables below.  

3.27.1.  PTI centres 

Table 184: Recurrent and one-off costs, costs savings and benefits for PTI centres in the policy options, expressed 
as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices) 

PO1a 

PO1b 

PO2 

PO3 

Difference to the baseline 

Adjustment costs 

PMC1 
PMC2 
PMC3 
PMC4 
PM2 
PM3 
PM4 

3,734.1 
143.6 
96.1 
697.1 
2,797.3 

23,507.9 
143.6 
96.1 
697.1 
2,797.3 
175.7 

23,332.2 
143.6 
96.1 
697.1 
2,797.3 

25,061.7 
143.6 
96.1 
697.1 
2,797.3 

203.9 
225.4 

190 

 
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
PM5 
PM6 
PM7 
PM10 
PM12 

Administrative costs 

PM11 

Administrative costs 
savings 
PM11 
Benefits 
PMC5 
PM2 
PM3 
PM4 
PM5 
PM6 
PM12 
Net benefits 

PO1a 

PO1b 

PO2 

PO3 

Difference to the baseline 

647.7 
17,680.8 

1,170.6 
99.0 
0.0 

0.0 

39,394.2 
860.5 
294.1 

1,454.8 
36,537.6 
247.2 
15,886.2 

647.7 
17,680.8 

1,170.6 
99.0 
136.5 
136.5 
1,643.4 

1,643.4 
39,100.1 
860.5 

1,454.8 
36,537.6 
247.2 
17,274.7 

647.7 
17,680.8 
1,300.2 
1,170.6 
99.0 
136.5 
136.5 
1,643.4 

1,643.4 
39,968.0 
860.5 

341.3 
526.6 
1,454.8 
36,537.6 
247.2 
16,413.2 

0.0 

0.0 

860.5 
860.5 

-2,873.6 

Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs. 

Table 185: One-off costs for PTI centres in the policy options, expressed as present value over 2026-2050 relative 
to the baseline, in million EUR (2022 prices) 

PO1a 

PO1b 

PO2 

PO3 

Difference to the baseline 

2,094.7 
143.6 
96.1 
372.7 
1,482.3 

Adjustment costs 

PMC1 
PMC2 
PMC3 
PMC4 
PM2 
PM3 
PM4 
PM5 
PM6 
PM7 
PM10 

Administrative costs 

0.0 

3,221.3 
143.6 
96.1 
372.7 
1,482.3 
3.9 

20.1 
1,097.9 

4.7 
0.0 

PM11 
Net costs 

2,094.7 

3,221.3 

Source: Ricardo et al. (2024), Impact assessment support study 

3,217.4 
143.6 
96.1 
372.7 
1,482.3 

20.1 
1,097.9 

4.7 
48.9 
48.9 
3,266.3 

3,708.7 
143.6 
96.1 
372.7 
1,482.3 

4.5 
1.1 
20.1 
1,097.9 
485.6 
4.7 
48.9 
48.9 
3,757.6 

Table 186: Recurrent and one-off costs, costs savings and benefits for PTI centres in the policy options, in 2026, 
2030 and 2050, relative to the baseline, in million EUR (2022 prices) 

Difference to the baseline 

PO1a 
2030 
115.8 

24.4 
0.0 
18.1 
73.3 

2026 
2,162 

119.8 
96.1 
390.8 
1,556 

2050 
91.4 

2026 
4,186 

0.0 
0.0 
18.1 
73.3 

119.8 
96.1 
390.8 
1,556 

PO1b 
2030 
1,130 

24.4 
0.0 
18.1 
73.3 

2050 
1,177 

2026 
4,175 

0.0 
0.0 
18.1 
73.3 

119.8 
96.1 
390.8 
1,556 

PO2 
2030 
1,121 

24.4 
0.0 
18.1 
73.3 

2050 
1,166 

2026 
4,603 

0.0 
0.0 
18.1 
73.3 

119.8 
96.1 
390.8 
1,556 

PO3 
2030 
1,313 

24.4 
0.0 
18.1 
73.3 

2050 
1,241 

0.0 
0.0 
18.1 
73.3 

Adjustment 
costs 

PMC1 
PMC2 
PMC3 
PMC4 

191 

 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Difference to the baseline 

PO1a 
2030 

2050 

2026 

PO1b 
2030 
8.9 

2026 
11.9 

2026 

2050 
11.1 

PO2 
2030 

2050 

2026 

PO3 
2030 

2050 

69.6 
1,870 

49.2 
886.0 

4.9 
995.7 

69.6 
1,870 

49.2 
886.0 

4.9 
995.7 

Admin costs 

0.0 

0.0 

0.0 

63.6 
8.6 

0.0 

61.8 
8.0 

0.0 

73.7 
0.6 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

44.1 
44.1 

45.5 
45.5 

52.3 
52.3 

2,086 
44.1 
14.8 

2,135 
45.5 
15.1 

2,275 
52.3 
19.0 

63.6 
8.6 

53.8 

53.8 
84.1 

61.8 
8.0 

4.9 

4.9 
87.1 

73.7 
0.6 

4.9 

4.9 
99.3 

84.1 
2,071 
44.1 

87.1 
2,120 
45.5 

99.3 
2,256 
52.3 

PM2 
PM3 
PM4 
PM5 
PM6 
PM7 
PM10 
PM12 

PM11 
Admin costs 
savings 
PM11 
Benefits 
PMC5 
PM2 
PM3 
PM4 
PM5 
PM6 
PM12 
Net benefits 

13.7 
12.3 
69.6 
1,870 
402.8 
63.6 
8.6 

53.8 

53.8 
84.1 

84.1 
2,115 
44.1 

17.0 
26.6 
115.8 
1,890 
21.4 
-2,458 

10.2 
11.9 
49.2 
886.0 
170.2 
61.8 
8.0 

4.9 

4.9 
87.1 

87.1 
2,166 
45.5 

17.5 
28.0 
115.0 
1,940 
19.7 
934.7 

13.0 
13.4 
4.9 
995.7 
48.0 
73.7 
0.6 

4.9 

4.9 
99.3 

99.3 
2,309 
52.3 

22.1 
31.5 
9.4 
2,192 
1.6 
1,163 

115.8 
1,890 
21.4 
-2,100 

115.0 
1,940 
19.7 
1,006 

9.4 
2,192 
1.6 
1,097 

115.8 
1,890 
21.4 
-2,073 

115.0 
1,940 
19.7 
1,082 

9.4 
2,192 
1.6 
1,184 

-2,118 

-70.3 

-39.1 

Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs. 

Table 187: One-off costs for PTI centres in the policy options, in 2026, 2030 and 2050, relative to the baseline, in 
million EUR (2022 prices) 

Difference to the baseline 

PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

Adjustment 
costs 

PMC1 

PMC2 

PMC3 

PMC4 

PM2 

PM3 

PM4 

PM5 

PM6 

PM7 

PM10 

Administrative 
costs 

PM11 

Net costs 

2,071 

24.4 

0.0 

3,111 

29.4 

1.7 

3,107 

29.3 

1.7 

3,479 

151.6 

119.8 

96.1 

372.7 

1,482 

24.4 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

119.8 

96.1 

372.7 

1,482 

24.4 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

119.8 

96.1 

372.7 

1,482 

24.4 

0.0 

0.0 

0.0 

3.3 

0.02 

0.04 

20.1 

1,012 

4.7 

0.0 

0.0 

4.9 

0.0 

0.0 

0.0 

1.7 

0.0 

0.0 

20.1 

1,012 

4.7 

48.9 

48.9 

0.0 

0.0 

0.0 

2,071 

24.4 

0.0 

3,111 

29.4 

1.7 

3,156 

0.0 

4.9 

0.0 

0.0 

0.0 

29.3 

0.0 

0.0 

0.0 

0.0 

0.0 

1.7 

0.0 

0.0 

0.0 

1.7 

119.8 

96.1 

372.7 

1,482 

3.8 

1.0 

20.1 

1,012 

367.0 

4.7 

48.9 

48.9 

24.4 

0.0 

0.0 

0.0 

0.02 

0.02 

0.0 

4.9 

122.2 

0.0 

0.0 

0.0 

3,528 

151.6 

1.7 

0.0 

0.0 

0.0 

0.0 

0.06 

0.00 

0.0 

1.7 

0.0 

0.0 

0.0 

0.0 

1.7 

Source: Ricardo et al. (2024), Impact assessment support study 

192 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
3.27.2.  Garages, motor vehicle dealers, tyre and repair stations, etc. 

Table 188: Recurrent  and one-off costs for garages, motor vehicle  dealers,  tyre and repair stations, etc. in the 
policy options, expressed as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices) 

Administrative costs 

PMC9 

PO1a 

460.0 

460.0 

Difference to the baseline 
PO1b 

PO2 

460.0 

460.0 

460.0 

460.0 

PO3 

460.0 

460.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 189: Recurrent  and one-off costs for garages, motor vehicle  dealers,  tyre and repair stations, etc. in the 
policy options, in 2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices) 

PO1a 

2030 

2026 

Difference to the baseline 

PO1b 

PO2 

PO3 

2050 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

2030 

2050 

172.7 

19.4 

14.9 

172.7 

19.4 

14.9 

172.7 

19.4 

14.9 

172.7 

19.4 

14.9 

172.7 

19.4 

14.9 

172.7 

19.4 

14.9 

172.7 

19.4 

14.9 

172.7 

19.4 

14.9 

Administrative 
costs 

PMC9 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 190: One-off costs for garages, motor vehicle dealers, tyre and repair stations, etc. in the policy options, in 
2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices) 

Difference to the baseline 

PO1a 

PO1b 

PO2 

PO3 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

2030 

2050 

Administrative 
costs 

PMC9 

149.2 

149.2 

0.0 

0.0 

0.0 

0.0 

149.2 

149.2 

0.0 

0.0 

0.0 

149.2 

0.0 

149.2 

0.0 

0.0 

0.0 

149.2 

0.0 

149.2 

0.0 

0.0 

0.0 

0.0 

Source: Ricardo et al. (2024), Impact assessment support study 

3.27.3.  OEMs 

Table 191: Recurrent and one-off costs for OEMs in the policy options, expressed as present value over 2026-2050 
relative to the baseline, in million EUR (2022 prices) 

Administrative costs 

PM11 

PO1a 

Difference to the baseline 
PO1b 

PO2 

0.0 

0.0 

55.9 

55.9 

PO3 

55.9 

55.9 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 192: Recurrent and one-off costs for OEMs in the policy options, in 2026, 2030 and 2050, relative to the 
baseline, in million EUR (2022 prices) 

Difference to the baseline 

Administrative 
costs 

PM11 

PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

22.0 

22.0 

PO2 

2030 

2.0 

2.0 

2050 

2026 

2.0 

22.0 

2.0 

22.0 

PO3 

2030 

2.0 

2.0 

2050 

2.0 

2.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 193: One-off costs for OEMs in the policy options, in 2026, 2030 and 2050, relative to the baseline, in million 
EUR (2022 prices) 

Difference to the baseline 

PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

20.0 

0.0 

0.0 

20.0 

0.0 

0.0 

Administrative 
costs 

193 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

PM11 

20.0 

0.0 

0.0 

20.0 

0.0 

0.0 

Difference to the baseline 

Source: Ricardo et al. (2024), Impact assessment support study 

3.27.4.  Other businesses (vehicle owners) 

Table 194: Recurrent costs, costs savings and benefits for other businesses (vehicle owners) in the policy options, 
expressed as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices) 

PO1a 

PO1b 

PO2 

PO3 

Difference to the baseline 

Administrative costs 

PMC5 
PM4 
PM5 
PM6 
PM12 
PM13 
PM14 

Administrative costs 
savings 
PM12 
Benefits 
PMC9 
Net benefits 

524.2 
524.2 

0.0 

118,340.5 
118,340.5 

117,816.3 

25,458.4 
524.2 

1,454.8 
23,295.9 

175.0 
8.5 

1,287.3 

1,287.3 

118,340.5 
118,340.5 

94,169.4 

25,666.4 
524.2 

1,454.8 
23,295.9 

175.0 
8.5 
208.0 
1,287.3 

1,287.3 

118,340.5 
118,340.5 

93,961.3 

26,051.5 
524.2 
385.1 
1,454.8 
23,295.9 

175.0 
8.5 
208.0 
1,287.3 

1,287.3 

118,340.5 
118,340.5 

93,576.3 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 195: Recurrent costs, costs savings and benefits for other businesses (vehicle owners) in the policy options, 
in 2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices) 

Difference to the baseline 

PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

27.0 

27.8 

31.6 

1,362 

1,394 

1,443 

1,372 

1,405 

1,456 

1,392 

1,425 

1,479 

27.0 

27.8 

31.6 

27.0 

27.8 

31.6 

27.0 

27.8 

31.6 

115.8 

1,204 

14.8 

0.4 

115.0 

1,237 

14.0 

0.4 

9.4 

1,400 

1.2 

0.5 

115.8 

1,204 

14.8 

0.4 

10.5 

115.0 

1,237 

14.0 

0.4 

10.9 

0.0 

0.0 

0.0 

109.4 

102.6 

10.1 

109.4 

102.6 

6,043 
6,043 

6,016 

6,353 
6,353 

6,325 

6,991 
6,991 

6,959 

109.4 

6,043 
6,043 

4,791 

102.6 

6,353 
6,353 

5,062 

10.1 

6,991 
6,991 

5,558 

109.4 

6,043 
6,043 

4,780 

102.6 

6,353 
6,353 

5,051 

9.4 

1,400 

1.2 

0.5 

12.9 

10.1 

10.1 

6,991 
6,991 

5,545 

27.0 

19.3 

115.8 

1,204 

14.8 

0.4 

10.5 

27.8 

20.4 

115.0 

1,237 

14.0 

0.4 

10.9 

109.4 

102.6 

109.4 

6,043 
6,043 

4,761 

102.6 

6,353 
6,353 

5,030 

31.6 

23.1 

9.4 

1,400 

1.2 

0.5 

12.9 

10.1 

10.1 

6,991 
6,991 

5,522 

Administrative 
costs 

PMC5 

PM4 

PM5 

PM6 

PM12 

PM13 

PM14 

Administrative 
costs savings 
PM12 

Benefits 
PMC9 

Net benefits 

Source: Ricardo et al. (2024), Impact assessment support study 

194 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
3.27.5.  Citizens (vehicle owners) 

Table 196: Recurrent costs, costs savings and benefits for citizens (vehicle owners) in the policy options, expressed 
as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices) 

PO1a 

PO1b 

PO2 

PO3 

Difference to the baseline 

344.2 

336.3 
7.9 

Adjustment costs 

PMC5 
PM1 
PM2 
PM3 
PM4 
PM6 
PM12 
PM15 

Adjustment costs savings 

878.2 

PM7 
PM8 
PM9 

Administrative costs savings 

PM12 
Benefits 
PMC9 
Net benefits 

878.2 
0.0 

65,666.9 
65,666.9 
66,200.9 

13,944.3 

336.3 

294.1 

13,241.7 
72.2 

2,144.6 

2,144.6 

591.9 

591.9 
65,666.9 
65,666.9 
54,459.0 

13,658.1 

336.3 
7.9 

13,241.7 
72.2 

2,144.6 

2,144.6 

591.9 

591.9 
65,666.9 
65,666.9 
54,745.2 

14,150.0 

336.3 

341.3 
141.5 
13,241.7 
72.2 
16.9 
4,289.3 
4,289.3 

591.9 

591.9 
65,666.9 
65,666.9 
56,398.0 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 197: Recurrent costs, costs savings and benefits for citizens (vehicle owners) in the policy options, in 2026, 
2030 and 2050, relative to the baseline, in million EUR (2022 prices) 

Difference to the baseline 

PO1a 

2030 

2026 

PO1b 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

17.5 

18.1 

21.1 

724.9 

742.0 

832.3 

710.6 

727.3 

813.8 

735.3 

752.8 

844.9 

17.1 

0.4 

17.7 

0.4 

20.6 

0.5 

17.1 

17.7 

20.6 

17.1 

0.4 

17.7 

0.4 

20.6 

0.5 

17.1 

17.7 

20.6 

14.8 

15.1 

19.0 

17.0 

7.3 

17.5 

7.6 

22.1 

8.4 

686.5 

703.4 

792.3 

686.5 

703.4 

792.3 

686.5 

703.4 

792.3 

6.5 

5.8 

0.3 

6.5 

5.8 

0.3 

6.5 

0.8 

5.8 

0.9 

0.3 

1.1 

49.0 

49.0 

49.0 

110.7 

114.1 

127.4 

110.7 

114.1 

127.4 

221.5 

228.2 

254.8 

110.7 

114.1 

127.4 

110.7 

114.1 

127.4 

221.5 

228.2 

254.8 

49.0 

0.0 

49.0 

0.0 

49.0 

0.0 

3,381 

3,381 

3,412 

3,554 

3,554 

3,585 

3,857 

3,857 

3,885 

53.4 

48.8 

53.4 

3,381 

3,381 

2,820 

48.8 

3,554 

3,554 

2,975 

2.8 

2.8 

3,857 

3,857 

3,155 

53.4 

48.8 

53.4 

3,381 

3,381 

2,834 

48.8 

3,554 

3,554 

2,990 

2.8 

2.8 

3,857 

3,857 

3,173 

53.4 

48.8 

53.4 

3,381 

3,381 

2,920 

48.8 

3,554 

3,554 

3,078 

2.8 

2.8 

3,857 

3,857 

3,269 

Administrative 
costs 

PMC5 

PM1 

PM2 

PM3 

PM4 

PM6 

PM12 

PM15 

Adjustment 
costs savings 

PM7 

PM8 

PM9 

Administrative 
costs savings 
PM12 

Benefits 

PMC9 

Net benefits 

Source: Ricardo et al. (2024), Impact assessment support study 

195 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
3.27.6.  National public authorities 

Table 198: Recurrent  and one-off costs, and costs savings for  national public  authorities in the policy options, 
expressed as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices) 

Adjustment costs 

PMC2 
PMC3 
PMC4 
PM1 
PM9 
PM12 
PM13 
PM14 
PM15 

Administrative costs 

PMC6 
PMC7 
PMC8 
PMC9 
PM1 
PM11 
PM13 
PM14 
PM15 
PM16 
PM17 

Enforcement costs 

PM2 
PM3 
PM4 

Administrative costs savings 

PMC6 
PMC7 
PM16 
Net benefits 

PO1a 

Difference to the baseline 
PO1b 

PO2 

7.0 
0.2 
1.3 
3.8 
0.3 
1.4 

2,233.8 
33.7 
15.4 
9.4 
2,122.1 
9.1 

35.8 
8.4 
0.0 

5,226.3 

3,155.0 
641.8 
1,429.5 
2,985.5 

198.3 
0.2 
1.3 
3.8 

192.9 
0.3 

2,190.4 
33.7 
15.4 
9.4 
2,122.1 

9.8 

32.9 
32.9 

3,796.8 

3,155.0 
641.8 

1,375.2 

207.2 
0.2 
1.3 
3.8 
0.3 

192.9 
0.3 
8.6 

2,387.5 
33.7 
15.4 
9.4 
2,122.1 
9.1 
36.3 
9.8 
107.5 

35.8 
8.4 
0.0 

5,226.3 

3,155.0 
641.8 
1,429.5 
2,631.6 

PO3 

208.0 
0.2 
1.3 
3.8 

192.9 
0.3 
8.6 
1.1 
2,397.9 
33.7 
15.4 
9.4 
2,122.1 

36.3 
9.8 
107.5 
19.5 
35.8 
8.4 
77.4 

38.1 
39.2 
5,226.3 

3,155.0 
641.8 
1,429.5 
2,543.1 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 199: Recurrent and one-off costs, and costs savings for national public authorities in the policy options, in 
2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices) 

Difference to the baseline 

PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

Adjustment 
costs 

PMC2 

PMC3 

PMC4 

PM1 

PM9 

PM12 

PM13 

PM14 

4.6 

0.2 

0.7 

2.1 

0.1 

1.4 

0.1 

0.1 

36.1 

9.6 

9.6 

39.6 

9.9 

9.9 

39.9 

9.9 

9.9 

0.2 

0.7 

2.1 

0.03 

0.1 

0.03 

0.1 

0.03 

0.1 

0.01 

0.03 

0.1 

0.01 

33.0 

0.03 

9.4 

0.03 

9.4 

0.03 

0.2 

0.7 

2.1 

0.1 

33.0 

0.03 

3.4 

0.03 

0.1 

0.01 

9.4 

0.03 

0.3 

0.03 

0.1 

0.01 

9.4 

0.03 

0.3 

0.2 

0.7 

2.1 

0.03 

0.1 

0.03 

0.1 

33.0 

0.03 

3.4 

9.4 

0.03 

0.3 

9.4 

0.03 

0.3 

196 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
  
  
  
  
  
  
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Difference to the baseline 

PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

0.45 

0.04 

0.04 

176.9 

115.3 

129.7 

161.9 

113.7 

128.0 

197.1 

122.8 

138.3 

197.6 

123.3 

139.0 

18.6 

8.5 

1.2 

0.9 

0.4 

0.5 

0.9 

0.4 

0.5 

18.6 

8.5 

1.2 

0.9 

0.4 

0.5 

0.9 

0.4 

0.5 

18.6 

8.5 

1.2 

0.9 

0.4 

0.5 

0.9 

0.4 

0.5 

18.6 

8.5 

1.2 

0.9 

0.4 

0.5 

0.9 

0.4 

0.5 

133.1 

111.4 

125.6 

133.1 

111.4 

125.6 

133.1 

111.4 

125.6 

133.1 

111.4 

125.6 

0.5 

0.5 

0.6 

14.1 

0.9 

0.0 

1.3 

0.4 

0.0 

1.3 

0.4 

0.0 

0.5 

14.3 

0.5 

5.4 

14.1 

0.9 

0.0 

0.5 

1.3 

0.5 

5.6 

1.3 

0.4 

0.0 

0.6 

1.3 

0.6 

6.7 

1.3 

0.4 

0.0 

0.5 

0.5 

0.6 

1.6 

1.6 

1.7 

1.7 

2.1 

2.1 

14.3 

0.5 

5.4 

1.0 

14.1 

0.9 

3.9 

1.9 

2.0 

1.3 

0.5 

5.6 

1.0 

1.3 

0.4 

4.0 

2.0 

2.1 

1.3 

0.6 

6.7 

1.3 

1.3 

0.4 

4.8 

2.5 

2.3 

272.7 

282.3 

312.7 

197.3 

203.0 

226.4 

272.7 

282.3 

312.7 

272.7 

282.3 

312.7 

161.5 

167.3 

190.6 

161.5 

167.3 

190.6 

161.5 

167.3 

190.6 

161.5 

167.3 

190.6 

35.8 

75.4 

91.2 

35.8 

79.3 

35.8 

86.3 

35.8 

35.8 

35.8 

166.8 

182.9 

-2.4 

78.1 

86.7 

35.8 

75.4 

35.9 

35.8 

79.3 

35.8 

86.3 

149.6 

164.5 

35.8 

75.4 

31.2 

35.8 

79.3 

35.8 

86.3 

145.0 

159.0 

PM15 

Administrative 
costs 

PMC6 

PMC7 

PMC8 

PMC9 

PM1 

PM11 

PM13 

PM14 

PM15 

PM16 

PM17 

Enforcement 
costs 

PM2 

PM3 

PM4 

Administrative 
costs savings 
PMC6 

PMC7 

PM16 

Net benefits 

Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs. 

Table 200: One-off costs for national public authorities in the policy options, in 2026, 2030 and 2050, relative to 
the baseline, in million EUR (2022 prices) 

Difference to the baseline 

PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

PO3 

2030 

2050 

Adjustment 
costs 

PMC2 

PMC3 

PMC4 

PM1 

PM9 

PM12 

PM13 

PM14 

PM15 

Administrative 
costs 

PMC6 

PMC7 

PMC8 

PMC9 

PM11 

PM16 

4.4 

0.2 

0.7 

2.0 

0.1 

1.4 

0.0 

0.0 

26.5 

0.0 

0.0 

29.7 

0.0 

0.0 

30.0 

0.0 

0.0 

0.2 

0.7 

2.0 

23.6 

0.03 

0.2 

0.7 

2.0 

0.1 

23.6 

0.03 

3.1 

0.2 

0.7 

2.0 

23.6 

0.03 

3.1 

0.4 

64.9 

0.0 

0.0 

51.6 

0.0 

0.0 

77.9 

0.0 

0.0 

77.9 

0.0 

0.0 

17.8 

8.1 

0.7 

25.0 

12.8 

17.8 

8.1 

0.7 

25.0 

17.8 

8.1 

0.7 

25.0 

13.0 

12.8 

17.8 

8.1 

0.7 

25.0 

13.0 

12.8 

197 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
  
 
 
 
 
  
 
 
  
 
 
  
 
 
  
  
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
  
  
  
  
  
  
 
 
 
 
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
  
  
  
 
 
 
 
Difference to the baseline 

PO1a 

PO1b 

2026 

2030 

2050 

2026 

2030 

2050 

2026 

PO2 

2030 

2050 

2026 

0.5 

PO3 

2030 

2050 

0.5 

0.0 

0.0 

78.1 

0.0 

0.0 

107.6 

0.0 

0.0 

107.9 

0.0 

0.0 

PM17 

Net costs 

0.5 

69.3 

Source: Ricardo et al. (2024), Impact assessment support study 

4.  IMPACTS BY POLICY MEASURE ON SAFETY, EMISSIONS AND NOISE  

This  section  explains  the  inputs  used  for  deriving  the  impacts  of  the  policy  options  on  safety, 
emissions and noise. 

In the first step, the impacts by policy measure have been assessed, drawing on relevant inputs. These 
are explained in detail in the sections below. Only the measures with significant impact, which have 
been quantified, are included in the sections below. The table below summarises the list of relevant 
measures by policy option and type of impact.  

Table 201: Summary of measures by type of impact  

Measure  Relevant options 

Safety  

Air pollutant 
emissions 

Noise  

PMC2 
PMC3 
PMC4 
PM1 
PM2 
PM3 
PM4 
PM5 
PM6 
PM10 
PM12 
PM13 
PM14 
PM15 

PO1a, PO1b, PO2, PO3 
PO1a, PO1b, PO2, PO3 
PO1a, PO1b, PO2, PO3 
PO1a/ PO2 
PO1b 
PO3 
PO3 
PO1b, PO2, PO3 
PO1b, PO2, PO3 
PO1b, PO2, PO3 
PO1b, PO2, PO3 
PO1b, PO2, PO3 
PO2, PO3 
PO3 

Y 

Y 
Y 
Y 
Y 

Y 

Y 
Y 
Y 

Y 
Y 
Y 
Y 
Y 

Y 
Y 

Y 

Y 
Y 

Y 
Y 
Y 

Y 
Y 

Y 
Y 

In the second step, the inputs by policy measure are aggregated into policy options and used in the 
PRIMES-TREMOVE model to assess the impacts on the level of fatalities and injuries, emissions 
and external costs of accidents, emissions and noise.  

4.1.  Impacts on road safety  

4.1.1. 

Introduction  

A number of the proposed measures are expected to have a direct impact on road safety through more 
effective identification of vehicles with major and dangerous defects in the fleet and the subsequent 
fix of such defects to restore the vehicles to a safe status. This can be achieved either through more 
frequent  tests  or  more  effective  tests,  better  capable  of  capturing  defects  and  also  covering  new 
technologies. The reduction in the number of unsafe vehicles should eventually lead to a reduction 
of road accidents caused by technical defects and, as a result, a reduction in the number of fatalities 
and injuries (i.e., serious and slight injuries).  

198 

 
  
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In  addition,  a  broader  set  of  measures  that  are  expected  to  increase  the  effectiveness  of  the 
implementation and enforcement of overall roadworthiness legislation (such as those related to the 
exchange of data among authorities) can also indirectly contribute to the reduction of unsafe vehicles.  

4.1.2.  Approach  

Additional or more effective PTI and/or RSI inspections can help identify safety related defects and, 
by mandating repair, eliminate the safety related risk. This contributes to a reduction of the number 
of road accidents resulting in a reduction in the total number of fatalities and injuries compared to 
the baseline. 

The approach used for the assessment of the road safety impacts of individual measures is based on 
the following formula: 

% reduction of fatalities/injuries relative to the baseline = TD x PTI/RSI_Share x IE x RSI_EFF  

Where:  

•  TD refers to the contribution of technical defects to accidents. A value of 6% is assumed for 

motorcycles and 4% for all other vehicle categories (see below). 

•  PTI/RSI_Share refers to share of a specific vehicle category in the fleet that is expected to be 
subject to PTI/RSI inspection on an annual basis. This is based on the scope of the measure and 
determined by the vehicles average age and the test frequency400.  

• 

IE refers to the effectiveness of PTI/RSI inspections in identifying major and dangerous defects, 
assumed to be 95%.  

•  RSI_EFF  is  relevant  only  in  the  case  of  measures  including  RSI  and  refers  to  the  expected 
enhanced  effectiveness  of  targeted  roadside  inspections  to  identify  vehicles  with  technical 
defects, when compared to the PTI where there is no such targeted approach. A factor of three is 
used401. As example, if the fleet includes a 10% share of high emitters, RSI based on random 
selection would identify 10 high emitters in 100 roadside inspections, while targeted RSIs are 
expected to be able to identify 30 high emitters (3 x 10) in 100 roadside inspections.  

The  formula  aims  to  identify  the  expected  percentage  reduction  of  road  accidents  and  thus  of 
fatalities/injuries in relation to the baseline levels for each policy measure and vehicle category.  

In the second step, in order to calculate the combined effect on safety of the policy measures included 
in each option by Member State, the common residual method is applied: 

CE A, B, C, … = 1−[(1-IA)x(1-IB)x(1-IC)x(1-…)]  

Where: 

•  CE A, B, C denotes the combined effect of measures A, B, C, etc. 

400 For example, in the case of an average vehicle age of 15 years and a PTI frequency of 4/2/2 (four years for the first 
inspection and 2 thereafter) we can calculate a total of 6.5 inspections until the age 15 which means an annual frequency 
of 0.43 (=6.5/15) inspections. For L and O vehicle types the average vehicle age is 18 years and the total number of 
inspections over the lifetime of the vehicle is 8 resulting in an annual frequency of 0.44 (=8/18). 
401 Based on a comparison of the share of defective vehicles found at RSI in Member States applying targeted checks 
(based on risk rating for the selection of HDVs) to those that select vehicles randomly, the factor of 3 is assessed to be a 
conservative estimate. For LDVs, remote sensing will help selecting vehicles to be tested at roadside. 

199 

 
 
• 

IA, IB and Ic correspond to the expected level of impact (in percentage terms) of each measure. 

The  resulting  percentage  reduction  by  policy  option  and  Member  State  is  used  as  input  in  the 
PRIMES-TREMOVE  model  and  translated  into  absolute  levels  of  avoided  fatalities  and  injuries 
relative to the baseline. Based on the number of fatalities and injuries avoided, the reduction in the 
external costs of accidents is calculated402.  

4.1.3.  Key assumptions 

The TD parameter relating to the contribution of technical defects on fatalities is a key parameter in 
the assessment as it determines the maximum impact that can be possibly achieved by the removal 
of  unsafe  vehicles  from  EU  roads.  As  presented  in  more  detail  in  the  baseline  section,  there  is 
significant uncertainty in relation to this parameter, with estimates that range between 0.5% to up to 
20% in terms of the share of road accidents caused by technical defects. It should however be noted 
that methodologies vary significantly and they are often not comparable. Following a review of the 
literature403, a conservative approach has been used. A 4% contribution of technical defects to road 
accidents is assumed in the case of LDVs, HDVs and trailers. For motorcycles, given the presence of 
some evidence of higher levels of contribution of this vehicle type, 6% is assumed404. Given the high 
uncertainty,  sensitivity  analysis  has  been  performed,  considering  alternatives  of  1%  and  7% 
contribution for LDVs, HDVs and trailers and 3% and 9% for motorcycles.  

The IE parameter refers to the expected effectiveness of the inspections. A value of 95% is assumed 
based on the fact that inspections need to  follow an extensive list, covering all vehicle aspects  as 
defined in the annexes of the PTI and RSI Directives (2014/45/EU and 2014/47/EU). Furthermore, 
given the focus of this analysis on major or dangerous defects, it is reasonable to assume that in the 
majority of cases these will be effectively identified during the inspections, by a trained inspector.  

In addition, a one-to-one relationship between the impact on road accidents and fatalities and injuries 
is  assumed. Namely, a 1% reduction in  the number of road accidents  is assumed to  lead to  a 1% 
reduction  in  fatalities  and  injuries.  This  is  considered  a  reasonable  assumption,  even  though  it  is 
possible that the adoption of new vehicle technologies in the future may change this relationship over 
time.  

Another important assumption made is that unsafe vehicles inspected and repaired to pass a follow 
up PTI inspection, will maintain their roadworthy status following the PTI and will not deteriorate 
until the next PTI. This is an important assumption, especially when considering older vehicles where 
faster deterioration is more likely. There is however no standard approach or evidence available for 
assessing the impact of such deterioration over time. There are also certain limiting factors of such 
an effect. This includes the possibility that some vehicle owners will repair their vehicles before the 
PTI date, when a serious defect that may pose safety issues is identified. Further to that, roadside 

402  The  2019  Handbook  on  the  external  costs  of  transport  (Source:  https://op.europa.eu/en/publication-detail/-
/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1) has been used to monetise the costs. According to the Handbook, 
the  external cost of  a fatality in 2022 prices is estimated at EUR 3.9 million and that of a serious injury at EUR 0.6 
million. 
403 Hudec (2021), Examination of the results of the vehicles technical inspections in relation to the average age of vehicles 
in selected EU states; SAFERWHEELS (2018), Study on Powered Two-Wheeler and Bicycle Accidents in the EU, Final 
Report, Brussels  
404 The 4% and 6% are two percentage points lower than the levels of contribution assumed in the 2012 impact assessment 
support study. Reduced rates were considered more appropriate because the estimated impact on fatalities in the 2012 
impact assessment support study was significantly higher than what was actually observed on the basis of data from the 
CARE database. 

200 

 
 
inspections can also help identify such defects, although their effectiveness is limited by the small 
share of the fleet affected and the fact that they are only mandatory for HDVs. 

4.1.4.  PMC2 - Update PTI and RSI due to new requirements in General Safety Regulation and 
checking  emission  reduction  systems  (new  test  items,  including  checks  of  software 
status/integrity), by reading on-board diagnostics 

PMC2 requires to  update the PTI and RSI to  new requirements in  the General  Safety  Regulation 
(including software status/integrity of safety or emission relevant systems during PTI for all vehicles 
and  at  technical  roadside  inspections  of  commercial  vehicles),  resulting  in  safety  benefits.  The 
enhanced  testing  requirements  are  expected  to  ensure  detecting  and  resolving  defects  for  vehicle 
safety  features  introduced  by  the  General  Safety  Regulation  (GSR),  thus  enabling  the  full  safety 
benefit of GSR to be realised.  

The impact assessment accompanying the GSR405 estimated the number of fatalities that could be 
prevented by GSR across all vehicle categories during 2021-2037 for EU27 plus UK (line (a) in the 
table below). These estimates were converted to EU27 (line (b) in the table below) by deducting the 
UK’s  fleet  share,  and  then  translated  to  the  period  2026-2050  by  first  annualising  them  and  then 
multiplying by 25 years (line (c) in the table below).  

Defects in ADAS would result in a reduced effectiveness of the GSR measures. This is calculated by 
applying an ADAS  defect  rate (line (e) in  the table below) to  the share of fatalities that could  be 
avoided (line (d) in the table below). The ADAS defect rate is assumed to be the same as the defect 
rate of electronic safety components, which was estimated at 17% by the initiative for Diagnosis of 
Electronic Systems in Motor Vehicles for PTI406. This provides a maximum share of total fatalities 
that could be reduced by addressing ADAS defects. In the case of passenger cars this is estimated at 
9.4% reduction of fatalities from the baseline levels.  

Finally, a success rate of PTI inspections to capture defects (95%) is applied (line (f) in the table 
below). For example, for M1 vehicles PMC2 could reduce fatalities and injuries from MS affected 
by 1.5% (line (g) in the table below).  

The table below presents the data for the calculation of the impact of PMC2 on safety, as outlined 
above. 

Table 202: Estimated impact of PMC2 on fatalities and injuries  
N2/N3 

Variable 

M1 

N1 

M2/M3  Explanation/source 

MS affected  

All 

All 

All 

All 

100% 

100% 

100% 

100% 

21,337 

1,283 

1,947 

227 

Assumed to equal the total GSR 
life-saving potential of PO3. 
Source: SWD(2018)190 

Share of EU fatalities 
affected 

Total fatalities prevented by 
GSR safety measures across 
all vehicle categories over 
the period 2021–2037 for 
EU27 plus UK (a) 

405 SWD(2018)190 
406 SWD(2012)206 

201 

 
 
 
 
Variable 

M1 

N1 

N2/N3 

M2/M3  Explanation/source 

Total fatalities prevented by 
GSR safety measures across 
all vehicle categories over 
the period 2021–2037 for 
EU27 (b) 

Total fatalities prevented by 
GSR safety measures across 
all vehicle categories over 
the period 2026–2050 across 
EU27 (c) 

Proportion of fatalities 
prevented by GSR safety 
measures across all vehicle 
categories across EU27 (d) 

Defect rate of ADAS 
systems (e) 

Success rate of PTI/RIS to 
capture defects and address 
them (f) 

% reduction of 
fatalities/injuries in the MS 
affected (g)=(d)x(e)x(f) 

19,051 

1,146 

1,738 

203 

28,016 

1,685 

2,556 

298 

Using the share of UK fleet into 
the total EU27 plus UK fleet 
(12% according to Eurostat data: 
Stock of vehicles by category and 
NUTS 2 regions 
[TRAN_R_VEHST]) 

Converted to 2026-2050 period 
by annualising and multiplying by 
25 years 

9.4% 

3.0% 

3.4% 

2.5% 

GSR fatalities prevented / total 
fatalities in the baseline 

17% 

17% 

17% 

17% 

Assumed to be the same as the 
defect rate of ESC, which is 
estimated at 17% by IDELSY  

95% 

95% 

95% 

95% 

Assumption 

1.5% 

0.5% 

0.5% 

0.4% 

Decrease in fatalities relative to 
the baseline 

Source: Ricardo et al. (2024), Impact assessment support study 

4.1.5.  PM1 - RSI for heavy/powerful motorcycles (L category > 125cm3) as alternative measure, 

in the Member States where they are not subject to PTI (i.e., using available opt-out) 

PM1  will  require  that  those  Member  States  (BE,  FI,  IE,  NL,  MT,  PT)407  that  do  not  have  a  PTI 
requirement  for  motorcycles  introduce  roadside  inspections  for  motorcycles  over  125  cc  as  an 
alternative.  The  roadside  inspections  are  expected  to  cover  5%  of  the  number  of  motorcycles 
registered every year. The motorcycle fleet of these Member States represent on average 8.6% of the 
fleet over 2026-2050. Furthermore, as the measure does not cover L3-L7 motorcycles of less than 
125cc, the scope of the measure is also reduced (84.2% of the total L3-L7 on average over 2026-
2050).  

On  the  basis  of  the  assumed  effectiveness  of  roadside  inspections  (RSI)  in  detecting  defective 
vehicles when inspected (i.e., 95%=100%-5%) and the expected enhanced effectiveness of RSI to 
identify defective vehicles (factor of 3), the share of defective motorcycles that is expected to  be 
identified on an annual basis is estimated. With 5% of the fleet inspected annually, the reduction in 

407  Until  the  end  of  2023,  France  had  not  introduced  mandatory  PTI  for  motorcycles,  but the  French  authorities  had 
announced the intention to do so. For this reason, for the purposes of the analysis it was assumed that France would not 
be affected by the proposed measure. Denmark does not have mandatory PTI but it has introduced roadside inspections, 
and it is thus assumed to be part of the baseline. In the case of Portugal, current requirements cover only motorcycles 
over 250cc.  

202 

 
 
the  number  of  fatalities  and  injuries  is  estimated  at  0.7%  relative  to  the  baseline  for  the  six  MS 
affected.  

Table 203: Estimated impact of PM1 on fatalities and injuries 
Values 

Variable 

Label 

Calculation 

Share of EU fleet affected (L3-L7)  

Share of L3-L7 in measure scope  

Share  of  fatalities/injuries  of  MS  affected  in  EU 
total 

Share of accidents directly caused by motorcycle 
technical defects  

Share of motorcycles inspected in RSI 

Parameter  reflecting  RSI  enhanced  capacity  to 
select defective vehicles for RSI 

Failure  rate  of  inspections  in  detecting  defective 
vehicles  

8.6% 

84.2% 

8% 

6% 

5% 

3.0 

5% 

% reduction in fatalities/injuries from affected 
MS  

0.7% 

Source: Ricardo et al. (2024), Impact assessment support study 

(a) 

(b) 

(c) 

(d) 

(e) 

(f) 

(g) 

(h) 

(h)=(1–(g)) x (f) x (e) x (b) 
x (d) 

4.1.6.  PM2 - Mandatory PTI for motorcycles above 125cm3 (remove opt-out) 

PM2 introduces mandatory PTI for all motorcycles over 125cm3  (removing opt-out). Besides the 
Member States identified in PM1, Denmark will also need to introduce PTI for motorcycles over 
125cm under PM2. Thus, the Member States affected by PM2 are BE, DK, FI, IE, MT, NL and PT.  

In this case the impact will depend on the expected frequency of the PTI inspections which has been 
assumed to be the minimum one provided for M1/N1 vehicles in the Directive (4/2/2), leading to an 
average  frequency  of  0.44  inspections  per  year408.  Assuming  5%  failure  rate  of  PTI  in  detecting 
defective vehicles and a 6% contribution of technical defects to road accidents, the reduction in the 
number of fatalities/injuries in the MS affected is estimated at 2.2% relative to the baseline.  

Table 204: Estimated impact of PM2 on fatalities and injuries 

Variable 

Value 

Label 

Calculation 

Share of EU fleet affected (L3-L7) 

Share of L3-L7 in measure scope 

Share of fatalities/injuries of MS affected in EU total  

Share of accidents directly caused by motorcycle technical 
defects  

8.8% 

85.9% 

8.5% 

6% 

(a) 

(b) 

(c) 

(d) 

408 For L vehicle types the average vehicle age is 18 years and the total number of inspections over the lifetime of the 
vehicle is 8 resulting in an annual frequency of 0.44 (=8/18). 

203 

 
 
 
 
 
 
 
 
 
 
 
 
 
Variable 

Value 

Label 

Calculation 

Average share of vehicles tested in PTI per year 

Failure rate of PTI in detecting defective vehicles  

% reduction in fatalities/injuries for affected MS 

44% 

5% 

2.2% 

(e) 

(f) 

(g) 

(g)=(1-(f)) x (b) x (c) x (d) 
x (e) 

Source: Ricardo et al. (2024), Impact assessment support study 

4.1.7.  PM3 - Extend PTI to all motorcycles (i.e., incl. from 50cm3 = all L3e, L4e, plus tricycles 

(L5e) and heavy quadricycles (L7e) 

PM3 extends the type of motorcycles covered by PTI to those from 50cm3 in the eight Member States 
where such requirement is currently not in place (BE, FI, IE, NL, MT, PT, DK, CY409).  

As in the case of PM2, a 5% failure rate of PTI in detecting defective vehicles is assumed and an 
average frequency of 0.44 inspections per year. The reduction in the number of fatalities/injuries for 
the MS affected is estimated at 2.5% relative to the baseline.  

Table 205: Estimated impact of PM3 on fatalities and injuries 

Variable 

Value 

Label 

Calculation 

Share of EU fleet affected (L3-L7) 

Share of L3-L7 vehicle fleet in measure scope  

Share of fatalities/injuries of affected MS in EU total  

Share of accidents directly caused by motorcycle technical 
defects  

Average share of vehicles tested in PTI per year 

Failure rate of PTI in detecting defective vehicles  

10.2% 

100% 

9% 

6% 

44% 

5% 

(a) 

(b) 

(c) 

(d) 

(e) 

(f) 

% reduction in fatalities/injuries for affected MS 

2.5% 

(g) 

(g)=(1-(f)) x (b) x (d) x (e) 

Source: Ricardo et al. (2024), Impact assessment support study 

4.1.8.  PM4 - Mandatory PTI for light trailers (O1 and O2 categories)  

PM4 requires the mandatory PTI for light trailers (O1 and O2 categories). Eleven  Member States 
would be affected by PM4: 7 Member States where there is currently no requirement for PTI for 
either O1 or O2 (DK, EL, FI, FR, NL, IE, PT) and 4 Member States where there is currently only a 
requirement for PTI for O2 (PL, SK, BE and ES). 

In the case of O1 around 21.5% of the total EU fleet of O1 vehicles will be affected while in the case 
of O2 around 9.3%. Due to the significant data gaps in the number of O1 and O2 vehicles in the EU, 
the shares above are based on estimates linking the number of trailers with the number of passenger 

409 In Cyprus motorcycles above 125cm3 are already covered.  

204 

 
 
 
 
 
 
 
 
 
 
cars in the fleet410. 

There is also no detailed data on the number of fatalities from O1/O2 vehicles. Data from the CARE 
database concerning the fatalities and injuries of passenger cars with trailers has been used, since 
passengers cars are not permitted to pull trailers over 3,500 kg. Data is available for only a small 
number  of  Member  States411  for  the  period  2019-2021.  For  the  10  Member  States  where  data  is 
available, the average total number of fatalities per year is 16. Considering that these Member States 
represent around 26% of the estimated number of trailers in the EU fleet, the total number of fatalities 
at EU level is estimated at around 62. On the basis of CARE database, and using a similar approach, 
the level of serious injuries at EU level in which O1/O2 vehicles are involved is estimated at around 
324 per year and slight injuries at 1,778 per year.  

Assuming a contribution of technical  defects  of light  trailers to  road accidents of 4%, an average 
frequency of 0.44 inspections per year412 and a 5% failure rate of PTI detecting defective vehicles, 
the percentage reduction in the number of fatalities and injuries due to PM4 is estimated at 1.7% 
relative to the baseline for both O1 and O2 for the MS affected.  

Table 206: Estimated impact of PM4 on fatalities and injuries 

Variable 

Share of EU fleet affected 

O1 

21.5% 

O2 

9.3% 

Share of MS affected fleet in measure scope  

Share of accidents directly caused by vehicle 
technical defects  

Average share of vehicles tested in PTI per 
year 

Failure  rate  of  PTI  in  detecting  defective 
vehicles  

100% 

4% 

44% 

5% 

%  reduction 
affected MS 

in  fatalities/injuries  for 

1.7% 

1.7% 

Source: Ricardo et al. (2024), Impact assessment support study 

Label 

Calculation 

(a) 

(b) 

(c) 

(d) 

(e) 

(f) 

(f)=(1-(e)) x (b) x 
(c) x (d)  

4.1.9.  PM6 - Mandatory yearly testing for vehicles that are 10-year-old or older 

Currently,  11  MS  do  not  require  annual  PTI  testing  of  light-duty  vehicles  after  10  years  of  their 
registration (CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT, SK). All these Member States currently 
require an inspection every two years which means that the proposed measure will double the number 
of inspections for vehicles over 10 years.  

The  share  of  older  vehicles  that  contribute  to  accidents  due  to  technical  defects  is  calculated  by 
multiplying the share of accidents directly caused by technical defects (4%) by 1.77, to account for 

410 Data from Eurostat passenger car stock (road_eqs_carage) has been used to calculate the number of O1/O2 trailers 
per passenger cars for the Member States where data is available. The median was used to estimate the number of 
trailers in the MS where data is missing. A 50% split of O1/O2 was used where data was not available.  
411 AT, BG, DK, ES, FI, IT, LT, LV, PT and SE.  
412 This is based on an average lifetime of 18 years and a frequency pattern of 4/2/2 (8 inspections within the 18 year 
period). The average lifetime is estimated based on the average age of vehicles.  

205 

 
 
 
 
 
 
 
 
 
 
the higher rate of technical defects for older vehicles. The scaling factor (1.77) is calculated based on 
the IGLAD study413, on the distribution of vehicle accidents by age. A 5% failure rate of PTI detecting 
defective vehicles is assumed.  

The reduction in fatalities and injuries for the affected MS is calculated separately for M1 and N1 
vehicles, as shown in the table below, and is estimated at 1.2% for M1 vehicles and 0.9% for N1 
vehicles relative to the baseline.  

Table 207: Estimated impact of PM6 on fatalities and injuries 

Variable 

M1 

N1 

Label 

Calculation 

MS affected by measure 

CY, DE, LT, CZ, 
DK, FR, EL, HU, 
IT, MT, SK 

CY, DE, LT, 
CZ, DK, FR, 
EL, HU, IT, 
MT, SK 

Share of fatalities in MS affected in EU 
total  

53% 

Share of vehicle fleet in measure scope  

53% 

Share of accidents directly caused by 
technical defects  

Scale factor for increased older vehicle 
accidents 

Increase in the share of vehicles tested 
per year 

Failure rate of PTI in detecting defective 
vehicles  

4% 

1.77 

33% 

5% 

41% 

52% 

4% 

1.77 

26% 

5% 

% reduction in fatalities/injuries for 
affected MS 

1.2% 

0.9% 

Source: Ricardo et al. (2024), Impact assessment support study 

4.1.10.  PM13 - Mandatory inspection of cargo securing 

(a) 

(b) 

(c) 

(d) 

(e) 

(f) 

(g) 

(h) 

(h)=(1-(g)) x (c) x 
(d) x (e) x (f)  

PM13 introduces mandatory standards in relation to cargo securing inspections. Currently 5 Member 
States414  do  not  require  either  minimum  training  or  specify  test  requirements  relating  to  cargo 
securing  during  RSI  in  their  national  transposition  of  Directive  2014/47/EU.  For  calculating  the 
impacts, the vehicle fleet of the affected Member States are considered. N2 and N3 vehicles in these 
Member States represent around 13% of the EU-wide fleet. 14 Member States415, covering 67% of 
the N2/N3 fleet, do not specify minimum training requirements for cargo securing.  

Based on MS data and available estimates416, up to 25% of crashes involving N2/N3 vehicles are 
linked  to  cargo  securing  defects.  The  share  of  fatalities  attributable  to  cargo  unsafe  vehicles  was 

413 http://www.iglad.net/. 
414 EE, FR, IE, LV and LU. 
415 BE, DK, DE, EE, FR, IE, LV, LU, BG, FI, IT, NL, PL and PT.  
416 https://road-safety.transport.ec.europa.eu/eu-road-safety-policy/priorities/safe-vehicles/cargo-securing-and-
abnormal-loads_en  

206 

 
 
 
 
 
 
 
 
 
assumed  to  be  proportionate  to  the  share  of  cargo-related  accidents.  The  failure  rate  of  cargo 
inspections  in  detecting  unsafe  cargo  loading  (in  line  with  the  2014  European  best  practise 
guidelines417) is assumed to be 5%.  

To calculate the percentage reduction in fatalities due to this measure in the affected MS, the accuracy 
of cargo inspections was multiplied by the share of the fleet undergoing RSI each year and the share 
of fatalities attributable to unsafe cargo. The impact of introducing minimum training requirements 
was weighted by 50%, to reflect its lower contribution in reducing fatalities compared to minimum 
testing requirements. PM13 is estimated to reduce the number of fatalities and injuries in MS with 
no testing requirements by 1.19% relative to the baseline and in MS with no training requirements 
by 0.59%.  

Table 208: Estimated impact of PM13 on fatalities and injuries 

Variable 

Value 

Label 

Calculation 

MS which lack testing minimum requirements 
& training 

EE, FR, IE, LV and 
LU 

MS  which  only 
requirements 

lack  minimum 

training 

BE, DK, DE, EE, FR, 
IE, LV, LU, BG, FI, 
IT, NL, PL and PT 

Weighting  of  fatality  contribution  due  to  the 
lack of training requirements 

Share of fatalities in MS which lack testing and 
training minimum requirements in EU total  

Share  of  fatalities  in  MS  which  lack  training 
minimum requirements in EU total  

Share  of  crashes  where  N2/N3  cargo  defects 
played a role 

Share of vehicles undergoing RSI annually 

Failure  rate  of  cargo  inspections  in  detecting 
unsafe cargo loading 

%  reduction 
affected MS with no testing requirements 

fatalities/injuries 

in 

for 

%  reduction 
for 
affected MS with no training requirements 

fatalities/injuries 

in 

50% 

13% 

69% 

25% 

5% 

5% 

1.19% 

0.59% 

(a) 

(b) 

(c) 

(d) 

(e) 

(f) 

(g) 

(h) 

(i) 

(j) 

(i)=(f) x (g) x (1-(h)) 

(j)=(f) x (g) x (1-(h)) x (c) 

Source: Ricardo et al. (2024), Impact assessment support study 

4.1.11.  PM14 - Extend the scope of application of roadside inspections to light commercial (N1) 

vehicles 

PM14 extends the scope of application of roadside inspections to N1 vehicles, and sets 2% as target 
for the share of inspections of the N1 vehicle fleet. On the basis of the information available, few 
Member  States  (ES,  HU,  SE,  SK  and  FI)  already  conduct  roadside  inspections  for  N1  vehicles, 

417 Cargo securing for road transport - Publications Office of the EU (europa.eu) 

207 

 
 
 
 
 
 
 
 
 
 
although without a certain target set and thus checking a low number of vehicles. For the purposes 
of the assessment it is assumed that these five Member States will not be affected.  

The  inspections  in  the  22  Member  States  affected  are  expected  to  lead  to  the  identification  of 
defective vehicles and thus lead to the restoration of their safe vehicle status, with positive impacts 
on safety. 

The  failure  rate  of  inspections  in  detecting  defective  vehicles  is  assumed  at  5%.  Further,  the 
effectiveness of RSI to identify defective vehicles is considered to be 3 times higher than that of PTI 
tests (due to the more targeted approach adopted in selecting vehicles for the tests). Also considering 
the annual target of 2% of the N1 fleet being inspected and the fact that 4% of N1 vehicle accidents 
are directly caused by technical defects, the reduction in the number of fatalities and injuries for the 
22 Member States affected is estimated at 0.23% relative to the baseline.  

Table 209: Analysis of expected impact of PM14 on fatalities and injuries 

Variable 

Value 

Label 

Calculation 

Share of EU fleet in MS affected  

Share of EU fatalities in MS affected in EU total 

Share of N1 vehicle accidents directly caused by 
technical defects  

Share of N1 vehicles inspected  

Parameter reflecting RSI enhanced capacity to 
identify defective vehicles  

Failure rate of inspections in detecting defective 
vehicles  

77% 

89% 

4% 

2% 

3.0 

5% 

% reduction in fatalities/injuries for affected 
MS 

0.23% 

Source: Ricardo et al. (2024), Impact assessment support study 

(a) 

(b) 

(c) 

(d) 

(e) 

(f) 

(g) 

(g)=(1–(f)) x (c) x (d) x 
(e) 

4.1.12.  PM15 - Extend the scope of application of roadside inspections to 2- and 3-wheeled vehicles 

(L-vehicles from L3) 

PM15  extends  the  scope  of  application  of  roadside  inspections  to  2-  and  3-wheeled  vehicles  (L-
vehicles from L3) and establishes a threshold of 1% of the vehicle fleet for roadside inspections. 

Few Member States (SE, SI, AT, FI, DK, HU, RO) already perform such inspections although they 
do not report the exact number of inspections of motorcycles separately and do not indicate a specific 
target. In the absence of more specific data it is assumed that these Member States will not be affected 
by PM15.  

The  failure  rate  of  inspections  in  detecting  defective  vehicles  is  assumed  at  5%.  Further,  the 
effectiveness of RSI to identify defective vehicles is considered to be 3 times higher than that of PTI 
tests (due to the more targeted approach adopted in selecting vehicles for the tests). Also considering 
the annual target of 1% of the N1 fleet being inspected and the fact that 6% of motorcycle-related 
accidents are directly caused by technical defects, the reduction in the number of fatalities and injuries 
for the 20 Member States affected is estimated at 0.17% relative to the baseline. 

208 

 
 
 
 
 
 
 
Table 210: Estimated impact of PM15 on fatalities and injuries 

Variable 

Value 

Label 

Calculation 

Share of fleet in MS affected in EU total  

Share  of  EU  fatalities  in  MS  affected  in  EU 
total 

Share  of  accidents  directly  caused  by 
motorcycle technical defects  

Share of motorcycles inspected  

Parameter reflecting RSI enhanced capacity to 
select defective vehicles  

Failure 
rate  of 
defective vehicles  

inspections 

in  detecting 

92% 

91% 

6% 

1% 

3.0 

5% 

(a) 

(b) 

(c) 

(d) 

( e) 

(f) 

%  reduction 
affected MS 

in 

fatalities/injuries 

for 

0.17% 

(g) 

(1 – (f)) x (c) x (d) x (e) 

Source: Ricardo et al. (2024), Impact assessment support study 

4.1.13.  Impact on safety by policy option  

On the basis of the analysis of the impacts of each individual measure, the combined impact of the 
measures for each policy option is estimated using the common residual method explained above. 
The tables below summarise the expected impact on fatalities and injuries relative to the baseline (% 
change from the baseline) for each policy option, by Member State and vehicle type. These are used 
as inputs in the PRIMES-TREMOVE model to derive the number of fatalities and injuries avoided, 
as well as the reduction in the external costs of accidents.   

Table 211: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline, 
for M1 vehicle category 

PO1a 

PO1b 

PO2 

PO3 

AT 

BE 

BG 

CY 

DE 

EE 

FI 

FR 

EL 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

2.7% 

2.7% 

1.5% 

1.5% 

2.7% 

2.7% 

1.5% 

2.7% 

1.5% 

2.7% 

2.7% 

1.5% 

1.5% 

209 

1.5% 

1.5% 

1.5% 

2.7% 

2.7% 

1.5% 

1.5% 

2.7% 

2.7% 

1.5% 

2.7% 

1.5% 

2.7% 

2.7% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

2.7% 

2.7% 

1.5% 

1.5% 

2.7% 

2.7% 

1.5% 

2.7% 

1.5% 

2.7% 

2.7% 

1.5% 

1.5% 

 
 
 
 
 
 
 
  
MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

ES 

DK 

CZ 

PO1a 

PO1b 

PO2 

PO3 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

2.7% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

2.7% 

1.5% 

2.7% 

2.7% 

2.7% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

2.7% 

1.5% 

2.7% 

2.7% 

2.7% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

1.5% 

2.7% 

1.5% 

2.7% 

2.7% 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 212: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline, 
for N1 vehicle category 

PO1a 

PO1b 

PO2 

PO3 

AT 

BE 

BG 

CY 

DE 

EE 

FI 

FR 

EL 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

ES 

DK 

CZ 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

1.4% 

1.4% 

0.5% 

0.5% 

1.4% 

1.4% 

0.5% 

1.4% 

0.5% 

1.4% 

1.4% 

0.5% 

0.5% 

1.4% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

1.4% 

0.5% 

1.4% 

1.4% 

0.7% 

0.7% 

0.7% 

1.6% 

1.6% 

0.7% 

0.5% 

1.6% 

1.6% 

0.7% 

1.4% 

0.7% 

1.6% 

1.6% 

0.7% 

0.7% 

1.6% 

0.7% 

0.7% 

0.7% 

0.7% 

0.5% 

0.7% 

1.4% 

0.5% 

1.6% 

1.6% 

0.7% 

0.7% 

0.7% 

1.6% 

1.6% 

0.7% 

0.5% 

1.6% 

1.6% 

0.7% 

1.4% 

0.7% 

1.6% 

1.6% 

0.7% 

0.7% 

1.6% 

0.7% 

0.7% 

0.7% 

0.7% 

0.5% 

0.7% 

1.4% 

0.5% 

1.6% 

1.6% 

Source: Ricardo et al. (2024), Impact assessment support study 

210 

 
  
  
Table 213: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline, 
for N2/N3 vehicle categories 

PO1a 

PO1b 

PO2 

PO3 

AT 

BE 

BG 

CY 

DE 

EE 

FI 

FR 

EL 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

ES 

DK 

CZ 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

0.5% 

1.1% 

0.5% 

0.5% 

1.7% 

1.1% 

1.7% 

0.5% 

1.1% 

0.5% 

1.7% 

1.1% 

0.5% 

1.7% 

1.7% 

0.5% 

1.1% 

1.1% 

1.1% 

0.5% 

1.1% 

0.5% 

0.5% 

1.1% 

0.5% 

0.5% 

0.5% 

0.5% 

1.1% 

0.5% 

0.5% 

1.7% 

1.1% 

1.7% 

0.5% 

1.1% 

0.5% 

1.7% 

1.1% 

0.5% 

1.7% 

1.7% 

0.5% 

1.1% 

1.1% 

1.1% 

0.5% 

1.1% 

0.5% 

0.5% 

1.1% 

0.5% 

0.5% 

0.5% 

0.5% 

1.1% 

0.5% 

0.5% 

1.7% 

1.1% 

1.7% 

0.5% 

1.1% 

0.5% 

1.7% 

1.1% 

0.5% 

1.7% 

1.7% 

0.5% 

1.1% 

1.1% 

1.1% 

0.5% 

1.1% 

0.5% 

0.5% 

1.1% 

0.5% 

0.5% 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 214: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline, 
for M2/M3 vehicle categories 

PO1a 

PO1b 

PO2 

PO3 

AT 

BE 

BG 

CY 

DE 

EE 

FI 

FR 

EL 

HR 

HU 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

211 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

 
  
  
IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

ES 

DK 

CZ 

PO1a 

PO1b 

PO2 

PO3 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

0.4% 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 215: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline, 
for L3-L7 vehicle categories 

PO1a 

PO1b 

PO2 

PO3 

AT 

BE 

BG 

CY 

DE 

EE 

FI 

FR 

EL 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

0.0% 

0.7% 

0.0% 

0.0% 

0.0% 

0.0% 

0.7% 

0.0% 

0.0% 

0.0% 

0.0% 

0.7% 

0.0% 

0.0% 

0.0% 

0.0% 

0.7% 

0.7% 

0.0% 

0.7% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

2.2% 

0.0% 

0.0% 

0.0% 

0.0% 

2.2% 

0.0% 

0.0% 

0.0% 

0.0% 

2.2% 

0.0% 

0.0% 

0.0% 

0.0% 

2.2% 

2.2% 

0.0% 

2.2% 

0.0% 

0.0% 

0.0% 

0.0% 

212 

0.0% 

0.7% 

0.0% 

0.0% 

0.0% 

0.0% 

0.7% 

0.0% 

0.0% 

0.0% 

0.0% 

0.7% 

0.0% 

0.0% 

0.0% 

0.0% 

0.7% 

0.7% 

0.0% 

0.7% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

2.7% 

0.2% 

0.2% 

0.2% 

0.2% 

2.5% 

0.2% 

0.2% 

0.2% 

0.0% 

2.7% 

0.2% 

0.2% 

0.2% 

0.2% 

2.7% 

2.7% 

0.2% 

2.7% 

0.0% 

0.0% 

0.0% 

0.2% 

 
  
  
ES 

DK 

CZ 

PO1a 

PO1b 

PO2 

PO3 

0.0% 

0.0% 

0.0% 

0.0% 

2.2% 

0.0% 

0.0% 

0.0% 

0.0% 

0.2% 

2.5% 

0.2% 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 216: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline, 
for O1 vehicle category 

PO1a 

PO1b 

PO2 

PO3 

AT 

BE 

BG 

CY 

DE 

EE 

FI 

FR 

EL 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

ES 

DK 

CZ 

0.0% 

1.7% 

0.0% 

0.0% 

0.0% 

0.0% 

1.7% 

1.7% 

1.7% 

0.0% 

0.0% 

1.7% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

1.7% 

1.7% 

1.7% 

0.0% 

0.0% 

0.0% 

1.7% 

1.7% 

1.7% 

0.0% 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 217: Estimated reduction in the number of fatalities and injuries by policy option, relative to the baseline, 
for O2 vehicle category 

PO1a 

PO1b 

PO2 

PO3 

AT 

BE 

BG 

CY 

DE 

EE 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

213 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
FI 

FR 

EL 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

ES 

DK 

CZ 

PO1a 

PO1b 

PO2 

PO3 

1.7% 

1.7% 

1.7% 

0.0% 

0.0% 

1.7% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

1.7% 

0.0% 

1.7% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

1.7% 

0.0% 

Source: Ricardo et al. (2024), Impact assessment support study 

4.2.  Impacts on air pollutant emissions and noise 

4.2.1. 

Introduction 

In the case of impacts on emissions and noise, the approach adopted was to estimate the expected 
contribution of each measure on the identification and removal of high emitter vehicles (whether due 
to defective emissions control systems or tampering) from the fleet. It is assumed that high emitters 
identified will undergo repair (whether this refers to the replacement of malfunctioning filters, sensor 
or sound control system or the necessary modifications of the engine). The focus of the analysis is 
on  high  emitters  only  (i.e.,  vehicles  with  emissions  multiple  times  higher  than  the  type-approval 
limits) as these are expected to be possible to capture during PTI and RSI or with the help of remote 
sensing.  

It should be noted that there is no standard definition of a high emitter418. A pragmatic approach has 
been  used  for  the  analysis,  making  use  of  information/data  provided  in  relevant  studies,  while 
recognising that they are not always consistent in the definition applied. Furthermore, it should be 
noted that high emitters may be vehicles with defective emission or noise control systems or vehicles 
with tampered emissions/noise control systems. In the absence of more detailed information, a 50% 

418 One possible definition would be: a vehicle whose average emissions are at least 2 standard deviations 
higher than the average emissions of the sample tested (https://pure.iiasa.ac.at/id/eprint/10156/1/XO-12-019.pdf). Euro 
7 on-board monitoring principle sets detecting exceedances at a level of at least 2,5 times the relevant exhaust emission 
limit value. 

214 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
share of defective and tampered vehicles is assumed in the total share of high emitters in the fleet. 
There is also a need to separate the two since it can be expected that tampered vehicles will not be 
effectively captured as part of a PTI. Their owners may be expected to activate the relevant control 
system before the PTI and then deactivate it again. This is possibly a simplification of reality so it is 
assumed that only 10% of tampered vehicles will be captured as part of the PTI.  

The  analysis  of  the  impacts  on  emissions  focuses  on  the  two  pollutants  that  are  targeted  in  the 
proposed measures, namely, NOx and PN/PM. Other pollutants have not been considered in detail 
although it is conceivable that, by identifying high emitters for these two categories of pollutants, 
there may also be benefits related to other pollutant types (e.g. CO, HC, SO2).      

4.2.2.  Approach 

The approach used to estimate the impacts on air pollutant emissions focuses on the extent to which 
additional or more effective PTI and/or RSI inspections can help identify high emitter vehicles and, 
by mandating repair, align the vehicle emissions with the  type-approval values. As a result, these 
would contribute to the reduction of the total emissions relative to the baseline.  

The approach used for the assessment of the impacts of individual measures is based on the following 
formula: 

Percentage  reduction  of  high  emitters  share  =  ((PTI_Share  x  (DEF  +  TAMP  x  PTI_TE)  + 
RSI_Share (DEF + TAMP) x RSI_EFF)) x IE / HE  

Where:  

•  PTI_Share refers to share of vehicles in the fleet that are expected to be subject to PTI on an 
annual basis. This is based on the scope of the measure, and determined by the vehicles average 
age and the test frequency419. Increased scope and frequency of PTI should in principle lead to a 
higher share of high emitters identified in the fleet.  

•  RSI_Share refers to share of vehicles in the fleet that are expected to be subject to RSI inspection 
on an annual basis. This is based on the scope of the measure. Increased scope of inspections 
should in principle lead to a higher share of high emitters identified in the fleet.  

•  DEF refers to the share of vehicles with defective emissions or noise control systems in the fleet 
in the baseline, for the specific vehicle category, fuel and EURO standard. In the absence of more 
detailed  data  these  are  assumed  to  be  half  of  the  total  high  emitters  for  the  specific  vehicle 
category, fuel and EURO standard.  

•  TAMP refers to the share of vehicles with tampered emissions or noise control systems in the 
fleet in the baseline. They are assumed to represent the remaining half of the total high emitters 
for the specific vehicle category, fuel and EURO standard.  

•  PTI_TE reflects the limited capacity of PTI to capture tampered vehicles. A share of 10% is 

assumed to be captured as part of the PTI420.  

419 For example, in the case of an average vehicle lifetime of 15 years and a PTI frequency of 4/2/2 (four years for the 
first  inspection  and  2  thereafter)  we  can  calculate  a  total  of  6.5  inspections  until  the  age  15  which  means  an  annual 
frequency of 0.43 (=6.5/15) inspections. For L and O vehicle types the  average  vehicle age is 18 years and the total 
number of inspections over the lifetime of the vehicle is 8, resulting in an annual frequency of 0.44 (=8/18). 
420 Giechaskiel, B., et al., (2022), Effect of tampering on on-road and off-road diesel vehicle emissions. Sustainability, 
14(10), p. 6065. 

215 

 
 
•  RSI_EFF  is  relevant  only  in  the  case  of  measures  including  RSI  and  refers  to  the  expected 
enhanced  effectiveness  of  targeted  roadside  inspections  to  identify  vehicles  with  technical 
defects when compared to the PTI (where there is no such targeted approach). A factor of three 
is used421. As example, if the fleet includes a 10% share of high emitters, RSI based on random 
selection would identify 10 high emitters in 100 roadside inspections, while targeted RSIs are 
expected to be able to identify 30 high emitters (3 x 10) in 100 roadside inspections. 

• 

IE refers to the effectiveness of the specific test method used to identify high emitting vehicles. 
This varies depending on the method used and is explained under the relevant policy measures.  

•  HE is the total share of high emitters in the baseline, equal to TAMP + DEF. 

The above formula aims to identify the expected level of reduction of high emitters in the fleet, as a 
percentage of the baseline figures. Namely, a 10% reduction relative to the baseline high emitters 
shares of 10% will mean a reduction by one percentage point, leading to a new level of high emitters 
of 9%. This can then be translated into actual emissions reductions, on the base of the emission factors 
of high emitters defined in the baseline.  

Furthermore, as in the case of safety, in order to calculate the combined effect of the policy measures 
included in each option, the common residual method is applied: 

CE A, B, C, … = 1−[(1-IA)x(1-IB)x(1-IC)x (1-…)]  

Where: 

•  CE A, B, C denotes the combined effect of measures A, B, C, etc. 

• 

IA, and  IB  and  Ic  correspond  to  the  expected  level  of  impact  (in  percentage  terms)  of  each 
measure. 

Similarly to the impacts on road safety, the percentage reduction of high emitters by policy option 
relative to the baseline is used as input in the PRIMES-TREMOVE model to calculate the reduction 
in air pollutant emissions, and in the external costs of emissions and noise422.  

4.2.3.  Key assumptions 

As indicated above, an assumption is made on the limited capacity of PTIs to capture tampering. 
These are those vehicles which are not brought back to their original pre-tampering state in view of 
the testing. A share of 10% of tampered vehicles is assumed to be captured as part of the PTI423. An 
enhanced effectiveness factor of 3 is used for RSI to reflect its targeted character424.  

An  additional  important  assumption  made  in  the  assessment  of  the  impacts  is  that  following  the 
identification of a high emitting vehicle and its repair/correction, while emission systems may not 

421 Based on a comparison of the share of defective vehicles found at RSI in Member States applying targeted checks 
(based on risk rating for the selection of HDVs) to those that select vehicles randomly, the factor of 3 is assessed to be a 
conservative estimate. For LDVs, remote sensing will help selecting vehicles to be tested at roadside. 
422  The  2019  Handbook  on  the  external  costs  of  transport  (Source:  https://op.europa.eu/en/publication-detail/-
/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1) has been used to monetise the costs.  
423 Giechaskiel, B., et al., (2022), Effect of tampering on on-road and off-road diesel vehicle emissions. Sustainability, 
14(10), p. 6065. 
424 Based on a comparison of the share of defective vehicles found at RSI in Member States applying targeted checks 
(based on risk rating for the selection of HDVs) to those that select vehicles randomly, the factor of 3 is assessed to be a 
conservative estimate. For LDVs, remote sensing will help selecting vehicles to be tested at roadside. 

216 

 
 
become as good as new, it can still be expected that any deterioration will be limited and will not 
lead to vehicles becoming high emitters again until the next PTI. This is considered to be a reasonable 
assumption, especially in the case of older vehicles where PTI frequency is higher. Since the analysis 
and  estimation  of  impacts  on  emissions  is  based  on  the  expected  reduction  in  the  share  of  high 
emitters, there is no risk of overestimation of the impacts due to the ongoing durability of the repairs 
following  PTI.  Further  to  that,  the  role  of  roadside  inspections  towards  achieving  continuous 
compliance  should  be  noted,  even  if  the  number  of  roadside  inspections  are  relatively  small  and 
currently  only  cover  heavy  duty  vehicles.  Furthermore,  enhanced  durability  of  vehicles  and 
components (at least partly driven by legal requirements) can also help maintain the performance of 
vehicles  over  time.  Euro  7  standards,  part  of  the  baseline,  are  expected  to  extend  the  durability 
requirements from the current levels of 100,000 km and 5 years (that do not cover older age vehicles), 
to 200,000 km425.   

4.2.4.  PMC3 - Mandatory PN testing of LDVs and HDVs equipped with particle filter, at PTI, and 

of HDVs at technical roadside inspections of commercial vehicles  

The implementation of PN emissions testing is expected to reduce the number of defective vehicles 
with PN emissions consistently over the legal value (that is, not temporarily higher than the legal 
requirement because of a just regenerated diesel particulate filter). PMC3 is thus expected to have an 
impact on air pollutant emissions. No impact on noise emissions is expected due to PMC3.  

The capacity of identifying faulty vehicles at PTI is assumed to be 95%. Some tampered vehicles 
will  also  be  identified  during  PTI.  These  are  those  vehicles  which  are  not  brought  back  to  their 
original pre-tampering state in view of the testing426. In addition, following the DIAS427 example, the 
share of fleet with defective emissions control system was assumed to be equal to the share of fleet 
with tampered emission control system. As explained above, it is assumed that 10% of the tampered 
vehicles are identified at PTI. The proportion of high emitters identified at PTI will also depend on 
the percentage of vehicles that undergo PTI checks. 

To estimate the impact of implementing the new PN test at PTI, the calculation is performed by using 
as  multiplicative  factor  (line  (h)  in  the  table  below),  the  difference  between  the  capabilities  of 
identifying high emitters by the new methodology (line (g) in the table below) and the capabilities of 
identifying high emitters by the currently used methods (line (f) in the table below). Therefore, the 
percentage of high emitters identified in PMC3 is calculated based on the table below, as: (h) x (e) x 
((c) + (i) x (d)), where the letters stand for the labels of the lines in the table. 

To obtain the reduction in high emitters relative to the baseline for the MSs affected (line (j) in the 
table  below),  the  percentage  of  high  emitters  identified  in  PMC3  is  divided  by  the  share  of  high 
emitters in the baseline fleet (b).  

The table below summarises, as example, the steps followed to calculate the expected reduction in 
high emitters in the M1 diesel Euro 5 fleet brought by implementing PMC3. 

425 Related to this a recent analysis by the UK government on the possible impact of a one year extension of the initial 
inspection, estimated a possible increase in PTI failure in terms of emissions at 1 to 4.6%.   
426 Giechaskiel, B., et al., (2022), Effect of tampering on on-road and off-road diesel vehicle emissions. Sustainability, 
14(10), p. 6065. 
427 DIAS (2022), D6.5 Impact assessment and guidelines for future anti-tampering regulations. 

217 

 
 
Table 218: Steps followed to estimate the impact of PMC3 on the M1 diesel Euro 5 fleet by age group relative to 
the baseline  

Label 

Calculation/ Assumption 

Vehicle category 

MS affected  

Age group 

M1 diesel Euro 5 

All MSs except for NL, DE, BE 

0-4 

5-9 

10-14 

15-19 

Share of vehicle fleet in 
measure scope (per age group) 

Share of high emitters in the 
fleet in the baseline 

Share of fleet with defective 
emissions control systems 

Share of fleet with tampered 
emission control systems  

% of vehicles that undergo PTI 
checks per year (per age group) 

Accuracy of current PTI 
emission test at identifying 
tampered/defective emission 
control systems 

PTI capacity to identify faulty 
vehicles (% of total) 

Change in detection accuracy 
due to the introduction of PN 
PTI testing 

Share of tampered vehicles 
identified at PTI 

% reduction in the level of 
high emitters relative to the 
baseline for MS affected 

% reduction in the level of 
high emitters - total EU fleet 

% of high emitters in the fleet 
following the implementation 
of the measure 

65% 

67% 

92% 

97% 

(a) 

PRIMES-TREMOVE 
baseline 

2.5% 

5.0% 

7.5% 

10% 

(b) 

See section on the baseline 

1.25% 

2.50% 

3.75% 

5.00% 

(c) 

1.25% 

2.50% 

3.75% 

5.00% 

(d) 

50% x (b) 

50% x (b) 

24% 

65% 

79% 

80% 

(e) 

3.6% 

3.6% 

3.6% 

3.6% 

(f) 

95% 

95% 

95% 

95% 

(g) 

91.4% 

91.4% 

91.4% 

91.4% 

(h) 

10% 

10% 

10% 

10% 

12% 

33% 

40% 

40% 

(i) 

(j) 

Estimation based on the MSs 
frequencies for PTIs 

The same level of accuracy 
is assumed as for the current 
NOx test (Boveroux & al, 
2021) 

Assumption 

(h) = (g) - (f) 

Assumption 

(j)= (h) x (e) x ((c) + (i) x 
(d))/(b) 

8% 

22% 

37% 

38% 

(k) 

(k) = (j) x (a) 

2.2% 

3.4% 

4.5% 

6% 

(l) 

(l) = (b) - (j) x (b) 

Source: Ricardo et al. (2024), Impact assessment support study 

For HDVs, PMC3 envisages to use the new PN measuring methodology at RSI as well (in addition 
to PTI). The table below presents first the methodology for assessing the impacts on emissions due 
to PTI for HDVs, which is similar to the one for M1 vehicles explained above. The second part of 
the table presents the methodology for assessing the impacts on emissions due to RSI.  

Roadside  inspections  have  the  capability  of  identifying  both  defective  and  tampered  emission 
systems. Therefore, no factor is used representing the limited capacity to capture tampering (as in the 
case of PTI). It is reasonable to expect that the combination of PN checks at both roadside and PTI 
will also have some deterrent effect on tampering, but this is not possible to quantify.  

The proportion of high emitting HDVs identified at RSI will be proportional to the percentage of 
vehicles that undergo RSI checks (assumed at 5%), to the capacity of portable PN measuring devices 

218 

 
 
 
 
 
 
 
 
 
to identify faulty vehicles (assumed 95% as for measurements at PTI), and to the share of fleet with 
defective/tampered emissions control systems. Furthermore, the effectiveness  factor reflecting the 
targeted nature of RSI is used in the calculations.  

The proportion of identified high emitting HDVs at RSI due to PMC3, based on the table below, is 
given by the product (k) x (l) x (m) x (b), where the letters stand for the labels of the lines in the table. 
The reduction in high emitters relative to the baseline is provided in line (n) in the table below. 

The combined impact of PN checks at both PTI and RSI on HDVs is estimated as the sum of the 
impacts of the PTI and RIS inspections minus their product and is provided in line (o) of the table 
below.  

The table below summarises, as example, the steps followed to estimate the reduction in high emitters 
in the HDVs Euro VI fleet due to PMC3, relative to the baseline. 

Table 219: Steps followed to estimate the impact of PMC3 on HDVs Euro VI fleet by age group  

Label 

Calculation/ 
Assumption 

Vehicle category 

N2/N3/M2/M3 Euro VI 

MS affected  

Age group 

Share of vehicle fleet in 
measure scope (per age group) 

Share of high emitters in the 
fleet in the baseline 

Share of fleet with defective 
emissions control system 

Share of fleet with tampered 
emission control system  

% of vehicles that undergo 
PTI checks per year (per age 
group) 

Accuracy of current PTI 
emission test at identifying 
tampered/defective emission 
control systems 

PTI capacity to identify faulty 
vehicles (% of total) 

Change in detection accuracy 
due to introduction of PN-PTI 
testing 

Share of tampered vehicles 
identified at PTI 

% reduction in the level of 
high emitters from baseline 
for MS affected (PTI only) 

 PTI checks: all MSs except NL, DE, BE 
RSI checks: all MSs 

0-4 

85% 

5-9 

88% 

10-14 

15-19 

95% 

97% 

(a) 

7.2% 

8.8% 

10.4% 

12.0% 

(b) 

3.6% 

4.4% 

5.2% 

6.0% 

3.6% 

4.4% 

5.2% 

6.0% 

100% 

100% 

100% 

100% 

(c) 

(d) 

(e) 

3.6% 

3.6% 

3.6% 

3.6% 

(f) 

95% 

95% 

95% 

95% 

(g) 

PRIMES-TREMOVE 
baseline 

See baseline section 

50% x (b) 

50% x (b) 

Estimation based on 
the MSs frequencies 
for PTIs 

The same level of 
accuracy is assumed 
as for the current 
NOx test (Boveroux 
& al, 2021) 
Assumption 

91.4% 

91.4% 

91.4% 

91.4% 

(h) 

(h) = (g) – (f) 

10% 

10% 

10% 

10% 

50% 

50% 

50% 

50% 

(i) 

(j) 

Assumption 

(j) = (h) x (e) x ((c) + 
(i) x (d))/(b) 

219 

 
 
 
 
 
 
 
 
 
 
 
 
Vehicle category 

N2/N3/M2/M3 Euro VI 

Label 

Calculation/ 
Assumption 

RSI effectiveness factor 

3 

3 

3 

3 

MS affected  

Age group 

% reduction in the level of 
high emitters from baseline - 
EU fleet (PTI only) 

Share of fleet checked at RSI 

PN portable equipment 
effectiveness at RSI 

% reduction in high emitters 
(RSI only) 

% reduction in high emitters 
from baseline (RSI only) - 
EU fleet  

% reduction in level of high 
emitters (combination RSI 
and PTI)  

% reduction in the level of 
high emitters in EU fleet 
(combination RSI and PTI) 

% of high emitters in the 
fleet following the 
implementation of the 
measure 

5-9 

10-14 

15-19 

44% 

48% 

49% 

(k) 

(k) = (j) x (a) 

 PTI checks: all MSs except NL, DE, BE 
RSI checks: all MSs 

0-4 

43% 

5% 

95% 

5% 

95% 

5% 

95% 

5% 

95% 

14% 

14% 

14% 

14% 

12% 

13% 

14% 

14% 

(l) 

(m) 

(n) 

(o) 

(p) 

Assumption 

Assumption 

Assumption 

(o) = (l) x (m) x (n) x 
(b) / (b)  

(p) = (o) x (a)  

(q) = (j) + (o) – (j) x 
(o)  

57% 

57% 

57% 

57% 

(q) 

49% 

51% 

54% 

56% 

(r) 

(r) = (q) x (a)  

3.7% 

4.3% 

4.7% 

5.3% 

(s) 

(s) = (b) – (r) x (b)  

Source: Ricardo et al. (2024), Impact assessment support study 

The tables below summarise the estimated reduction, relative to the baseline, in the share of high 
emitters due to checks at PTI for LDVs and at PTI and RSI for HDVs (defined as the percentage of 
high emitters identified divided by the baseline share of high emitters). The estimates are presented 
for diesel vehicles only, as the PN measurement method is still under development for petrol vehicles.  

Table 220: Reduction in the share of PN high emitters for M1 and N1 diesel vehicles (all Euro standards) by age 
group relative to the baseline  

Age group 
(years) 

Reduction in high emitters 
relative to the baseline M1 
and N1 

Reduction in high emitters in 
EU fleet 

Reduction in high emitters in 
EU fleet 

M1 diesel 

N1 diesel 

0-4 

5-9 

10-14 

15-19 

12% 

33% 

40% 

40% 

8% 

22% 

37% 

38% 

Source: Ricardo et al. (2024), Impact assessment support study 

220 

9% 

24% 

33% 

36% 

 
 
 
 
 
 
 
 
 
 
 
 
Table 221: Reduction in the share of PN high emitters due to PTI only, RSI only, and their combined impact on 
N2/N3/M2/M3 vehicles (all Euro standards) by age group relative to the baseline 

Age 
group 
(years) 

Reduction in 
high emitters 
from baseline 
(PTI only) 

Reduction in 
high emitters 
in EU fleet 

(PTI only) 

Reduction in 
high emitters 
from baseline 
(RSI only) 

Reduction in 
high emitters 
in EU fleet 

(RSI only) 

Reduction in 
high 
emitters 
from 
baseline 
(PTI + RSI) 

Reduction in 
high emitters 
in EU fleet 

(PTI + RSI) 

0-4 

5-9 

10-14 

15-19 

50% 

50% 

50% 

50% 

43% 

44% 

48% 

49% 

14% 

14% 

14% 

14% 

12% 

13% 

14% 

14% 

57% 

57% 

57% 

57% 

49% 

51% 

54% 

56% 

Source: Ricardo et al. (2024), Impact assessment support study 

4.2.5.  PMC4  –  Mandatory  NOx-testing  of  LDV  and  HDV  at  PTI,  and  HDVs  at  roadside 

inspections  

This  measure is  similar  to  PMC3 but  applies NOx testing.  PMC4 will introduce mandatory  NOx 
emission testing during PTI for LDVs and HDVs (from Euro 5b and Euro VI respectively) and at 
RSIs (for HDVs from Euro VI). As a result, the number of defective LDVs  and HDVs with NOx 
emissions over the legal value is expected to decrease. PMC4 is thus expected to have an impact on 
air pollutant emissions. No impact on noise emissions is expected due to PMC4.  

The approach used to estimate the impacts is similar to that for PMC3, described in Section 4.2.4. 

The assumption used for the NOx measuring devices is that the capacity of identifying faulty vehicles 
is 95% for both the equipment used at PTI and at RSI. Similarly to PMC3, it is assumed that only 
10% of the tampered vehicles are identified at PTI. The LDV and HDV fleets of all EU Member 
States are expected to be affected by this measure, as none of the MSs are currently measuring NOx 
emissions. 

For RSI, similarly to PMC3, a factor of 3 is used to represent their effectiveness relative to PTI, to 
take into account that the inspections are usually not random but targeted. 

The tables below summarise the estimated reduction, relative to the baseline, in the share of high 
emitters due to checks at PTI for LDVs and at PTI/RSI for HDVs (defined as the percentage of high 
emitters identified divided by the baseline share of high emitters).  

Table  222:  Reduction  in  the  share  of  NOx  high  emitters  for  M1  and  N1  diesel  and  petrol  vehicles  (all  Euro 
standards) by age group relative to the baseline 

Age group (years) 

Reduction in high emitters relative to the baseline  

0-4 

5-9 

10-14 

Petrol and diesel M1 and N1 

13% 

34% 

41% 

221 

 
Age group (years) 

Reduction in high emitters relative to the baseline  

Petrol and diesel M1 and N1 

15-19 

42% 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 223: Reduction in the share of NOx high emitters due to PTI only, RSI only, and their combined impact on 
N2/N3/M2/M3 vehicles (all Euro standards) by age group relative to the baseline 
Reduction in high emitters 
from baseline (RSI only) 

Reduction in high emitters 
from baseline (PTI only) 

Reduction in high emitters 
from baseline (PTI + RSI) 

Age group 
(years) 

All age groups 

52% 

14% 

59% 

 Source: Ricardo et al. (2024), Impact assessment support study 

4.2.6.  PM1 - RSI for heavy/powerful motorcycles (L category > 125cm3) as alternative measure, 

in the Member States where they are not subject to PTI (i.e., using available opt-out) 

PM1  will  require  that  those  Member  States  (BE,  FI,  IE,  NL,  MT,  PT)428  that  do  not  have  a  PTI 
requirement  for  motorcycles  introduce  roadside  inspections  for  motorcycles  over  125  cc  as  an 
alternative.  The  roadside  inspections  are  expected  to  cover  5%  of  the  number  of  motorcycles 
registered every year. The motorcycle fleet of these Member States represent on average 8.6% of the 
fleet over 2026-2050. Furthermore, as the measure does not cover L3-L7 motorcycles of less than 
125cc, the scope of the measure is also reduced (84.2% of the total L3-L7 on average over 2026-
2050). 

The share of high emitters of air pollution and noise emissions in the baseline is assumed at 8% and 
30%, respectively, based on limited information from the literature and the PTI data analysis (see 
baseline section).  

PM1 is expected to have an impact on air pollutant emissions and noise emissions. Similar to the 
approach used for assessing the impacts on road safety, the failure rate of inspections in detecting 
defective  vehicles  is  assumed  at  5%.  To  reflect  the  enhanced  effectiveness  of  RSI  in  targeting 
defective vehicles compared to PTI, a factor of 3 is used. The proportion of motorcycle undergoing 
roadside inspections (5%) and the share of motorcycles in the scope of the measure is also taken into 
account in the assessment.  

The share of high emitters of air pollutant emissions and noise is estimated to reduce by 12% in the 
MS affected (1% at the EU level) due to PM1, relative to the baseline.  

Table 224: Estimated impact of PM1 on the share of high emitters of air pollutant emissions and noise 

Variable 

MS affected 

Emissions 

Noise 

Label 

Calculation 

FI, NL, MT, PT, BE, IE 

428 Until end 2023, France had not introduced mandatory PTI for motorcycles, but the French authorities had announced 
the intention to do so. For this reason, for the purposes of the analysis it was assumed that France would not be affected 
by the proposed measure. Denmark does not have mandatory PTI but since it has introduced roadside inspections, and it 
is thus assumed to be part of the baseline. In the case of Portugal, current requirements cover only motorcycles over 
250cc.  

222 

 
 
 
 
Variable 

Emissions 

Noise 

Label 

Calculation 

Share of EU fleet affected 

Share of vehicle fleet in measure scope  

Share of fleet inspected in RSI 

RSI effectiveness factor 

8.6% 

84.2% 

5% 

3.0 

Share of high emitters in the fleet in the 
baseline (emissions/noise) 

8% 

30% 

(a) 

(b) 

(c) 

(d) 

(e) 

Share of fleet with defective emissions/noise 
control systems 

4% 

15% 

(f) 

50% x (e) 

(emissions/noise) 

Share of fleet with tampered emission/noise 
control systems (emissions/noise) 

Failure rate of inspections in detecting 
defective vehicles  

% reduction in the share of high emitters 
relative to the baseline in the Member 
States affected (emissions/noise) 

% reduction in the share of high emitters 
relative to the baseline at EU level 
(emissions/noise) 

% of high emitters in the fleet following the 
implementation of the measure 
(emissions/noise) 

4% 

15% 

(g) 

50% x (e) 

5% 

12% 

(h) 

(i) 

(i) = (1 – (h)) x (c) x (d) x 
(b)  

1% 

(j) 

(j) = (i) x (a) 

7% 

26% 

(k) 

(k) = (e) - (e) x (i) 

Source: Ricardo et al. (2024), Impact assessment support study 

4.2.7.  PM2 - Mandatory PTI for motorcycles above 125cm3 (remove current opt-out) 

PM2 introduces mandatory PTI for all motorcycles over 125cm3  (removing opt-out). Besides the 
Member States identified in PM1, Denmark will also need to introduce PTI for motorcycles over 
125cm under PM2. Thus, the Member States affected by PM2 are BE, DK, FI, IE, MT, NL and PT. 

PM2 is expected to have an impact on air pollutant emissions and noise emissions. The impact of 
PM2 is based on the expected effectiveness of PTI for motorcycles to identify high emitters, applying 
the emission measurements and test methods already considered in PMC3 and PMC4. Considering 
the MS affected by PM2, the measure is expected to have an impact on a small share of the EU fleet 
(8.8%)429. Furthermore, as it does not encompass all motorcycle categories (only L3-L7, except L3-
1a), a reduced scope is used to estimate the impacts on the total motorcycle fleet (85.9%)430.  

429 This reflects the average over 2026-2050 based on the PRIMES-TREMOVE baseline.  
430 This reflects the average over 2026-2050 based on the PRIMES-TREMOVE baseline.  

223 

 
 
 
 
 
 
 
 
The share of high emitters of air pollution and noise emissions in the baseline is assumed at 8% and 
30%, respectively, based on limited information from the literature and the PTI data analysis (see 
baseline section).  

Similar  to  the  approach  used  for  assessing  the  impacts  of  PM1,  the  failure  rate  of  inspections  in 
detecting defective vehicles is assumed at 5%. The impact will also depend on the expected frequency 
of the PTI inspections which has been assumed to be the minimum one provided for M1/N1 vehicles 
in the Directive (4/2/2), leading to an average frequency of 0.44 inspections per year431. In addition, 
it is assumed that 10% of the tampered vehicles are identified at PTI. The share of motorcycles in the 
scope of the measure is also taken into account in the assessment.  

The share of high emitters of air pollutant emissions and noise is estimated to reduce by 20% in the 
MS affected (1.7% at the EU level) due to PM2, relative to the baseline.  

Table 225: Estimated impact of PM2 on the share of high emitters of air pollutant emissions and noise  
Calculation 

Emissions 

Variable 

Label 

Noise 

MS affected  

BE, DK, FI, IE, MT, NL, PT 

Share of EU fleet affected 

Share of vehicle fleet in measure scope 

Share  of  high  emitters  in  the fleet  in  the 
baseline (emissions / noise) 

Share  of  fleet  with  defective  emissions 
control systems 

Share  of  fleet  with  tampered  emission 
control systems 

% of vehicles that undergo PTI per year 

PTI capacity to identify tampering (% of 
total) 

Failure  rate  of  inspections  in  detecting 
defective vehicles  

%  reduction  in  the  share  of  high 
emitters  relative  to  the  baseline  in  the 
Member 
affected 
States 
(emissions/noise) 

%  reduction  in  the  share  of  high 
emitters  relative  to the  baseline  at  EU 
level (emissions/noise) 

8% 

4% 

4% 

8.8% 

85.9% 

30% 

(a) 

(b) 

(c) 

15% 

(d) 

50% x (c) 

15% 

(e) 

50% x (c) 

44% 

10% 

5% 

20% 

(f) 

(g) 

(h) 

(i) 

4/2/2 over 18 years (i.e., 8 
inspections) 

(i) = (f) x ((g) x (e) + (d)) x (1 
– (h)) x (b) / (c)  

1.7% 

(j) 

(j) = (i) x (a) 

431 For L vehicle types the average vehicle age is 18 years and the total number of inspections over the lifetime of the 
vehicle is 8 resulting in an annual frequency of 0.44 (=8/18). 

224 

 
 
 
 
 
 
 
 
 
Variable 

Emissions 

Noise 

Label 

Calculation 

% of high emitters in the fleet following 
the  implementation  of  the  measure 
(emissions/noise) 

6.4% 

24% 

(k) 

(k) = (c) - (c) x (i) 

Source: Ricardo et al. (2024), Impact assessment support study 

4.2.8.  PM3  -  Extend  PTI  to  all  motorcycles  (i.e.,  including  from  50cm3  =  all  L3e,  L4e,  plus 

tricycles (L5e) and heavy quadricycles (L7e)) 

PM3 extends the type of motorcycles covered by PTI to those from 50cm3 in the eight Member States 
where such requirement is currently not in place (BE, FI, IE, NL, MT, PT, DK, CY432).  

The approach followed for the assessment is the same as in the case of PM2. The only difference is 
that the extended scope of the measure to cover vehicles over 50cm3 leads to increased share of the 
fleet affected as shown in the table below.  

The share of high emitters of air pollutant emissions and noise is estimated to reduce by 23.2% in the 
MS affected (2.4% at the EU level) due to PM3, relative to the baseline.  

Table 226: Estimated impact of PM3 on the share of high emitters of air pollutant emissions and noise  

Variable 

MS affected 

Emissions 

Noise 

Label 

Calculation 

BE, FI, IE, NL, MT, PT, DK, 
CY 

Share of EU fleet affected 

Share of vehicle fleet in measure scope  

Share of high emitters in the fleet in the 
baseline (emissions/noise) 

Share of fleet with defective emissions 
control systems (emissions/noise) 

Share of fleet with tampered emission control 
systems (emissions/noise)  

% of vehicles that undergo PTI per year 

PTI capacity to identify tampering (% of 
total) 

Failure rate of inspections in detecting 
defective vehicles  

% reduction in the share of high emitters 
relative to the baseline in the Member 
States affected (emissions/noise) 

8% 

4% 

4% 

10.2% 

100% 

30% 

(a) 

(b) 

(c) 

15% 

(d) 

50% x (c) 

15% 

(e) 

50% x (c) 

44% 

10% 

5% 

23.2% 

(f) 

(g) 

(h) 

(i) 

4/2/2 over 18 years 
(i.e., 8 inspections) 

(i) = (f) x ((g) x (e) + 
(d)) x (1 – (h)) x (b) / 
(c)  

432 In Cyprus motorcycles above 125cm3 are already covered.  

225 

 
 
 
 
 
 
 
 
 
Variable 

Emissions 

Noise 

Label 

Calculation 

% reduction in the share of high emitters 
relative to the baseline at EU level 
(emissions/noise) 

% of high emitters in the fleet following the 
implementation of the measure 
(emissions/noise) 

2.4% 

(j) 

(j) = (i) x (a) 

6.1% 

23% 

(k) 

(k) = (c) - (c) x (i) 

Source: Ricardo et al. (2024), Impact assessment support study 

4.2.9.  PM5 - Annual emission testing for light commercial vehicles (N1) instead of the currently 

required 4-2-2 frequency  

PM5 includes a requirement for annual emission testing for light commercial vehicles (N1) instead 
of the currently required 4-2-2 frequency. It assumes additional emission testing in all Member States. 
While certain Member States (e.g. LT and FR) apply yearly (emission) testing from a certain vehicle 
age, this means smoke opacity test or EOBD test that are not considered effective. PM5 is expected 
to have an impact on air pollutant emissions. No impact on noise emissions is expected due to PM5. 

Based on the DIAS study433, it is assumed that 50% of the high emitters are caused by tampering. As 
tampering of vehicles is more difficult to detect, the emission test is assumed to only detect 10% of 
the tampered vehicles. The accuracy of the new PTI emission test at identifying tampered/defective 
emission control systems is assumed at 95%. Taking also into account the share of the age group in 
the vehicle fleet and the percentage increase in the number of inspections, the table below provides 
the calculations and impact on the share of high emitters of air pollutant emissions for the 0-4 age 
group.  

Table 227: Estimated impact of PM5 on the share of high emitters of air pollutant emissions for the 0-4 years age 
group 

Variable 

Share of EU vehicle fleet in measure scope  

Share of age group in N1 fleet 

Percentage increase in inspections across 
EU27 

Percentage of high emitter vehicles which are 
tampered 

PTI capacity to identify tampering (% of 
total) 

Share of vehicles with tampered or defective 
emission systems which are detected 

Accuracy of new PTI emission test at 
identifying tampered/defective emission 
control systems 

Value 

100% 

18.7% 

34% 

50% 

10% 

55% 

95% 

Label 

Calculation 

(a) 

(b) 

(c) 

(d) 

(e) 

(f) 

(g) 

(f) = (d) + (b) x (e)  

433 DIAS (2022), D6.5 Impact assessment and guidelines for future anti-tampering regulations. 

226 

 
 
 
 
 
 
 
 
Variable 

Value 

Label 

Calculation 

% reduction in the share of high emitters 
at the EU level compared to the baseline 

16.93%  

(h) 

(h) = (a) x (c) x (g) x (f)  

Source: Ricardo et al. (2024), Impact assessment support study 

The percentage reductions in the shares of high emitters across the EU for four age groups of the N1 
vehicle category are shown in the table below. The differences between age groups are due to the 
additional number of inspections relative to the baseline and the share of each age group in the N1 
vehicle fleet.  

Table 228: Estimated reduction of the share of high emitters of air pollutant emissions for N1 vehicles, by age 
group 

Variable 

Age group 

Vehicle age group (years) 

0-4 

5-9 

10-14 

15-19 

% reduction in the share of high emitters in the fleet at EU 
level compared to the baseline 

16.93% 

16.13% 

1.89% 

1.88% 

Source: Ricardo et al. (2024), Impact assessment support study 

4.2.10.  PM6 - Mandatory yearly testing for vehicles that are 10-year-old or older  

Currently,  11  MS  do  not  require  annual  PTI  testing  of  light-duty  vehicles  after  10  years  of  their 
registration (CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT, SK). All these Member States currently 
require an inspection every two years which means that the proposed measure will double the number 
of  inspections  for  vehicles  over  10  years.  PM6  is  expected  to  have  an  impact  on  air  pollutant 
emissions. No impact on noise emissions is expected due to PM6. 

Based on the DIAS study434, it is assumed that 50% of the high emitters are caused by tampering. As 
tampering of vehicles is more difficult to detect, the emission test is assumed to only detect 10% of 
the tampered vehicles. The accuracy of the new PTI emission test at identifying tampered/defective 
emission  control  systems  is  assumed  at  95%.  The  reduction  in  the  share  of  high  emitters  in  the 
affected MS is calculated by also taking into account the increase in the number of inspections for 
the N1 and M1 vehicle categories relative to the baseline. To calculate the percentage reduction in 
the share of high emitters in the fleet at EU level compared to baseline, the share of EU fleet affected 
is further taken into account.  

The calculation approach for the 10-14 years age group of M1 and N1 vehicles is provided in the 
table below. 

Table 229: Estimated impact of PM6 on the share of M1 and N1 high emitters of air pollutant emissions for the 
10-14 years age group 

Variable 

M1 values (a) 

N1 values (b) 

Label 

Calculation 

MS affected by measure 

CY, DE, LT, CZ, 
DK, FR, EL, HU, 
IT, MT, SK 

CY, DE, LT, 
CZ, DK, FR, 
EL, HU, IT, 
MT, SK 

(a) 

434 DIAS (2022), D6.5 Impact assessment and guidelines for future anti-tampering regulations. 

227 

 
 
 
Variable 

M1 values (a) 

N1 values (b) 

Label 

Calculation 

Share of EU fleet affected 

%  increase  in  the  number  of 
inspections 
the 
baseline 

relative 

to 

Percentage  of  high  emitter 
vehicles which are tampered 

47% 

33% 

50% 

PTI 
to 
capacity 
tampering (% of total) 

identify 

10% 

Share of vehicles with tampered 
or  defective  emission  systems 
which are detected 

55% 

49% 

26% 

50% 

10% 

55% 

(b) 

(c) 

(d) 

(e) 

(f) 

(f) = (d) + (b) x (e)  

Accuracy  of  new  PTI  emission 
identifying 
test 
tampered/defective 
emission 
control systems 

at 

% reduction in the share of 
high emitters in the fleet in the 
MS affected compared to 
baseline 

% reduction in the share of 
high emitters in the fleet at 
EU level compared to baseline 

95% 

95% 

(g) 

17.24% 

13.59% 

(h) 

(h) = (c) x (f) x (g) 

8.08% 

6.64% 

(i) 

(i) = (h) x (b) 

Source: Ricardo et al. (2024), Impact assessment support study 

It is assumed that the vehicles older than 10 years are evenly distributed between the 10-14 years and 
15-19 years age groups. This is also the case of the increase in the number of inspections relative to 
the baseline. Therefore, the percentage reductions in the shares of N1 and M1 high emitters (line (f) 
in the table above) are the same for the 10-14 years and 15-19 years age groups. 

4.2.11.  PM10 - More advanced testing of noise for motorcycles 

PM10 requires that all Member States perform noise testing for motorcycles at PTI, inspired by the 
procedure for pass-by noise test described in the UN Regulation no. 41. Four MSs (DE, ES, HR, SK) 
currently  require  testing  of  noise  for  L-category  vehicles  at  PTI.  Even  though  the  stringency  and 
effectiveness of current testing methods in these MS may be lower than the noise testing methods 
proposed  in  UN  Regulation  41  for  pass-by  noise  tests,  they  represent  a  significant  improvement 
compared to the subjective assessment by the inspector, which is required by the PTI Directive. PM10 
is expected to have an impact on noise emissions. 

The measure is  expected to  affect  72% of the L3-7 vehicle fleet  across the EU. The share of the 
vehicle fleet which will be subject to the new advanced noise test each year is calculated by assuming 
a standard PTI frequency for L-category vehicles of 4-2-2 and an average vehicle life of 18 years. In 
addition, it is assumed that 50% of the high noise-emitting motorcycles are caused by tampering and 
50% by defective noise control systems. As tampering of vehicles is more difficult to detect during 
PTI, the advanced noise test is assumed to only detect 10% of tampered vehicles during PTI.  

228 

 
 
 
 
 
 
The introduction of advanced noise testing for motorcycles is expected to reduce the share of high 
emitter L vehicles by 22% in the MS affected, relative to the baseline. The approach for calculating 
the reduction in the share of high emitter vehicles is provided in the table below.  

Table 230: Estimated impact of PM10 on the share of noise high-emitter L vehicles in the fleet 
Calculation 

Variable 

Values 

Label 

Share of vehicle fleet in measure scope 

72% 

(a) 

All MSs except for DE, ES, 
HR, SK 

Share of high emitters in the fleet in the baseline 

Percentage of high emitter vehicles which are tampered 

Proportion of high emitter vehicles due to defective 
systems 

PTI capacity to identify tampering (% of total) 

Share of fleet inspected annually 

Noise test effectiveness 

Tampered vehicles identified at PTI 

Defective vehicles identified at PTI 

% reduction in the share of high emitter vehicles in 
the fleet in the MS affected  

30% 

50% 

50% 

10% 

44% 

90% 

0.6% 

6.0% 

22.0% 

(b) 

(c) 

(d) 

(e) 

(f) 

(g) 

(h) 

(i) 

(j) 

Estimate based on 4-2-2 PTI 
frequency 

(h) = (b) x (c) x (e) x (f) x (g) 

(i) = (b) x (d) x (f) x (g) 

(j) = ((h) + (i))/(b) 

% of high emitters in the fleet following the 
implementation of the measure 

23.4% 

(k) 

(k) = (b) – (b) x (j) 

Source: Ricardo et al. (2024), Impact assessment support study 

4.2.12.  PM12 – NOx, PM, and noise measurement by remote sensing in RSI of all vehicles (with 

option for simplified PTI if vehicle passed recent RSI)  

PM12 requires NOx and PM measurement by remote sensing in technical roadside inspections of all 
vehicle types, and optional plume chasing in technical roadside inspections of commercial vehicles. 
In addition, acoustic cameras would need to be added to remote sensing equipment to measure noise 
at the roadside. Thus, it is expected that PM12 will decrease the number of LDVs and HDVs with 
tampered/faulty emission system leading to high exhaust of NOx and particle emissions, and also 
decrease  the  number  of  M1,  N1  vehicles  and  motorcycles  with  tampered/faulty  exhaust  system 
leading to high noise emissions. 

NOx and PN high emitter light duty and heavy duty vehicles 

The potential reduction in high emitter vehicles depends on: 

•  the effectiveness of remote sensing (RS), which is intrinsically penalised by the short time scale 
during which a measurement takes place, and by the possible contamination of the plume by near 
vehicles, is assumed at 70% (line (c) in the table below). The effectiveness of plume chasing is 
assumed to be 95% as for the RSI measurements (line (h) in the table below); 

229 

 
 
 
 
 
 
•  the proportion of false positives (that is, vehicles wrongly identified as high emitters by remote 

sensing and plume chasing) is assumed at 5% (line (e) in the table below); 

•  the capacity of identifying NOx and PN high emitters at RSI is assumed to be 95% (line (d) in the 

table below);  

•  the target proportion of the fleet analysed by remote sensing is assumed to be 30% (line (f) in the 

table below); 

•  the targeted proportion of the HDVs fleet analysed by plume chasing is assumed to be 3% (line 

(i) in the table below); and 

•  the  capacity  of  RSI,  that  is,  the  highest  proportion  of  the  whole  LDV  and  HDV  fleets  that  is 

feasible to check through RSI is assumed to be 0.5% (line (b) in the table below). 

The table below summarises the steps followed to estimate the impact of PM12 on the share of NOx 
high emitters Euro VI HDVs relative to the baseline.  

Remote sensing and plume chasing are used as a filtering tool for a better targeted RSI. The high 
emitters flagged as high emitters, which contain both real high emitters and false positives, are sent 
either to RSI (line (m) in the table below) or, in case the number of vehicles is too high compared to 
the capacity of RSI, to a testing centre (PTI station) to be double checked.  

The proportion of vehicles flagged as high emitters will be proportional to the percentage of the fleet 
analysed, the remote sensing and plume chasing435 effectiveness and the share of high emitters in the 
fleet.  

In the case of HDVs, the option of plume chasing is added: it is possible to find high emitting HDVs 
(line (k)) proportionally to the share of fleet measured via plume chasing (line (i)), and the plume 
chasing capacity of identifying faulty vehicles (line (h)). For LDVs this additional share of identified 
high emitters by plume chasing does not exist.  

All vehicles flagged as potential high emitters by remote sensing and plume chasing will be sent to 
RSI up to the RSI capacity of 0.5% of the fleet (b). 

The proportion of the real high emitters identified at RSI (line (n) in the table below) will be the 
product of the percentage of the fleet correctly identified as high emitter by RS and the effectiveness 
of the test, that is: (n) = (m) x (d).  

The share of vehicles identified by remote sensing as high emitters – including possible false positives 
- that are not checked via RSI due to capacity limitations are to be sent to a PTI station for further 
testing (o). This is multiplied by (1-(e)) to take into account the percentage of false positives (line (p) 
in the table below), that is vehicles that are flagged as high emitters by remote sensing but that at a 
second check are found emitting within the legal limit.  

Of these vehicles, as in PMC4 (section 4.2.5) it is expected that half (50%) will be tampered and 50% 
faulty. PTI is assumed to only be able to capture 10% of tampered vehicles as a large part of them 
will be set to the pre-tampering stated before the inspection, while faulty ones will be captured with 
an effectiveness of 95%. The high emitting vehicles captured at the PTI (line (u) in the table below) 
are the combination of the tampered vehicles identified and the faulty vehicles identified.  

435 Relevant only for HDVs. 

230 

 
 
The total high emitters identified are the sum of those captured by RSI and at PTI stations following 
their screening by remote sensing and plume chasing – in the case of HDVs only (line (v) in the table 
below). The percentage reduction in the share of high emitters, defined as the percentage of total high 
emitters identified divided by the baseline share of high emitters is provided in line (z) of the table 
below. 

Table 231: Estimated impact of PM12 on the share of high emitters Euro VI HDVs, by age group, at EU level 
(relative to the baseline) 

Label 

Calculation/ Assumption 

Vehicle category 

MS affected  

Age group 

Share of vehicle fleet in measure 
scope (per age group) 

Share of high emitters in the fleet 
in the baseline 

Maximum RSI capacity (% of 
whole fleet) 

Remote sensing (RS) capacity to 
identify faulty vehicles (% of high 
emitters correctly identified by RS) 

% high emitters correctly 
identifiable by NOx/PN RSI test  

Remote sensing and plume chasing 
false positives (% of the vehicles 
flagged as high emitters which are 
not real high emitters) 

Proportion of the fleet analysed by 
remote sensing  

Proportion of the fleet identified 
as high emitter by RS 

Plume chasing capacity to identify 
faulty vehicles 

Share of fleet measured via plume 
chasing 

Share of fleet identified as high 
emitters by plume chasing  

Total share of fleet identified as 
high emitters by remote sensing 
and plume chasing 

N2/N3/M2/M3 Euro VI 

All MSs 

0-4 

5-9 

10-14 

15-19 

100% 

100% 

100% 

100% 

7.2% 

8.8% 

10.4% 

12.0% 

(a) 

See the baseline section 

0.5% 

0.5% 

0.5% 

0.5% 

(b) 

70% 

70% 

70% 

70% 

(c) 

95% 

95% 

95% 

95% 

(d) 

5% 

5% 

5% 

5% 

(e) 

Assumption 

Assumption 

Assumption 

Assumption 

30% 

30% 

30% 

30% 

(f) 

Assumption  

1.51% 

1.85% 

2.18% 

2.52% 

(g) 

(g) = (f) x (c) x (a) 

95% 

95% 

95% 

95% 

(h) 

3% 

3% 

3% 

3% 

(i) 

Assumption 

Assumption 

0.21% 

0.25% 

0.30% 

0.34% 

(k) 

(k) = (h) x (i) x (a) 

1.72% 

2.10% 

2.48% 

2.86% 

(l) 

(l) = (k) + (g) 

Sent to RSI (pre-selected by RS) 

0.5% 

0.5% 

0.5% 

0.5% 

(m) 

if (l) <= (b), (m) =(l); otherwise 
(m) = (b) 

Proportion of the real high 
emitters identified by RSI  

Vehicles sent to PTI stations: 
vehicles flagged as high emitters 
by remote sensing and plume 
chasing but not inspected at RSI 

Vehicles sent to PTI stations 
which are actually high emitters 

Share of high emitters that are 
tampered 

0.48% 

0.48% 

0.48% 

0.48% 

(n) 

(n) = (m) x (d) 

1.22% 

1.60% 

1.98% 

2.36% 

(o) 

(o) = (l) – (m) 

1.16% 

1.52% 

1.88% 

2.24% 

(p) 

(p) = (o) x (1- (e)) 

50% 

50% 

50% 

50% 

(q) 

Assumption 

231 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Vehicle category 

MS affected  

Age group 

N2/N3/M2/M3 Euro VI 

All MSs 

0-4 

5-9 

10-14 

15-19 

Label 

Calculation/ Assumption 

0.58% 

0.76% 

0.94% 

1.12% 

(r) 

(r) = (p) x (q) 

Vehicles sent to PTI stations 
which are high emitters because 
they are tampered  

PTI capacity to identify tampered 
vehicles  

NOx/PN -PTI test effectiveness 

95% 

95% 

95% 

95% 

10% 

10% 

10% 

10% 

(s) 

(t) 

Assumption 

Assumption 

High emitters identified at PTI 
stations 

Total high emitters identified at 
PTI stations and RSI 

% reduction in the share of high 
emitters (RS + RSI) relative to 
the baseline 

0.61% 

0.80% 

0.99% 

1.18% 

(u) 

(u) = (r) x (s)+(1-(r)) x (t) 

1.08% 

1.27% 

1.46% 

1.65% 

(v) 

(v) = (u) + (n) 

15.03% 

14.46% 

14.06% 

13.78% 

(z) 

(z) = (v) / (a) 

Source: Ricardo et al. (2024), Impact assessment support study 

Noise emissions from N1, M1, and L-vehicles 

Acoustic cameras can be installed before a RSI site to optimise the detection rates of N1, M1, and L-
vehicles emitting noise over the legal limit. Coupling with a PTI is a possibility; however, this is not 
expected  to  be  particularly  effective  in  all  cases  of  tampered  vehicles,  as  for  motorcycles,  for 
example, altering some parts of the exhaust system and reinstating their original settings is relatively 
easy (for instance, removing/re-installing the muffler). 

The proportion of the fleet that is high emitters and is identifiable at RSI (line (e) in the table below) 
is derived as the product of the share of high emitters in the fleet in the baseline (line (a) in the table 
below), the remote sensing capacity of identifying faulty vehicles (line (d) in the table below), and 
the  RSI  noise  test  effectiveness  (line  (c)  in  the  table  below).  The  effectiveness  assumed  for  the 
measurements at roadside is lower than the one assumed at PTI, to reflect the challenge of measuring 
in  a  noisy  environment.  The  acoustic  camera  effectiveness  is  considered  higher  than  noise 
measurements at roadside because it is the result of more than one measurement. 

As only a portion (line (f) in the table below) of the fleet will be analysed by the acoustic cameras, 
the proportion of the fleet that is high emitters and is identifiable at RSI (line (g)) is derived as: (g) = 
(f) x (e), where the letters stand for the labels of the rows in the table below. However, the maximum 
percentage of noise high emitters eventually identified (line (h)) is limited by the RSI capacity (line 
(b)).  

The table below summarises the steps and assumptions used to estimate the percentage reduction in 
the share of M1, N1, and L noise high emitting vehicles.  

232 

 
 
 
 
 
 
 
 
 
 
 
 
Table 232: Estimated impact of PM12 on the share of noise high emitters for N1, M1 vehicles, and motorcycles 
relative to the baseline  

Label  Calculation/ Assumption 

Vehicle category 

N1 

L3-L7 

M1 

MSs affected 

All MSs  All MSs 

All 
MSs 

Share of vehicle fleet in measure scope 

Share of high emitters in the fleet in the 
baseline 

Share of fleet selected via remote 
sensing and sent to RSI (i.e., maximum 
RSI capacity) 

Noise test effectiveness 

Remote sensing capacity to identify 
faulty vehicles (% of total) 

Proportion of the fleet that is high 
emitters and is identified at RSI if 100% 
inspected of the fleet is analysed via RS 
and inspected at RSI 

Proportion of the fleet analysed by RS 

Proportion of the fleet that is high 
emitters and is identifiable at RSI 

High emitters identified at RSI with 
limited RSI capacity (RS+RSI) 

% reduction in the share of high 
emitters (remote sensing + RSI) 

100% 

100% 

100% 

4% 

30% 

4% 

(a) 

See the baseline section 

0.5% 

5.0% 

0.5% 

(b) 

Assumption 

80% 

80% 

80% 

(c) 

Assumption 

70% 

70% 

70% 

(d) 

Assumption 

2.2% 

16.8% 

2.2% 

(e) 

(e) = (d) x (c) x (a) 

30% 

30% 

30% 

(f) 

Assumption 

0.7% 

5.0% 

0.7% 

(g) 

(g =(f) x (e) 

0.5% 

5.0% 

0.5% 

(h) 

If (g) <= (b) then (h) = (g); 

Otherwise (h) = (b) 

12.5% 

16.7% 

12.5% 

(i) 

(i) = (h) / (a) 

Source: Ricardo et al. (2024), Impact assessment support study 

4.2.13.  PM14 - Extend the scope of application of roadside inspections to light commercial (N1) 

vehicles 

PM14 extends the scope of application of roadside inspections to N1 vehicles, and sets 2% as target 
for the share of inspections of the N1 vehicle fleet. The introduction of roadside inspections of N1 
category vehicles can contribute further to the identification of vehicles with defective or tampered 
emissions/noise  control  systems.  To  the  extent  that  these  roadside  inspections  are  expected  to  be 
targeted (as is currently the case in most Member States), this can be a particularly effective measure 
in removing defective vehicles. PM14 is expected to have an impact on both air pollutant and noise 
emissions. 

On  the  basis  of  the  information  available,  few  Member  States  (ES,  HU,  SE,  SK  and  FI)  already 
conduct roadside inspections for N1 vehicles, although without a certain target set and thus checking 
a low number of vehicles. For the purposes of the assessment it is assumed that these Member States 
will not be affected. The N1 vehicles fleet of the 22 Member States affected represent around 77% 
of the N1 vehicles fleet in the EU. 

233 

 
 
 
 
 
 
 
 
 
Depending on the age, Euro standard and fuel type, the share of air pollutant high emitter N1 vehicles 
ranges between 4% and 20% in the baseline. The share of noise high emitter N1 vehicles is estimated 
at 4% in the baseline. Of these, half are assumed to be tampered and half defective.  

The RSI inspections would cover 2% of the N1 vehicle fleet annually in PM14. Due to the enhanced 
effectiveness as a result of the targeted nature of RSIs, the number of high emitters identified will, 
on  average,  be  three  times  higher  than  if  the  inspections  were  completely  random.  Similar  to  the 
approach for assessing  the impact  on road safety,  it is  assumed that the effectiveness of  roadside 
inspections in detecting high emitters is 95%. 

PM14 is estimated to reduce by 5.7% the share of high emitter vehicles in the Member States affected 
relative to the baseline (4.4% at EU level).  

Table 233: Estimated impact of PM14 on the share of high emitters of air pollutant emissions and noise  

Emissions 

Noise 

Label 

Calculation 

Share of EU fleet affected 

77% 

Share of high emitters in the fleet in 
the baseline 

4%-20% depending 
on age, Euro standard 
and fuel type 

4% 

2% 

2% 

(a) 

(b) 

(c) 

(d) 

(e) 

(f) 

(g) 

(h) 

(c) = 50% x (b) 

(c) = 50% x (b) 

(h) = (e) x (f) x ((c) + 
(d)) x (1-(g)) / (b) 

2%-20% 

2%-20% 

2% 

3 

5% 

5.7% 

4.4% 

(i) 

(i) = (h) x (a) 

Share of fleet with defective 
emissions control system 

Share of fleet with tampered 
emission control system 

RSI fleet target 

Parameter reflecting RSI enhanced 
capacity to identify defective 
vehicles 

Failure rate of inspections in 
detecting defective vehicles  

% reduction in the share of high 
emitter vehicles (emissions/noise) 
in the MS affected, relative to the 
baseline 

% reduction in the share of high 
emitter vehicles at EU level 
relative to the baseline 

Source: Ricardo et al. (2024), Impact assessment support study 

4.2.14.  PM15 – Extend the scope of application of roadside inspections to 2- and 3-wheeled vehicles 

(L-vehicles from L3) 

PM15  extends  the  scope  of  application  of  roadside  inspections  to  2-  and  3-wheeled  vehicles  (L-
vehicles from L3) and establishes a threshold of 1% of the vehicle fleet for roadside inspections. Few 
Member States (SE, SI, AT, FI, DK, HU, RO) already perform such inspections although they do not 
report the exact number of inspections of motorcycles separately and do not indicate a specific target. 
In the absence of more specific data it is assumed that these Member States will not be affected by 

234 

 
 
 
 
 
 
 
PM15. The L-category vehicle fleet of the 20 Member States affected is estimated to represent on 
average 92% of the L-category vehicle EU fleet over 2026-2050436. PM15 is expected to have an 
impact on air pollutant emissions and noise emissions. 

The share of high emitters of air pollution and noise emissions in the baseline is assumed at 8% and 
30%, respectively, based on limited information from the literature and the PTI data analysis (see 
baseline section).  

Similar to the approach used for assessing the impacts on road safety, the failure rate of inspections 
in  detecting defective vehicles is  assumed at  5%. To reflect  the enhanced effectiveness  of RSI in 
targeting defective vehicles compared to PTI, a factor of 3 is used. 

PM15 is estimated to reduce by 2.9% the share of high emitter vehicles in the Member States affected 
relative to the baseline (2.6% at EU level).  

Table 234: Estimated impact of PM15 on the share of high emitters of air pollutant emissions and noise  

Emissions 

Noise 

Label 

Calculation 

Share of EU fleet affected 

92% 

Share of high emitters in the fleet in 
the baseline 

Share of fleet with defective 
emissions control system 

Share of fleet with tampered 
emission control system 

Share of fleet checked in RSI 

Parameter reflecting RSI enhanced 
capacity to identify defective 
vehicles 

Failure rate of inspections in 
detecting defective vehicles  

% reduction in the share of high 
emitter vehicles (emissions/noise) 
in the MS affected, relative to the 
baseline 

% reduction in the share of high 
emitter vehicles at EU level 
relative to the baseline 

8% 

4% 

4% 

30% 

15% 

15% 

1% 

3 

5% 

2.9% 

(a) 

(b) 

(c) 

(d) 

(e) 

(f) 

(g) 

(h) 

(c) = 50% x (b) 

(c) = 50% x (b) 

(h) = (e) x (f) x ((c) + 
(d)) x (1-(g)) / (b) 

2.6% 

(i) 

(i) = (h) x (a) 

Source: Ricardo et al. (2024), Impact assessment support study 

436 The share is calculated based on the PRIMES-TREMOVE baseline projections.  

235 

 
 
 
 
 
 
 
 
4.2.15.  Impacts on air pollutant emissions and noise emissions by policy option  

Air pollutant emissions 

On the basis of the analysis of the impacts of each individual measure, the combined impact of the 
measures for each policy option is estimated using the common residual method explained above. 
The tables below summarise the expected reduction in the share of high emitter vehicles relative to 
the  baseline,  by  vehicle  category,  Euro  standard  and  fuel  type  at  EU  level.  They  are  provided 
separately  for  NOx  and  PN  high  emitter  vehicles.  These  are  used  as  inputs  in  the  PRIMES-
TREMOVE model to derive the reduction in  the air pollution emissions and external  costs of  air 
pollution emissions relative to the baseline.  

Table 235: Reduction in the share of NOx high emitter vehicles by policy option relative to the baseline 

Vehicle category 

Euro 
standard 

Fuel 

Age group 

PO1a 

PO1b 

PO2  

PO3  

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

236 

12.0% 

32.1% 

42.6% 

43.0% 

12.0% 

32.1% 

42.6% 

43.0% 

12.0% 

32.1% 

42.6% 

43.0% 

12.0% 

32.1% 

42.6% 

43.0% 

12.0% 

32.1% 

42.6% 

43.0% 

12.0% 

32.1% 

42.6% 

43.0% 

12.0% 

32.1% 

42.6% 

43.0% 

12.0% 

32.1% 

42.6% 

43.0% 

29.2% 

42.3% 

54.3% 

54.2% 

26.9% 

41.6% 

54.0% 

54.0% 

29.2% 

42.3% 

54.3% 

54.2% 

27.2% 

41.6% 

54.0% 

54.0% 

29.6% 

44.3% 

55.4% 

55.4% 

29.6% 

43.9% 

55.2% 

54.9% 

37.4% 

50.5% 

53.9% 

54.0% 

36.7% 

50.2% 

53.7% 

53.8% 

29.2% 

42.3% 

54.3% 

54.2% 

26.9% 

41.6% 

54.0% 

54.0% 

29.2% 

42.3% 

54.3% 

54.2% 

27.2% 

41.6% 

54.0% 

54.0% 

29.6% 

44.3% 

55.4% 

55.4% 

29.6% 

43.9% 

55.2% 

54.9% 

40.3% 

52.8% 

56.1% 

56.2% 

39.7% 

52.5% 

55.9% 

56.0% 

29.2% 

42.3% 

54.3% 

54.2% 

26.9% 

41.6% 

54.0% 

54.0% 

29.2% 

42.3% 

54.3% 

54.2% 

27.2% 

41.6% 

54.0% 

54.0% 

29.6% 

44.3% 

55.4% 

55.4% 

29.6% 

43.9% 

55.2% 

54.9% 

40.3% 

52.8% 

56.1% 

56.2% 

39.7% 

52.5% 

55.9% 

56.0% 

 
Vehicle category 

Euro 
standard 

Fuel 

Age group 

PO1a 

PO1b 

PO2  

PO3  

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

L3-L7 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro VI 

Euro VI 

Euro VI 

Euro VI 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

All ages 

12.0% 

32.1% 

42.6% 

43.0% 

12.0% 

32.1% 

42.6% 

43.0% 

12.0% 

32.1% 

42.6% 

43.0% 

12.0% 

32.1% 

42.6% 

43.0% 

59.1% 

59.1% 

59.1% 

59.1% 

59.1% 

59.1% 

59.1% 

59.1% 

1.0% 

37.4% 

50.5% 

53.9% 

54.0% 

36.7% 

50.2% 

53.7% 

53.8% 

40.1% 

51.9% 

54.9% 

54.8% 

38.8% 

51.3% 

54.4% 

54.4% 

65.2% 

65.0% 

64.8% 

64.7% 

66.5% 

66.0% 

65.7% 

65.5% 

1.7% 

40.3% 

52.8% 

56.1% 

56.2% 

39.7% 

52.5% 

55.9% 

56.0% 

42.9% 

54.2% 

57.0% 

56.9% 

41.7% 

53.6% 

56.6% 

56.6% 

65.2% 

65.0% 

64.8% 

64.7% 

66.5% 

66.0% 

65.7% 

65.5% 

1.0% 

40.3% 

52.8% 

56.1% 

56.2% 

39.7% 

52.5% 

55.9% 

56.0% 

42.9% 

54.2% 

57.0% 

56.9% 

41.7% 

53.6% 

56.6% 

56.6% 

65.2% 

65.0% 

64.8% 

64.7% 

66.5% 

66.0% 

65.7% 

65.5% 

5.1% 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 236: Reduction in the share of PN high emitter vehicles by policy option relative to the baseline 

Vehicle category 

Euro 
standard 

Fuel 

Age group 

PO1a 

PO1b 

PO2  

PO3  

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

237 

7.5% 

20.6% 

37.8% 

38.1% 

7.5% 

20.6% 

37.8% 

38.1% 

7.5% 

20.6% 

37.8% 

38.1% 

7.5% 

20.6% 

25.6% 

32.5% 

50.5% 

50.4% 

23.2% 

31.7% 

50.1% 

50.1% 

25.6% 

32.5% 

50.5% 

50.4% 

23.5% 

31.7% 

25.6% 

32.5% 

50.5% 

50.4% 

23.2% 

31.7% 

50.1% 

50.1% 

25.6% 

32.5% 

50.5% 

50.4% 

23.5% 

31.7% 

25.6% 

32.5% 

50.5% 

50.4% 

23.2% 

31.7% 

50.1% 

50.1% 

25.6% 

32.5% 

50.5% 

50.4% 

23.5% 

31.7% 

 
  
  
Vehicle category 

Euro 
standard 

Fuel 

Age group 

PO1a 

PO1b 

PO2  

PO3  

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

Euro 6 

Euro 6 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro VI 

Euro VI 

Euro VI 

Euro VI 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

238 

37.8% 

38.1% 

7.5% 

20.6% 

37.8% 

38.1% 

7.5% 

20.6% 

37.8% 

38.1% 

8.1% 

22.7% 

33.4% 

33.7% 

8.1% 

22.7% 

33.4% 

33.7% 

8.1% 

22.7% 

33.4% 

33.7% 

8.1% 

22.7% 

33.4% 

33.7% 

8.1% 

22.7% 

33.4% 

33.7% 

8.1% 

22.7% 

33.4% 

33.7% 

48.7% 

50.6% 

54.4% 

54.5% 

48.7% 

50.6% 

54.4% 

54.5% 

50.1% 

50.1% 

26.0% 

34.9% 

51.7% 

51.6% 

26.0% 

34.3% 

51.4% 

51.1% 

34.6% 

43.7% 

46.5% 

46.5% 

33.9% 

43.3% 

46.3% 

46.3% 

34.6% 

43.7% 

46.5% 

46.5% 

33.9% 

43.3% 

46.3% 

46.3% 

37.4% 

45.3% 

47.7% 

47.4% 

36.1% 

44.6% 

47.2% 

47.0% 

56.4% 

57.8% 

60.8% 

60.8% 

58.0% 

59.0% 

61.8% 

61.7% 

50.1% 

50.1% 

26.0% 

34.9% 

51.7% 

51.6% 

26.0% 

34.3% 

51.4% 

51.1% 

37.7% 

46.3% 

49.1% 

49.1% 

37.0% 

46.0% 

48.8% 

48.9% 

37.7% 

46.3% 

49.1% 

49.1% 

37.0% 

46.0% 

48.8% 

48.9% 

40.4% 

47.9% 

50.2% 

49.9% 

39.1% 

47.2% 

49.7% 

49.5% 

56.4% 

57.8% 

60.8% 

60.8% 

58.0% 

59.0% 

61.8% 

61.7% 

50.1% 

50.1% 

26.0% 

34.9% 

51.7% 

51.6% 

26.0% 

34.3% 

51.4% 

51.1% 

37.7% 

46.3% 

49.1% 

49.1% 

37.0% 

46.0% 

48.8% 

48.9% 

37.7% 

46.3% 

49.1% 

49.1% 

37.0% 

46.0% 

48.8% 

48.9% 

40.4% 

47.9% 

50.2% 

49.9% 

39.1% 

47.2% 

49.7% 

49.5% 

56.4% 

57.8% 

60.8% 

60.8% 

58.0% 

59.0% 

61.8% 

61.7% 

 
Vehicle category 

Euro 
standard 

Fuel 

Age group 

PO1a 

PO1b 

PO2  

PO3  

L3-L7 

All ages 

1.0% 

1.7% 

1.0% 

5.1% 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 237: Share of NOx high emitter vehicles in the baseline and policy options 

Vehicle category 

Euro 
standard 

Fuel 

Age group 

Baseline 
level 

PO1a 

PO1b 

PO2 

PO3 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

239 

2.5% 

5.0% 

7.5% 

10.0% 

3.5% 

6.5% 

9.8% 

13.0% 

2.5% 

5.0% 

7.5% 

10.0% 

3.3% 

6.5% 

9.8% 

13.0% 

1.3% 

3.0% 

4.5% 

5.0% 

1.6% 

3.3% 

4.9% 

6.5% 

6.0% 

9.0% 

12.0% 

15.0% 

7.8% 

11.7% 

15.6% 

19.5% 

6.0% 

9.0% 

12.0% 

15.0% 

7.8% 

11.7% 

2.2% 

3.4% 

4.3% 

5.7% 

3.1% 

4.4% 

5.6% 

7.4% 

2.2% 

3.4% 

4.3% 

5.7% 

2.9% 

4.4% 

5.6% 

7.4% 

1.1% 

2.0% 

2.6% 

2.9% 

1.4% 

2.2% 

2.8% 

3.7% 

5.3% 

6.1% 

6.9% 

8.6% 

6.9% 

7.9% 

9.0% 

11.1% 

5.3% 

6.1% 

6.9% 

8.6% 

6.9% 

7.9% 

1.8% 

2.9% 

3.4% 

4.6% 

2.6% 

3.8% 

4.5% 

6.0% 

1.8% 

2.9% 

3.4% 

4.6% 

2.4% 

3.8% 

4.5% 

6.0% 

0.9% 

1.7% 

2.0% 

2.2% 

1.1% 

1.8% 

2.2% 

2.9% 

3.8% 

4.5% 

5.5% 

6.9% 

4.9% 

5.8% 

7.2% 

9.0% 

3.8% 

4.5% 

5.5% 

6.9% 

4.9% 

5.8% 

1.8% 

2.9% 

3.4% 

4.6% 

2.6% 

3.8% 

4.5% 

6.0% 

1.8% 

2.9% 

3.4% 

4.6% 

2.4% 

3.8% 

4.5% 

6.0% 

0.9% 

1.7% 

2.0% 

2.2% 

1.1% 

1.8% 

2.2% 

2.9% 

3.6% 

4.2% 

5.3% 

6.6% 

4.7% 

5.6% 

6.9% 

8.6% 

3.6% 

4.2% 

5.3% 

6.6% 

4.7% 

5.6% 

1.8% 

2.9% 

3.4% 

4.6% 

2.6% 

3.8% 

4.5% 

6.0% 

1.8% 

2.9% 

3.4% 

4.6% 

2.4% 

3.8% 

4.5% 

6.0% 

0.9% 

1.7% 

2.0% 

2.2% 

1.1% 

1.8% 

2.2% 

2.9% 

3.6% 

4.2% 

5.3% 

6.6% 

4.7% 

5.6% 

6.9% 

8.6% 

3.6% 

4.2% 

5.3% 

6.6% 

4.7% 

5.6% 

 
  
  
Vehicle category 

Euro 
standard 

Fuel 

Age group 

Baseline 
level 

PO1a 

PO1b 

PO2 

PO3 

Euro 6 

Euro 6 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro VI 

Euro VI 

Euro VI 

Euro VI 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

L3-L7 

L3-L7 

L3-L7 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15.6% 

19.5% 

9.0% 

11.1% 

3.0% 

4.5% 

6.0% 

7.5% 

3.6% 

4.4% 

5.2% 

6.0% 

7.2% 

8.8% 

10.4% 

12.0% 

3.6% 

4.4% 

5.2% 

6.0% 

3.5% 

6.5% 

9.8% 

2.6% 

3.1% 

3.4% 

4.3% 

3.2% 

3.0% 

3.0% 

3.4% 

2.9% 

3.6% 

4.3% 

4.9% 

1.5% 

1.8% 

2.1% 

2.5% 

3.5% 

6.4% 

9.6% 

7.2% 

9.0% 

1.8% 

2.2% 

2.7% 

3.4% 

2.2% 

2.1% 

2.4% 

2.7% 

2.5% 

3.1% 

3.7% 

4.2% 

1.2% 

1.5% 

1.8% 

2.1% 

3.5% 

6.4% 

9.6% 

6.9% 

8.6% 

1.7% 

2.1% 

2.6% 

3.2% 

2.1% 

2.0% 

2.3% 

2.6% 

2.5% 

3.1% 

3.7% 

4.2% 

1.2% 

1.5% 

1.8% 

2.1% 

3.5% 

6.4% 

9.6% 

6.9% 

8.6% 

1.7% 

2.1% 

2.6% 

3.2% 

2.1% 

2.0% 

2.3% 

2.6% 

2.5% 

3.1% 

3.7% 

4.2% 

1.2% 

1.5% 

1.8% 

2.1% 

3.3% 

6.2% 

9.2% 

L3-L7 

15-19 
Source: Ricardo et al. (2024), Impact assessment support study 

13.0% 

12.9% 

12.8% 

12.9% 

12.3% 

Table 238: Share of PN high emitter vehicles in the baseline and policy options 

Vehicle category 

Euro 
standard 

Fuel 

Age group 

Baseline 
level 

PO1a 

PO1b 

PO2  

PO3  

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 7 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

240 

2.5% 

5.0% 

7.5% 

10.0% 

2.6% 

5.2% 

7.8% 

10.4% 

2.5% 

5.0% 

7.5% 

10.0% 

2.6% 

5.2% 

7.8% 

10.4% 

1.3% 

2.3% 

4.0% 

4.7% 

6.2% 

2.4% 

4.1% 

4.9% 

6.4% 

2.3% 

4.0% 

4.7% 

6.2% 

2.4% 

4.1% 

4.9% 

6.4% 

1.2% 

1.9% 

3.4% 

3.7% 

5.0% 

2.0% 

3.6% 

3.9% 

5.2% 

1.9% 

3.4% 

3.7% 

5.0% 

2.0% 

3.6% 

3.9% 

5.2% 

1.0% 

1.9% 

3.4% 

3.7% 

5.0% 

2.0% 

3.6% 

3.9% 

5.2% 

1.9% 

3.4% 

3.7% 

5.0% 

2.0% 

3.6% 

3.9% 

5.2% 

1.0% 

1.9% 

3.4% 

3.7% 

5.0% 

2.0% 

3.6% 

3.9% 

5.2% 

1.9% 

3.4% 

3.7% 

5.0% 

2.0% 

3.6% 

3.9% 

5.2% 

1.0% 

 
  
  
  
  
  
  
  
  
Vehicle category 

Euro 
standard 

Fuel 

Age group 

Baseline 
level 

PO1a 

PO1b 

PO2  

PO3  

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 5 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 6 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Euro VI 

Euro VI 

Euro VI 

Euro VI 

Euro 7 

Euro 7 

Euro 7 

Euro 7 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Petrol 

Petrol 

Petrol 

Petrol 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

Diesel 

M1 

M1 

M1 

M1 

M1 

M1 

M1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N1 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

N2/N3/M2/M3 

L3-L7 

L3-L7 

L3-L7 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

15-19 

0-4 

5-9 

10-14 

3.0% 

4.5% 

5.0% 

1.3% 

2.6% 

3.9% 

5.2% 

6.0% 

9.0% 

12.0% 

15.0% 

6.2% 

9.4% 

12.5% 

15.6% 

6.0% 

9.0% 

12.0% 

15.0% 

6.2% 

9.4% 

12.5% 

15.6% 

3.0% 

4.5% 

6.0% 

7.5% 

3.1% 

4.7% 

6.2% 

7.8% 

7.2% 

8.8% 

10.4% 

12.0% 

3.6% 

4.4% 

5.2% 

6.0% 

2.6% 

5.2% 

7.8% 

2.4% 

2.8% 

3.1% 

1.2% 

2.1% 

2.4% 

3.2% 

5.5% 

7.0% 

8.0% 

9.9% 

5.7% 

7.2% 

8.3% 

10.3% 

5.5% 

7.0% 

8.0% 

9.9% 

5.7% 

7.2% 

8.3% 

10.3% 

2.8% 

3.5% 

4.0% 

5.0% 

2.9% 

3.6% 

4.2% 

5.2% 

3.7% 

4.3% 

4.7% 

5.5% 

1.8% 

2.2% 

2.4% 

2.7% 

2.6% 

5.1% 

7.7% 

2.0% 

2.2% 

2.4% 

1.0% 

1.7% 

1.9% 

2.5% 

3.9% 

5.1% 

6.4% 

8.0% 

4.1% 

5.3% 

6.7% 

8.4% 

3.9% 

5.1% 

6.4% 

8.0% 

4.1% 

5.3% 

6.7% 

8.4% 

1.9% 

2.5% 

3.1% 

3.9% 

2.0% 

2.6% 

3.3% 

4.1% 

3.1% 

3.7% 

4.1% 

4.7% 

1.5% 

1.8% 

2.0% 

2.3% 

2.6% 

5.1% 

7.7% 

2.0% 

2.2% 

2.4% 

1.0% 

1.7% 

1.9% 

2.5% 

3.7% 

4.8% 

6.1% 

7.6% 

3.9% 

5.1% 

6.4% 

8.0% 

3.7% 

4.8% 

6.1% 

7.6% 

3.9% 

5.1% 

6.4% 

8.0% 

1.8% 

2.3% 

3.0% 

3.8% 

1.9% 

2.5% 

3.1% 

3.9% 

3.1% 

3.7% 

4.1% 

4.7% 

1.5% 

1.8% 

2.0% 

2.3% 

2.6% 

5.1% 

7.7% 

L3-L7 

15-19 
Source: Ricardo et al. (2024), Impact assessment support study 

10.4% 

10.3% 

10.2% 

10.3% 

241 

2.0% 

2.2% 

2.4% 

1.0% 

1.7% 

1.9% 

2.5% 

3.7% 

4.8% 

6.1% 

7.6% 

3.9% 

5.1% 

6.4% 

8.0% 

3.7% 

4.8% 

6.1% 

7.6% 

3.9% 

5.1% 

6.4% 

8.0% 

1.8% 

2.3% 

3.0% 

3.8% 

1.9% 

2.5% 

3.1% 

3.9% 

3.1% 

3.7% 

4.1% 

4.7% 

1.5% 

1.8% 

2.0% 

2.3% 

2.5% 

4.9% 

7.4% 

9.9% 

 
  
  
  
  
  
  
  
  
Noise emissions 

On the basis of the analysis of the impacts of each individual measure, the combined impact of the 
measures for each policy option is estimated using the common residual method explained above. 
The tables below summarise the expected reduction in the share of noise high emitter vehicles relative 
to  the  baseline,  by  vehicle  type  and  Member  State.  These  are  used  as  inputs  in  the  PRIMES-
TREMOVE model to derive the reduction in  the external  costs of noise  emissions  relative to the 
baseline.   

Table 239: Reduction in the share of noise high emitter M1 vehicles by policy option relative to the baseline 

AT 

BE 

BG 

CY 

DE 

EE 

FI 

FR 

EL 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

ES 

DK 

PO1a 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

PO1b 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

CZ 

12.5% 
Source: Ricardo et al. (2024), Impact assessment support study 

0.0% 

PO2 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

PO3 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

Table 240: Share of noise high emitter M1 vehicles in the baseline and policy options  

AT 

BE 

BG 

CY 

DE 

Baseline 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

PO1a 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

PO1b 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

PO2 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

PO3 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

242 

 
  
 
EE 

FI 

FR 

EL 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

ES 

DK 

CZ 

Baseline 

PO1a 

PO1b 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

PO2 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

PO3 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

Source: Ricardo et al. (2024), Impact assessment support study 

Table 241: Reduction in the share of noise high emitter N1 vehicles by policy option relative to the baseline 

AT 

BE 

BG 

CY 

DE 

EE 

FI 

FR 

EL 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PO1a 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

PO1b 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

243 

PO2 

17.5% 

17.5% 

17.5% 

17.5% 

17.5% 

17.5% 

12.5% 

17.5% 

17.5% 

17.5% 

12.5% 

17.5% 

17.5% 

17.5% 

17.5% 

17.5% 

17.5% 

17.5% 

17.5% 

PO3 

17.5% 

17.5% 

17.5% 

17.5% 

17.5% 

17.5% 

12.5% 

17.5% 

17.5% 

17.5% 

12.5% 

17.5% 

17.5% 

17.5% 

17.5% 

17.5% 

17.5% 

17.5% 

17.5% 

 
 
  
PT 

RO 

SE 

SI 

SK 

ES 

DK 

PO1a 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

PO1b 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

12.5% 

CZ 

12.5% 
Source: Ricardo et al. (2024), Impact assessment support study 

0.0% 

PO2 

17.5% 

17.5% 

12.5% 

17.5% 

12.5% 

12.5% 

17.5% 

17.5% 

Table 242: Share of noise high emitter N1 vehicles in the baseline and policy options 

Baseline 

PO1a 

PO1b 

AT 

BE 

BG 

CY 

DE 

EE 

FI 

FR 

EL 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

ES 

DK 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

4.0% 

CZ 

4.0% 
Source: Ricardo et al. (2024), Impact assessment support study 

4.0% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

3.5% 

PO2 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.5% 

3.3% 

3.3% 

3.3% 

3.5% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.5% 

3.3% 

3.5% 

3.5% 

3.3% 

3.3% 

PO3 

17.5% 

17.5% 

12.5% 

17.5% 

12.5% 

12.5% 

17.5% 

17.5% 

PO3 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.5% 

3.3% 

3.3% 

3.3% 

3.5% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.3% 

3.5% 

3.3% 

3.5% 

3.5% 

3.3% 

3.3% 

Table 243: Reduction in the share of noise high emitter L3-L7 vehicles by policy option relative to the baseline 

AT 

BE 

PO1a 

0.0% 

12.0% 

PO2 

35.0% 

42.8% 

PO3 

35.0% 

51.5% 

PO1b 

35.0% 

48.0% 

244 

 
  
 
  
BG 

CY 

DE 

EE 

FI 

FR 

EL 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

ES 

DK 

PO1a 

0.0% 

0.0% 

0.0% 

0.0% 

12.0% 

0.0% 

0.0% 

0.0% 

0.0% 

12.0% 

0.0% 

0.0% 

0.0% 

0.0% 

12.0% 

12.0% 

0.0% 

12.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

PO1b 

35.0% 

35.0% 

16.7% 

35.0% 

48.0% 

35.0% 

35.0% 

16.7% 

35.0% 

48.0% 

35.0% 

35.0% 

35.0% 

35.0% 

48.0% 

48.0% 

35.0% 

48.0% 

35.0% 

35.0% 

35.0% 

16.7% 

16.7% 

48.0% 

CZ 

35.0% 
Source: Ricardo et al. (2024), Impact assessment support study 

0.0% 

PO2 

35.0% 

35.0% 

16.7% 

35.0% 

42.8% 

35.0% 

35.0% 

16.7% 

35.0% 

42.8% 

35.0% 

35.0% 

35.0% 

35.0% 

42.8% 

42.8% 

35.0% 

42.8% 

35.0% 

35.0% 

35.0% 

16.7% 

16.7% 

35.0% 

35.0% 

Table 244: Share of noise high emitter L3-L7 vehicles in the baseline and policy options 
PO2 

Baseline 

PO1b 

PO1a 

AT 

BE 

BG 

CY 

DE 

EE 

FI 

FR 

EL 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

19.5% 

15.6% 

19.5% 

19.5% 

25.0% 

19.5% 

15.6% 

19.5% 

19.5% 

25.0% 

19.5% 

15.6% 

19.5% 

19.5% 

19.5% 

19.5% 

30.0% 

26.4% 

30.0% 

30.0% 

30.0% 

30.0% 

26.4% 

30.0% 

30.0% 

30.0% 

30.0% 

26.4% 

30.0% 

30.0% 

30.0% 

30.0% 

245 

19.5% 

17.2% 

19.5% 

19.5% 

25.0% 

19.5% 

17.2% 

19.5% 

19.5% 

25.0% 

19.5% 

17.2% 

19.5% 

19.5% 

19.5% 

19.5% 

PO3 

36.9% 

36.9% 

19.0% 

36.9% 

50.1% 

36.9% 

36.9% 

19.0% 

35.0% 

51.5% 

36.9% 

36.9% 

36.9% 

36.9% 

51.5% 

51.5% 

36.9% 

51.5% 

35.0% 

35.0% 

35.0% 

19.0% 

19.0% 

50.1% 

36.9% 

PO3 

19.5% 

14.5% 

18.9% 

18.9% 

24.3% 

18.9% 

15.0% 

18.9% 

18.9% 

24.3% 

19.5% 

14.5% 

18.9% 

18.9% 

18.9% 

18.9% 

 
  
 
MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

ES 

DK 

Baseline 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

PO1a 

26.4% 

26.4% 

30.0% 

26.4% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

30.0% 

CZ 

30.0% 
Source: Ricardo et al. (2024), Impact assessment support study 

30.0% 

PO1b 

15.6% 

15.6% 

19.5% 

15.6% 

19.5% 

19.5% 

19.5% 

25.0% 

25.0% 

15.6% 

19.5% 

PO2 

17.2% 

17.2% 

19.5% 

17.2% 

19.5% 

19.5% 

19.5% 

25.0% 

25.0% 

19.5% 

19.5% 

PO3 

14.5% 

14.5% 

18.9% 

14.5% 

19.5% 

19.5% 

19.5% 

24.3% 

24.3% 

15.0% 

18.9% 

5.  IMPACTS BY POLICY OPTION ON SAFETY, EMISSIONS AND NOISE 

5.1.  Impacts on road safety  

As explained in section 6.2.1 and in Annex 4 (section 4.1), given that the general objective of the 
initiative is to improve road safety in the EU, several measures to achieve this objective were included 
in the policy options. Direct impact on road safety is expected due to the more effective identification 
of vehicles with major and dangerous defects in the fleet, which should lead to the reduction of road 
crashes caused by technical defects and, as a result, to reduced fatalities and injuries (serious and 
light). Policy options also include other measures contributing to road safety, which relate to better 
implementation  and  enforcement  of  the  roadworthiness  legislation  (such  as  the  exchange  of  data 
among Member States’ authorities).  

Several assumptions were used to establish the impacts on road safety. They are explained in detail, 
by policy measure, in section 4.1 of Annex 4. These inputs437 were subsequently used in the PRIMES-
TREMOVE model to derive the impacts on the number of lives saved and injuries avoided. It should 
be noted that an important element in this assessment relates to the contribution of vehicle technical 
defects to road crashes. As explained in section 2.1.1, various studies indicate that their share as a 
contributing  factor  of  the  cause  of  crashes  is  between  3  and  19%,  depending  on  the  scope  and 
methodology  of  the  study;  for  motorcycles,  it  is  5%  to  12%  of  crashes.  For  this  assessment,  a 
conservative approach was taken assuming a 4% contribution of technical defects on road crashes in 
the case of light-duty vehicles, heavy-duty vehicles and trailers and 6% in the case of motorcycles. 
Considering the uncertainty, a sensitivity analysis has been performed and is included in section 6 of 
Annex 4. 

All policy options are expected to result in lives saved and injuries avoided relative to the baseline 
scenario. The table below provides the reduction in the number of fatalities and injuries relative to 
the baseline in 2030 and 2050, as well as the cumulative number of lives saved and injuries avoided 
relative to the baseline over the 2026-2050 horizon. Cumulatively, over the period 2026-2050, PO3 
is expected to result in 7,013 lives saved, followed by PO2 (6,912 lives saved), PO1b (6,847 lives 
saved) and PO1a (4,661 lives saved). The numbers of severe and slight injuries avoided follow a 
similar pattern with PO3 having the highest impact, followed by PO2, PO1b, and PO1a. 

437 See more details in Annex 4 (section 4.1) on the inputs by measure and their aggregation into policy options.  

246 

 
 
 
Table 245: Expected reduction in the number of fatalities and injuries in the POs relative to the baseline, in 2030 
and 2050, and cumulative reduction over the period 2026-2050 

PO1a 

PO1b 

PO2 

PO3 

2030 
2050 
Cumulative over 2026-2050 
% reduction 
2030 
2050 
Cumulative over 2026-2050 
% reduction 
2030 
2050 
Cumulative over 2026-2050 
% reduction 
2030 
2050 
Cumulative over 2026-2050 
% reduction 

Fatalities  
195  
173  
4,661  
1.1% 
287  
253  
6,847  
1.6% 
289  
255  
6,912  
1.6% 
293  
259  
7,013  
1.6% 

Serious injuries 
1,768  
1,587  
42,272  
1.2% 
2,711  
2,420  
64,640  
1.8% 
2,721  
2,429  
64,885  
1.8% 
2,753  
2,460  
65,686  
1.8% 

Slight injuries 
9,929  
9,011  
239,803  
1.3% 
15,099  
13,658  
364,155  
1.9% 
15,162  
13,712  
365,665  
1.9% 
15,274  
13,826  
368,498  
2.0% 

Source: Ricardo et al. (2024), Impact assessment support study 

It  should be noted that  the assessment of the impacts  at  option level  has considered  all synergies 
between policy measures included in the options, by vehicle category. As such, the impact of a policy 
measure may differ depending on whether it is assessed as part of a package or in isolation. While it 
is quite straightforward for assessing the costs and costs savings by policy measure and policy option, 
it is much more challenging to assess the impacts on the number of fatalities and injuries, and on 
external costs.  

To split the impacts on lives saved and injuries avoided, and the respective external costs, by policy 
option and policy measure the synergies between measures need to be considered. One possibility 
would  be  to  assess  various  combinations  of  measures  and  look  at  differences  between  such 
combinations. This would however result in a large number of policy options that is neither practical 
nor  proportionate  for  the  analysis.  On  the  other  hand,  considering  that  the  PRIMES-TREMOVE 
model calculates the impacts on road safety for each category of vehicle, an approximation of the 
impacts by policy option and policy measure can be derived based on: the difference between policy 
options where only one policy measure is related to a certain vehicle category (if relevant) and the 
inputs used for estimating the impacts on road safety by policy measure and the combined effect of 
measures, according to the common residual method. The table below presents the impacts on lives 
saved and injuries avoided, cumulatively  over the period 2026-2050, by  policy option and policy 
measure relative to the baseline. 

Table 246: Expected cumulative reduction in the number of fatalities and injuries (over the period 2026-2050) by 
policy option and policy measure relative to the baseline 

Policy option 
PO1a 

PO1b 

 Policy measure 
Total 
PMC2 
PM1 
Total 
PMC2 
PM2 
PM6 
PM13 

Severe injuries 
42,272 
42,137 
135 
64,640 
42,137 
430 
21,392 
681 

Slight injuries 
239,803 
239,239 
564 
364,155 
239,239 
1,726 
120,521 
2,669 

Fatalities  
4,661 
4,643 
19 
6,847 
4,643 
60 
1,841 
304 

247 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Policy option 
PO2 

PO3 

 Policy measure 
Total 
PMC2 
PM1 
PM6 
PM13 
PM14 
Total 
PMC2 
PM3 
PM4 
PM6 
PM13 
PM14 
PM15 

Fatalities  
6,912 
4,643 
19 
1,841 
304 
105 
7,013 
4,643 
71 
4 
1,841 
304 
105 
45 

Severe injuries 
64,885 
42,137 
135 
21,392 
681 
540 
65,686 
42,137 
552 
25 
21,392 
681 
540 
359 

Slight injuries 
365,665 
239,239 
564 
120,521 
2,669 
2,671 
368,498 
239,239 
2,004 
137 
120,521 
2,669 
2,671 
1,257 

Source: Ricardo et al. (2024), Impact assessment support study 

The  most  significant  impact  on  road  safety  is  estimated  to  come  as  a  result  of  the  new  testing 
requirements in PTIs and roadside inspections, which will ensure that safety-related technologies to 
be fitted in new vehicles as required by the General Safety Regulation (GSR) operate as expected 
(PMC2). Due to inspections which will be able to detect defective ADAS systems there should be 
fewer  road  crashes  and  thus  fewer  fatalities  and  injuries.  This  measure  is  included  in  and  has  an 
impact on all policy options. In the case of PO1a, additional positive impacts are expected due to 
roadside inspection of motorcycles over 125cc for those Member States438 where no PTI is currently 
in place for such motorcycles (PM1), assuming that they will choose this option instead of PTI.  

For  PO1b,  in  addition  to  the  impacts  of  new  testing  requirements  for  safety-related  technologies 
mandated by the GSR (PMC2), there are additional impacts expected from mandatory annual PTI 
testing of vehicles over 10-year-old (PM6), mandatory PTI for motorcycles over 125cc (PM2) and 
mandatory cargo securing inspections (PM13). The mandatory annual PTI testing of vehicles over 
10-year-old (PM6) will lead to an increase of the PTI frequency in 11 Member States439, and has the 
second  most  significant  impact  on  road  safety  after  PMC2.  PM2  is  expected  to  help  in  the 
identification of motorcycles over 125cc  with  significant  safety  defects  during PTI inspections in 
those  countries  that  do  not  apply  this  measure  yet440.  Mandatory  inspections  of  cargo  securing 
(PM13) should ensure that appropriate standards are applied across all the EU, thus contributing to 
the avoidance of accidents caused by cargo defects from HGVs (vehicle category N2/N3)441. In PO2, 
further positive, albeit smaller impact is expected due to the introduction of a systematic roadside 
inspection of vans (PM14), which has a high effectiveness in capturing defective N1 vehicles. Finally, 
PO3 goes further in road-safety related measures and besides the impact of measures PMC2, PM6, 
PM13 and PM14, there is additional positive impact expected from the extended scope of PTI to all 
motorcycle over 50 cc (PM3), which would mean a higher share of these vehicles subject to PTI and 

438 BE, FI, IE, MT, NL, PT (DK already applies RSI for motorcycles and FR plans to introduce PTI in 2024). 
439 CY, DE, LT, CZ, DK, FR, EL, HU, IT, MT, SK 
440 BE, FI, IE, MT, NL, PT (FR is expected to introduce PTI in 2024 and is thus part of the baseline). 
441 This concerns only Member States (BE, BG, DK, DE, EE, FI, FR, IE, IT, LV, LU, NL, PL, PT) where there are no such 
inspections or no adequate standards in place yet. 

248 

 
  
  
  
  
  
  
  
  
  
  
  
  
 
a higher share of detected defects. Mandatory PTI for O1 and O2 light trailers442 would affect around 
21.5% of the total EU fleet of O1 trailers and around 9.3% of the O2 trailers (PM4). Extending the 
scope of roadside inspections to all 2- and 3-wheeled vehicles (PM15) with a target of 1% of the fleet 
is expected to bring an additional reduction of fatalities and serious injuries in comparison to baseline 
levels. It will cover most of the EU Member States except those443 that indicated that they already 
have RSI inspections for motorcycles in place, although with no clearly stated target. 

The  table  below  provides  the  reduction  in  the  external  costs  of  accidents  relative  to  the  baseline, 
expressed as present value over the 2026-2050 period. The 2019 Handbook on the external costs of 
transport444 was used to monetise the costs445. As a result of the positive impacts on lives saved and 
injuries avoided presented above, PO3 shows the highest impact in terms of reduction in the external 
costs of accidents relative to the baseline (expressed as present value over the 2026-2050 period), 
estimated at EUR 75.2 billion. It is followed by PO2 with EUR 74.2 billion, PO1b with EUR 73.9 
billion, and PO1a with EUR 48.1 billion.  

Table 247: Reduction in the external costs of accidents in the POs relative to the baseline, expressed as present 
value over the 2026-2050 horizon, in 2022 prices (million EUR) 
 PO1a  
11,677 
21,348 
15,053 
48,079 

 Fatalities  
 Serious injuries  
 Slight injuries  
 Total  

 PO1b  
17,498 
33,235 
23,196 
73,929 

 PO3  
17,902 
33,821 
23,521 
75,244 

 PO2  
17,633 
33,299 
23,251 
74,183 

Source: Ricardo et al. (2024), Impact assessment support study 

The  table  below  presents  the  impacts  on  external  costs  of  accidents  by  policy  option  and  policy 
measure relative to the baseline, expressed as present value over the 2026-2050 period. The split by 
policy measure considers the synergies between the measures included in the options. Considering 
the  caveats  explained  above,  this  should  be  seen  as  an  approximation  of  the  impacts  by  policy 
measure.  

Table 248: Reduction in the external costs of accidents by policy option and policy measure relative to the baseline, 
expressed as present value over the 2026-2050 horizon, in 2022 prices (million EUR) 

PO1a 
47,885 
193 

 Policy measure 
PMC2 
PM1 
PM2 
PM3 
PM4 
PM6 
PM13 
PM14 
PM15 

PO1b 
47,885 

615 

24,200 
1,229 

PO2 
47,885 
193 

24,200 
1,229 
675 

PO3 
47,885 

739 
32 
24,200 
1,229 
675 
483 

442 Eleven Member States would be affected by PM4: 7 Member States where there is currently no requirement for PTI 
for either O1 or O2 (DK, EL, FI, FR, NL, IE, PT) and 4 Member States where there is currently only a requirement for 
PTI for O2 (PL, SK, BE and ES). 
443 SE, SI, AT, FI, DK, HU, RO 
444  https://op.europa.eu/en/publication-detail/-/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1  
445 Based on the Handbook, the external cost of a fatality in 2022 prices is estimated at around EUR 3.5 million, that of a serious 
injury at around EUR 0.5 million and that of a slight injury at around EUR 0.04 million. These values are multiplied by the number 
of fatalities,  serious and  slight injuries, respectively, to monetise  the external costs of  accidents  in the context of this impact 
assessment. 

249 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Policy measure 
Total 

PO1a 
48,079 

PO1b 
73,929 

PO2 
74,183 

PO3 
75,244 

Source: Ricardo et al. (2024), Impact assessment support study 

5.2.  Impacts on air pollution emissions and noise  

Impacts  on  air  pollutant  emissions.  As  explained  in  section  6.3,  the  analysis  of  the  impact  on 
emissions has focused on the two pollutants that are targeted in the proposed measures, NOx and 
particulate matter (particulates). Other pollutants have not been considered although it is plausible 
that by targeting high emitters for these two pollutants, there will also be benefits related to other air 
pollutants  (e.g.  CO,  HC,  SO2).  The  measures  included  in  the  analysis  having  an  impact  on  air 
pollutant emissions are targeted at high emitters of NOx and particulate matter in the vehicle fleet, 
which should be effectively identified and repaired.  

All  four  policy  options  include  the  two  measures  aimed  at  NOx  and  particulate  matter,  PMC3 
(mandatory  PN  testing)  and  PMC4  (NOx  testing).  All  policy  options  include  a  combination  of 
measures specific for motorcycles (PM1 and PM15 for roadside inspections, and PM2 and PM3 for 
PTI).  In  addition,  all  options  but  PO1a  include  more  frequent  emissions  testing  for  vans  (PM5), 
mandatory annual PTI for cars and vans older than 10 years (PM6), and NOx and PM measurement 
by remote sensing in roadside inspection of all vehicles and plume chasing in RSI of commercial 
vehicles (PM12). 

It is expected that the proposed new testing methods under PMC3 and PMC4 (PN measurement and 
new NOx emissions testing) will be more effective in identifying high emitters than currently used 
methods such as opacity tests. This, combined with an increased scope and frequency of inspection, 
should in principle lead to a higher share of high emitters in the fleet identified. It is also expected 
that roadside inspections of air pollutants (as provided in PM1 and PM15 for motorcycles, and in 
PM14 for vans) will be very effective in identifying tampered vehicles since their owners will not be 
prepared  for  the  specific  inspection  and,  in  the  majority  of  the  cases,  will  not  have  the  time  to 
deactivate the tampering device. In the case of measures related to PTI inspections (i.e., PM2 and 
PM3 for motorcycles) it can be expected that they are less effective in identifying tampered vehicles 
as the owners can remove or deactivate the tampering device before the PTI inspection and activate 
it again after the inspection. Detailed tables with the expected impact of the four policy options in 
terms of the expected level of reduction of high emitters in comparison to the baseline levels for each 
vehicle category with reference to the total EU fleet are provided in section 4.2.15 of Annex 4.    

Regarding both NOx and particle matter emissions, PO1a has the least impact among all options, 
relative to the baseline, since it only includes common PTI measures PMC3 and PMC4 for PN and 
NOx measurement, respectively, and PM1. PO1b, PO2 and PO3 are all expected to have a higher 
impact than PO1a, in particular for light commercial vehicles (vans), as a result of the introduction 
of more frequent emission testing starting from the first year for vans (PM5) and the requirement of 
annual PTI for vehicles older than 10 years (PM6). Additional positive impacts of these three options 
should arise from  the introduction of remote sensing and plume chasing  (PM12). However, more 
positive impacts are expected for PO2 and PO3 due to the additional mandatory roadside inspection 
for vans (PM14). Compared to PO1b, PO2 has a higher total expected impact on emissions from 
PM1  due  to  assumed  higher  effectiveness  of  RSI  inspections,  especially  in  capturing  tampered 
vehicles, while PTIs are considered less effective in capturing of tampered vehicles. In the case of 
PO3, the slightly higher level of impacts in comparison to PO2 comes from the broader scope of 
motorcycles to be covered by PTI (>50 cc, PM3).    

250 

 
The table below presents the expected impact on the level of emissions in comparison to the baseline 
for  each  policy  option.  PO2  and  PO3  are  expected  to  have  the  highest  cumulative  impact  on  air 
pollutants reduction over 2026-2050 (3,969 kilo-tonnes of NOx in PO2 and 3,970 kilo-tonnes of NOx 
in PO3, and 199 kilo-tonnes of PM in both PO2 and PO3), representing a decrease of 21% and 18.7% 
for  NOx  and  PM,  respectively,  relative  to  the  baseline.  PO1b  shows  somewhat  lower  levels  of 
emissions  reductions  (20.8%  for  NOx  and  18.5%  for  PM).  PO1a  is  expected  to  bring  the  least 
reduction of both air pollutants over the 2026-2050 period (3,176 kilo-tonnes of NOx, representing a 
16.8% reduction relative to the baseline, and 135 kilo-tonnes of PM, representing 12.7% reduction). 

Table 249: Impact on air pollutant emissions (kilo tonnes of NOx and PM2.5 avoided relative to the  baseline in 
2030 and in 2050, and cumulative over 2026-2050; % change in cumulative air pollution emissions relative to the 
baseline) 

2030 

2050 

Cumulative 
over 2026-2050 

% change to 
baseline 

NOx (kilo tonnes of NOx avoided) 
PO1a 
PO1b 
PO2 
PO3 
PM2.5 (kilo tonnes of PM avoided) 
PO1a 
PO1b 
PO2 
PO3 

200.5 
253.1 
255.9 
255.9 

7.8 
12.0 
12.1 
12.1 

Source: Ricardo et al. (2024), Impact assessment support study 

12.1 
13.9 
14.0 
14.0 

0.6 
0.8 
0.8 
0.8 

3,176 
3,925 
3,969 
3,970 

135 
196 
199 
199 

-16.8% 
-20.8% 
-21.0% 
-21.0% 

-12.7% 
-18.5% 
-18.7% 
-18.7% 

The  external  cost  savings  due  to  the  reduction  of  air  pollutant  emissions  (NOx  and  PM)  were 
calculated using the 2019 Handbook on the external costs of transport446. PO2 and PO3 are expected 
to  lead  to  the highest  levels  of reduction in  external  costs, estimated at  around  EUR  76.1 billion, 
expressed as present value over the 2026-2050 period. This is slightly higher than PO1b (EUR 75.2 
billion) and much higher than PO1a (EUR 58.7 billion). Results are presented in the table below. 

Table 250: Reduction in the external costs of air pollutant emissions relative to the baseline, expressed as present 
value over 2026-2050, in 2022 prices (million EUR) 

Reduction in external costs related to NOx emissions  

PO1a 
46,966  

PO1b 
58,054  

PO2 
58,646  

PO3 
58,659  

Reduction in external costs related to PM emissions  

11,707  

17,193  

17,429  

17,429  

Total reduction in external costs of air pollutant emissions  

58,673  

75,247  

76,075  

76,088  

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

Impact on noise emissions. The measures which are expected to have the highest impact on noise 
reduction are PM12, by the use of remote sensing with acoustic cameras, and PM10, through more 
advanced testing methods for motorcycles at PTI. Positive impact on noise reduction is also expected 
due to measures focusing on high emitters, such as the extension of scope of PTI to cover motorcycles 
(PM3, but also PM1 and PM2), and extending the roadside inspections to cover motorcycles (PM15) 
and light commercial (N1) vehicles (PM14). As in the case of exhaust gas aftertreatment systems, 
PTI on its own is not expected to have a sizeable impact on identifying tampering of noise control 
systems.  Roadside  inspections  are  generally  expected  to  be  a  more  effective  tool,  which  was 
confirmed by the stakeholders that responded on this point during the consultations. The limiting 

446  https://op.europa.eu/en/publication-detail/-/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1  

251 

 
  
 
 
 
 
 
 
 
 
  
 
factor in this case is the capacity of roadside inspections to cover a large share of the fleet. Detailed 
explanations on the input by policy measure used to quantify the impacts are provided in section 4.2 
of Annex 4.  

When comparing the policy options, the impact  on the reduction of high emitters and thereby on 
noise is expected to be the lowest in PO1a as it does not contain any measure directly targeted at 
noise  (it  has  a  small  positive  impact  through  PM1,  the  introduction  of  roadside  checks  for 
motorcycles in six Member States where they are not fully covered by PTI447). A higher impact is 
expected in the case of PO1b and PO2, combining more advanced noise testing in PTI (PM10) and 
use of remote sensing to support roadside inspections (PM12). For PO2 and PO3, additional positive 
impacts can also arise from the increase in roadside inspection of vans but the highest impacts in 
terms of noise reduction are expected in PO3, due to the mandatory RSI for motorcycles (PM15). 
The table below presents the estimated reduction in the external costs of noise for the four policy 
options, with PO3 providing the largest savings of around EUR 7.8 billion, expressed as present value 
over 2026-2050 relative to the baseline. PO1b and PO2 are expected to bring similar reductions in 
external  noise  cost  (EUR  7.3  billion  over  the  same  period).  The  reduction  under  PO1a  would  be 
significantly lower (EUR 0.2 billion). As for the costs of accidents and air pollution, the external 
costs of noise were calculated using the PRIMES-TREMOVE model, based on the 2019 Handbook 
on the external costs of transport. 

Table 251: Reduction in the external costs of noise emissions relative to the baseline, expressed as present value 
over 2026-2050, in 2022 prices (million EUR) 

Reduction in external costs related to noise emissions  

PO1a 
154  

PO1b 
7,323  

PO2 
7,319  

PO3 
7,757  

Source: Ricardo et al. (2024), Impact assessment support study 

6.  TRADE-OFFS IN TERMS OF COSTS AND BENEFITS OF SOME KEY POLICY MEASURES 

As explained in section 5.1 of Annex 4, the assessment of the impacts at option level has considered 
all  synergies  between  policy  measures  included  in  the  options,  by  vehicle  category.  As  such,  the 
impact of a policy measure may differ depending on whether it is assessed as part of a package or in 
isolation. While in this case this is quite straightforward for assessing the costs and costs savings by 
policy measure and policy option, it is much more challenging to assess the impacts on external costs. 

To split the impacts on lives saved, injuries avoided, the reduction in air pollution and noise emissions 
and  the  respective  external  costs  by  policy  option  and  policy  measure,  the  synergies  between 
measures need to be considered. One possibility would be to assess various combinations of measures 
and look at differences between such combinations. This would however result in a large number of 
policy  options  that  is  neither  practical  nor  proportionate  for  the  analysis.  On  the  other  hand, 
considering that the PRIMES-TREMOVE model calculates the impacts on road safety, air pollution 
and noise external costs corresponding to each category of vehicle, an approximation of the external 
costs savings by policy option and policy measure can be derived based on: (1) the difference between 
policy options where only one policy measure is related to a certain vehicle category (if relevant), (2) 
the inputs used for estimating the impacts on road safety and (3) the share of high-emitting vehicles 
by policy measure and the combined effect of measures, according to the common residual method. 

While keeping in mind the caveats above, the tables below illustrate the benefits, costs, and benefits 
to  costs  ratio  for  policy  measures  related  to  motorcycles  (see  Table  252),  for  the  policy  measure 
related to  trailers (see  Table 253)  and older vehicles (see Table 254),  and for the policy measure 

447 BE, FI, IE, MT, NL, PL 

252 

 
  
 
related to odometer readings (see Table 255). All costs and benefits are expressed as present value 
over 2026-2050, relative to the baseline. 

While the cost and benefits of the measures addressing motorcycles and trailers are rather limited 
(due to the relatively small number of Member States and number of vehicles affected), the impacts 
of testing cars and vans older than 10 years annually is much more significant. This is even more so 
for the policy measure related to odometer readings that shows the highest benefits.  

Table 252: Benefits and costs for policy measures related to motorcycles, expressed as present value over 2026-
2050 (in million EUR) 

Benefits and costs (present 
value, in million EUR) 

PM1 
Benefits 

External costs savings 

Costs 

Citizens 
National public administrations 

Benefits to costs ratio 
PM2 
Benefits 

External costs savings 
Other benefits for PTI centres (increased number of inspections) 

Costs 

PTI centres 
Citizens 
National public administrations 

Benefits to costs ratio 
PM3 
Benefits 

External costs savings 
Other benefits for PTI centres (increased number of inspections) 

Costs 

PTI centres 
Citizens 
National public administrations 

Benefits to costs ratio 
PM15 
Benefits 

External costs savings 

Costs 

Citizens 
National public administrations 

Benefits to costs ratio 

Source: Ricardo et al. (2024), Impact assessment support study 

253 

350.9 
350.9 
17.4 
7.9 
9.5 
20.2 

1,212.2 
918.1 
294.1 
502.7 
175.7 
294.1 
32.9 
2.4 

1,477.8 
1,136.5 
341.3 
583.4 
203.9 
341.3 
38.1 
2.5 

693.9 
693.9 
37.6 
16.9 
20.6 
18.5 

 
 
  
  
  
  
Table 253: Benefits and costs for the policy measure related to trailers, expressed as present value over 2026-2050 
(in million EUR) 

Benefits and costs (present 
value, in million EUR) 

PM4 
Benefits 

External costs savings 
Other benefits for PTI centres (increased number of inspections) 

Costs 

PTI centres 
Other businesses (vehicle owners) 
Citizens 
National public administrations 

Benefits to costs ratio 

558.8 
32.2 
526.6 
791.3 
225.4 
385.1 
141.5 
39.2 
0.7 

Source: Ricardo et al. (2024), Impact assessment support study 

For older vehicles (PM6), because of the high costs linked to additional investment in new PTI lanes 
and equipment, and, most importantly, additional human resources, the benefits to costs ratio is 1.4 
when considering the economic benefits to PTI centres due to the increased number of inspections. 

Table 254: Benefits and costs for the policy measure related to older vehicles (cars and vans), expressed as present 
value over 2026-2050 (in million EUR) 

Benefits and costs (present value, 
in million EUR) 

PM6 
Benefits 

External costs savings 
Other benefits for PTI centres (increased number of inspections) 

Costs 

PTI centres 
Other businesses (vehicle owners) 
Citizens 

Benefits to costs ratio 

Source: Ricardo et al. (2024), Impact assessment support study 

73,872.8 
37,335.2 
36,537.6 
54,218.4 
17,680.8 
23,295.9 
13,241.7 
1.4 

The policy measure related to odometer readings (PMC9) is estimated to lead to the highest benefits 
to costs ratio among the measures. This is due to the significant benefits expected for citizens and 
businesses (vehicle owners) due to the reduction in odometer fraud. Even if the effectiveness of the 
measure in reducing the number of vehicles with tampered odometers was significantly lower, the 
benefits and the efficiency of the measure is still expected to remain high. 

Table 255: Benefits and costs for the policy measure related to odometer readings, expressed as present value over 
2026-2050 (in million EUR) relative to the baseline 

Benefits and costs (present 
value, in million EUR) 

PMC9 
Benefits 

Other businesses (vehicle owners) 
Citizens 

Costs 

Garages, motor vehicle dealers, tyre and repair stations, etc. 
OEMs 

254 

184,007.4 
118,340.5 
65,666.9 
2,638.0 
460.0 
55.9 

 
 
  
 
  
 
  
National public administrations 

Benefits to costs ratio 

Source: Ricardo et al. (2024), Impact assessment support study 

7.  SENSITIVITY ANALYSIS 

Benefits and costs (present 
value, in million EUR) 

2,122.1 
69.8 

Sensitivity  analysis  on  contribution  of  technical  defects  to  road  crashes  and  share  of  high 
emitting  vehicles  of  air  pollution  and  noise  in  the  fleet.  As  indicated  in  section  6.2.1,  there  is 
significant  uncertainty  around  the  contribution  of  technical  defects  to  road  crashes.  The  central 
assumption used is that 4% of road crashes are caused by technical defects in the case of cars, vans, 
heavy duty vehicles and trailers and 6% in the case of motorcycles. A sensitivity analysis has been 
performed to understand the implications of lower or higher contribution of technical defects to road 
crashes. The following cases have been assessed: 

-  Low case:  3% for motorcycles and 1% for all other categories;  

-  High case: 9% for motorcycles and 7% for all other vehicle categories.  

In addition, considering the uncertainty of the share of high emitting vehicles of air pollution and 
noise  in  the  fleet,  the  implications  of  alternative  shares  of  high  and  low  emitters  in  the  baseline 
scenario  have  been  assessed.  More  specifically,  compared  to  the  central  case  the  following 
assumptions have been used: 

-  Low case: shares of high emitters 25% lower than in the baseline; 

-  High case: shares of high emitters 25% higher than in the baseline. 

Subsequently, the impacts on external costs and the efficiency of the policy options is assessed for 
the low and high case, including both elements related to safety and emissions. 

The table below presents the impacts on the external costs of accidents, air pollution and noise, in the 
low case, central case (i.e. central estimate used in the assessment) and high case.  

Table 256: External costs savings by policy option in the low case, central case and high case, expressed as present 
value over 2026-2050 compared to the baseline (in million EUR, in 2022 prices)  

in  external  costs  of 

Total external costs savings - low 
case 
Reduction  in  external  costs  of  air 
pollution emissions 
Reduction in external costs of noise 
emissions 
Reduction 
accidents 
Total  external  costs  savings  - 
central case 
Reduction  in  external  costs  of  air 
pollution emissions 
Reduction in external costs of noise 
emissions 
Reduction 
accidents 

in  external  costs  of 

Difference to the Baseline 

PO1a 

91,372.4 

PO1b 

116,754.9 

PO2 

PO3 

117,340.6 

118,216.9 

42,119.0 

55,690.0 

56,322.0 

56,332.0 

1,271.4 

5,589.9 

5,585.6 

5,920.9 

47,982.0 

55,475.0 

55,433.0 

55,964.0 

106,906.2 

156,499.4 

157,577.4 

159,088.7 

58,673.0 

75,247.0 

76,075.0 

76,088.0 

154.2 

7,323.4 

7,319.4 

7,756.7 

48,079.0 

73,929.0 

74,183.0 

75,244.0 

255 

 
 
 
Total external costs savings - high 
case 
Reduction  in  external  costs  of  air 
pollution emissions 
Reduction in external costs of noise 
emissions 
Reduction 
accidents 

in  external  costs  of 

Difference to the Baseline 

PO1a 

126,790.2 

PO1b 

197,380.7 

PO2 

PO3 

198,932.4 

201,093.3 

76,510.0 

95,745.0 

96,758.0 

96,774.0 

2,104.2 

9,251.7 

9,245.4 

9,799.3 

48,176.0 

92,384.0 

92,929.0 

94,520.0 

Source: Ricardo et al. (2024), Impact assessment support study 

The following table presents the impacts on total benefits, net benefits and benefits to costs ratio by 
policy option in the low case, central case and high case. It shows that all policy options are expected 
to result in net benefits under the three cases considered. It also shows that the ranking of the policy 
options is not expected to change in the low case and high case relative to the central case estimates.  

Table  257: Summary  of  costs  and  benefits  of  the  policy  options  in  the  low  case,  central  case  and  high  case, 
expressed as present value over 2025-2050 compared to the baseline (in million EUR, in 2022 prices) 

Total costs 

Total benefits 

Low case 

Central case 

High case 

Net benefits 

Low case 

Central case 

High case 

Benefits to costs ratio 

Low case 

Central case 

High case 

 Difference to the Baseline  

 PO1a  

 PO1b  

 PO2  

 PO3  

7,303.3 

65,792.3 

65,903.9 

68,598.9 

     282,344.8  

           347,977.0  

           351,341.5  

           355,230.4  

     297,878.6  

           387,721.5  

           391,578.3  

           396,102.2  

     317,762.6  

           428,602.8  

           432,933.3  

           438,106.8  

     275,041.5  

           282,184.7  

           285,437.6  

           286,631.5  

     290,575.3  

           321,929.3  

           325,674.4  

           327,503.3  

     310,459.3  

           362,810.5  

           367,029.4  

           369,507.9  

              38.7  

                      5.3  

                      5.3  

                      5.2  

              40.8  

                      5.9  

                      5.9  

                      5.8  

              43.5  

                      6.5  

                      6.6  

                      6.4  

Source: Ricardo et al. (2024), Impact assessment support study 

Sensitivity analysis on odometer fraud.  As explained in  sections 6.1.2.4 and 6.1.3, it should be 
acknowledged that there is uncertainty regarding the economic damage caused by odometer fraud 
and the number of vehicles affected. For this reason, sensitivity analysis has been performed on the 
economic damage caused by odometer fraud and the number of vehicles affected. 

With regard to the economic damage caused by odometer fraud, a central estimate of EUR 2,119 
per vehicle has been used and it is explained in more detail in Annex 4 (section 2). The following 
cases have been assessed: 

-  Low economic damage case: 20% lower damage costs/costs savings per vehicle (EUR 1,696 

per vehicle);  

-  High economic damage case: 20% higher damage costs/costs savings per vehicle (EUR 2,543 

per vehicle).  

256 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
Subsequently, the impacts on the benefits due to avoided odometer fraud and the efficiency of the 
policy options is assessed for the low economic damage and high economic damage case. 

The table below presents the benefits due to avoided odometer fraud for national and cross-border 
sales, in the low economic damage case, central case (i.e. central estimate used in the assessment) 
and high economic damage case.  

Table 258: Benefits due to avoided odometer fraud by policy option in the low economic damage case, central case 
and high economic damage case, expressed as present value over 2026-2050 compared to the baseline (in million 
EUR, in 2022 prices)  

Low economic damage case 

National 
Cross border 

Central case 
National 
Cross border 

High economic damage case 

National 
Cross border 

PO1a 

147,205.9 
52,718.5 
94,487.4 
184,007.4 
65,898.2 
118,109.2 
220,808.9 
79,077.8 
141,731.1 

Difference to the Baseline 
PO1b 

147,205.9 
52,718.5 
94,487.4 
184,007.4 
65,898.2 
118,109.2 
220,808.9 
79,077.8 
141,731.1 

PO2 
147,205.9 
52,718.5 
94,487.4 
184,007.4 
65,898.2 
118,109.2 
220,808.9 
79,077.8 
141,731.1 

PO3 
147,205.9 
52,718.5 
94,487.4 
184,007.4 
65,898.2 
118,109.2 
220,808.9 
79,077.8 
141,731.1 

Source: Ricardo et al. (2024), Impact assessment support study 

The following table presents the impacts on total benefits, net benefits and benefits to costs ratio by 
policy option in  the low  economic damage  case, central  case and high  economic damage case.  It 
shows that all policy options are expected to result in net benefits under the three cases considered. 
It also shows that the ranking of the policy options is not expected to change in the low economic 
damage case and high economic damage case relative to the central case estimates.  

Table 259: Summary of costs and benefits of the policy options in the low economic damage case, central case and 
high economic damage case, expressed as present value over 2025-2050 compared to the baseline (in million EUR, 
in 2022 prices) 

Total costs 
Total benefits 
Low economic damage case 
Central case 
High economic damage case 
Net benefits 
Low economic damage case 
Central case 
High economic damage case 
Benefits to costs ratio 
Low economic damage case 
Central case 
High economic damage case 

 PO1a  

 Difference to the Baseline  
 PO1b  

 PO2  

 PO3  

7,303.3 

65,792.3 

65,903.9 

68,598.9 

261,077.0 
297,878.5 
334,680.0 

253,773.7 
290,575.2 
327,376.7 

35.7 
40.8 
45.8 

350,920.0 
387,721.5 
424,523.0 

285,127.7 
321,929.2 
358,730.7 

5.3 
5.9 
6.5 

354,776.4 
391,577.8 
428,379.3 

288,872.5 
325,674.0 
362,475.4 

5.4 
5.9 
6.5 

359,300.6 
396,102.1 
432,903.6 

290,701.7 
327,503.2 
364,304.7 

5.2 
5.8 
6.3 

Source: Ricardo et al. (2024), Impact assessment support study 

With  regard  to  the  number  of  vehicles  affected,  the  central  assumptions  used  for  the  shares  of 
vehicles with tampered odometers are provided in Annex 4 (section 2), Table 37. The following cases 
have been assessed: 

-  Fewer vehicles affected case: share of affected vehicles 20% lower than in the central case;  

257 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
-  More vehicles affected case: share of affected vehicles 20% higher than in the central case.  

The table below presents the benefits due to avoided odometer fraud for national and cross-border 
sales, in the fewer vehicles affected case, central case (i.e. central estimate used in the assessment) 
and more vehicles affected case.  

Table 260: Benefits due to avoided odometer fraud by policy option in the  fewer vehicles affected case, central 
case  and  more  vehicles  affected  case,  expressed  as  present  value  over  2026-2050  compared  to  the  baseline  (in 
million EUR, in 2022 prices)  

Fewer vehicles affected case 

National 
Cross border 

Central case  
National 
Cross border 

More vehicles affected case 

National 
Cross border 

PO1a 

147,205.9 
52,718.5 
94,487.4 
184,007.4 
65,898.2 
118,109.2 
220,808.9 
79,077.8 
141,731.1 

Difference to the Baseline 
PO1b 

147,205.9 
52,718.5 
94,487.4 
184,007.4 
65,898.2 
118,109.2 
220,808.9 
79,077.8 
141,731.1 

PO2 
147,205.9 
52,718.5 
94,487.4 
184,007.4 
65,898.2 
118,109.2 
220,808.9 
79,077.8 
141,731.1 

PO3 
147,205.9 
52,718.5 
94,487.4 
184,007.4 
65,898.2 
118,109.2 
220,808.9 
79,077.8 
141,731.1 

Source: Ricardo et al. (2024), Impact assessment support study 

The following table presents the impacts on total benefits, net benefits and benefits to costs ratio by 
policy option in  the  fewer vehicles  affected  case, central  case and  more  vehicles affected  case.  It 
shows that all policy options are expected to result in net benefits under the three cases considered. 
It also shows that the ranking of the policy options is not expected to change in the fewer vehicles 
affected case and more vehicles affected case relative to the central case estimates.  

Table 261: Summary of costs and benefits of the policy options in the fewer vehicles affected case, central case and 
more vehicles affected case, expressed as present value over 2025-2050 compared to the baseline (in million EUR, 
in 2022 prices) 

Total costs 
Total benefits 
Fewer vehicles affected case 
Central case  
More vehicles affected case 
Net benefits 
Fewer vehicles affected case 
Central case  
More vehicles affected case 
Benefits to costs ratio 
Fewer vehicles affected case 
Central case  
More vehicles affected case 

 PO1a  

 Difference to the Baseline  
 PO1b  

 PO2  

 PO3  

7,303.3 

65,792.3 

65,903.9 

68,598.9 

261,077.0 
297,878.5 
334,680.0 

253,773.7 
290,575.2 
327,376.7 

35.7 
40.8 
45.8 

350,920.0 
387,721.5 
424,523.0 

285,127.7 
321,929.2 
358,730.7 

5.3 
5.9 
6.5 

354,776.4 
391,577.8 
428,379.3 

288,872.5 
325,674.0 
362,475.4 

5.4 
5.9 
6.5 

359,300.6 
396,102.1 
432,903.6 

290,701.7 
327,503.2 
364,304.7 

5.2 
5.8 
6.3 

Source: Ricardo et al. (2024), Impact assessment support study 

The number of vehicles affected in 2026, 2030, 2040 and 2050 in the fewer vehicles affected case, 
central case and more vehicles affected case is further provided in the table below.  

Table 262: Number of vehicles affected in 2026, 2030, 2040 and 2050 in the fewer vehicles affected case, central 
case and more vehicles affected case  

258 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
Fewer vehicles affected case 
National second hand sales with 
mileage fraud (million vehicles) 
Cross border sales with mileage fraud 
(million vehicles) 
National mileage fraud avoidance 
(million vehicles) 
Cross border mileage fraud avoidance 
(million vehicles) 
Central case 
National second hand sales with 
mileage fraud (million vehicles) 
Cross border sales with mileage fraud 
(million vehicles) 
National mileage fraud avoidance 
(million vehicles) 
Cross border mileage fraud avoidance 
(million vehicles) 
More vehicles affected case 
National second hand sales with 
mileage fraud (million vehicles) 
Cross border sales with mileage fraud 
(million vehicles) 
National mileage fraud avoidance 
(million vehicles) 
Cross border mileage fraud avoidance 
(million vehicles) 

2026 

1.30 

2.55 

1.26 

2.29 

1.63 

3.18 

1.58 

2.87 

1.96 

3.82 

1.90 

3.44 

Difference to the baseline 

2030 

2040 

1.37 

2.68 

1.33 

2.41 

1.71 

3.35 

1.66 

3.01 

2.06 

4.02 

1.99 

3.61 

1.52 

2.87 

1.48 

2.58 

1.90 

3.59 

1.85 

3.23 

2.28 

4.30 

2.22 

3.87 

2050 

1.52 

2.91 

1.47 

2.62 

1.90 

3.64 

1.84 

3.28 

2.28 

4.37 

2.21 

3.93 

Source: Ricardo et al. (2024), Impact assessment support study 

In addition, the combined impact of the economic damage caused by odometer fraud and vehicles 
affected has been assessed as follows: 

-  Low economic damage and vehicles affected case: 20% lower damage costs/costs savings per 
vehicle (EUR 1,696 per vehicle)  and the share of affected vehicles  20% lower than in the 
central case;  

-  High economic damage and vehicles affected case: 20% higher damage costs/costs savings 
per vehicle (EUR 2,543 per vehicle) and the share of affected vehicles 20% higher than in the 
central case.  

Subsequently, the impacts on the benefits due to avoided odometer fraud and the efficiency of the 
policy options is assessed for the low economic damage and vehicles affected case and for the high 
economic damage and vehicles affected case. 

The table below presents the benefits due to avoided odometer fraud for national and cross-border 
sales, in the low economic damage and vehicles affected case, central case (i.e. central estimate used 
in the assessment) and high economic damage and vehicles affected case.  

259 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 263: Benefits due to avoided odometer fraud by policy option in the low  economic damage  and  vehicles 
affected case, central case and high economic damage and vehicles affected case, expressed as present value over 
2026-2050 compared to the baseline (in million EUR, in 2022 prices)  

Low economic damage and vehicles 
affected case 
National 
Cross border 

Central case 
National 
Cross border 

High economic damage and vehicles 
affected case 
National 
Cross border 

PO1a 

Difference to the Baseline 
PO1b 

PO2 

PO3 

117,764.7 

117,764.7 

117,764.7 

117,764.7 

42,174.8 
75,589.9 
184,007.4 
65,898.2 
118,109.2 

42,174.8 
75,589.9 
184,007.4 
65,898.2 
118,109.2 

42,174.8 
75,589.9 
184,007.4 
65,898.2 
118,109.2 

42,174.8 
75,589.9 
184,007.4 
65,898.2 
118,109.2 

264,970.6 

264,970.6 

264,970.6 

264,970.6 

94,893.4 
170,077.3 

94,893.4 
170,077.3 

94,893.4 
170,077.3 

94,893.4 
170,077.3 

Source: Ricardo et al. (2024), Impact assessment support study 

The following table presents the impacts on total benefits, net benefits and benefits to costs ratio by 
policy option in the low economic damage and vehicles affected case, central case and high economic 
damage  and  vehicles  affected  case.  It  shows  that  all  policy  options  are  expected  to  result  in  net 
benefits under the three cases considered. It also shows that the ranking of the policy options is not 
expected to significantly change in the low economic damage and vehicles affected case and high 
economic damage and vehicles affected case relative to the central case estimates.  

Table 264: Summary of costs and benefits of the policy options in the low economic damage and vehicles affected 
case, central case and high  economic damage and  vehicles affected case, expressed as present value over 2025-
2050 compared to the baseline (in million EUR, in 2022 prices) 

Total costs 
Total benefits 
Low economic damage and vehicles 
affected case 
Central case 
High economic damage and vehicles 
affected case 
Net benefits 
Low economic damage and vehicles 
affected case 
Central case 
High economic damage and vehicles 
affected case 
Benefits to costs ratio 
Low economic damage and vehicles 
affected case 
Central case 
High economic damage and vehicles 
affected case 

 PO1a  

 Difference to the Baseline  
 PO1b  

 PO2  

 PO3  

7,303.3 

65,792.3 

65,903.9 

68,598.9 

231,635.9 

321,478.8 

325,335.2 

329,859.5 

297,878.5 

387,721.5 

391,577.8 

396,102.1 

378,841.8 

468,684.7 

472,541.1 

477,065.4 

224,332.5 

255,686.6 

259,431.3 

261,260.6 

290,575.2 

321,929.2 

325,674.0 

327,503.2 

371,538.5 

402,892.5 

406,637.2 

408,466.5 

31.7 

40.8 

51.9 

4.9 

5.9 

7.1 

4.9 

5.9 

7.2 

4.8 

5.8 

7.0 

Source: Ricardo et al. (2024), Impact assessment support study 

260 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
8.  TESTING TECHNOLOGIES 

It  should be noted that most  of the technologies required for more advanced testing  in  the policy 
measures are available. However certain test methods need to be developed. This is true for electric 
vehicles, advanced driver assistance systems, as well as for testing the emissions of modern vehicles. 
Although electric vehicles have now been subject to PTI for some time, the PTI Directive has no 
specific  provision  to  test  high-voltage  systems  and  thus  the  risks  associated  with  them.  Certain 
Member States have applied their own test methods but there is scope for harmonising the items to 
be checked as well as the methods used. An overview of the main technologies/test methods relevant 
for specific measures is provided in the table below. 

Table 265: Technology/methods required by specific policy measures 

Measure   Technology/test  procedure 

Current status  

required  

PMC1 

Visual testing and tools to 
measure insulation 
resistance and equipotential 
bonding 

This  technology  and  equipment  already  exists  (see  for  example: 
https://www.hioki.com/euro-
en/learning/applications/detail/id_n1265994) – a number of stakeholders 
confirmed this (e.g. TUV, ARBO, CITA, FSD) but indicated that they do 
not take place in general as this is not required for roadworthiness testing. 

See also: https://citainsp.org/wp-
content/uploads/2023/06/CITA_WP_BEV_REV1_15062023_FINAL.p
df  

A recent proposal from FR focused on visual inspection on the basis that 
this is faster/cheaper and, in FR’s view, sufficient.   

PMC2 

PTI scan tool 

Already exists and being used, though not as widely and regularly as it 
could be. 

PMC3 

PN testing equipment 

PTI centres are required to have scan tools since May 2023 only and their 
use is optional. As such, only a few MSs have made use of it for testing 
electronic  safety  systems  or  checking  the  status  of  emission  control 
systems. An ISO standard describing the checks of safety-related systems 
has only been developed recently. 

Already exists and has been used by three Member States that have made 
PN testing a requirement. Most other Member States did not indicate a 
clear intention to introduce these existing test methods as requirement. 

PMC4 

NOx testing equipment and 
standardised testing 
procedure  

NOx testing procedures exist but JRC is still working on a test method. 
Current experience (e.g. Flanders) suggest that this is expensive but over 
time and with large scale adoption costs may come down. 

Cost can also be a barrier for PTI adoption given the consideration that 
PTI should not be an expensive test. The intention is to combine this test 
with the PN test. 

Generally available  – not barrier/issue for adoption besides investment 
costs  

Relevant equipment and testing methods are in place and used in some 
Member States (according to SE, DE authorities and CITA). Reason for 
no broader adoption is mainly the cost. 

PMC6 

PM7 

Digital technology for 
electronic roadworthiness 
certificate  

Need to apply advanced 
testing of suspension 
(damping efficiency of 
shock absorbers) for all 
vehicles and specific 

261 

 
 
Measure   Technology/test  procedure 

Current status  

required  

braking test (extrapolation 
method) for HDVs.  

PM10 

PM12 

Advance noise testing 
similar to pass-by noise test 
described in the UN 
Regulation no. 41 

Existing technology already used in some Member States (DE, ES, HR 
and SK). A barrier for broader adoption is the cost of equipment and/or 
requirements  for  ensuring  silence  (according  to  Dutch  authorities, 
EGEA) that may require additional investment. 

Remote sensing, plume 
chasing equipment for NOx 
and PM and acoustic 
cameras for noise 

Technologies already exist and also methodologies are in place. 

Main  barrier  for  adoption  is  the  reliability  of  the  methods  along  with 
investment cost, and the fact that they are not seen by some stakeholders 
as  replacing  PTI  (e.g.  TUV  (DE),  AECA-ITV  (BE))  but  as 
complementary (AEEC refers to a few member states (DK, BE) that have 
tried remote sensing or plume chasing). There is no clear indication of 
expected  broader  uptake  at  Member  State  level.  FI  indicated  that  the 
approach should not become mandatory and ES that they do not see this 
as priority for RSI.  

PM16 

No specific technologies 
needed – digital 
technologies already in 
place 

Barrier  for  broader  adoption  is  the  cost/investment  needed.  Most 
authorities supported the measure in principle but proposed that it should 
not  be  mandatory  (e.g.  NL,  DE,  FI,  SI,  NO,  SK,  LV)  although  others 
prefer it to be mandatory (ES, SE, HR). 

262 

 
 
 
ANNEX 5: COMPETITIVENESS CHECK 

1.  OVERVIEW OF IMPACTS ON COMPETITIVENESS  

Dimensions of 
Competitiveness 

Impact of the initiative 
(++ / + / 0 / - / -- / n.a.) 

References to sub-sections of the 
main report or annexes 

Cost and price competitiveness 

International competitiveness  

Capacity to innovate 

SME competitiveness 

0/+ 

n.a. 

+ 

0/+ 

6.1.2, 6.1.4 and Annex 4 (section 3) 

n.a. 

6.1.5 

6.1.6 and Annex 10 

2.  SYNTHETIC ASSESSMENT  

Cost and price competitiveness 

PTI  centres  and  businesses  that  own  and  use  light  and  heavy-duty  vehicles  are  expected  to  face 
significant costs related to additional testing requirements and data governance in PO2. Total one-
off costs for PTI centres have been estimated at  EUR 3.3 billion. Recurrent costs are expected to 
amount  to  EUR  20.2  billion  for  PTI  centres  and  EUR  25.7  billion  for  other  businesses  (vehicle 
owners), expressed as present value over 2026-2050 relative to the baseline. Vehicle manufacturers, 
and  garages  will  face  comparatively  lower  costs  (one-off  costs:  EUR  20  million  for  vehicle 
manufacturers and EUR 149.2 million for garages; recurrent administrative costs: EUR 35.9 million 
for vehicle manufacturers and EUR 310.8 million for garages). 

At  the  same  time,  PTI  centres  will  benefit  from  administrative  cost  savings  (EUR  1.6  billion, 
expressed  as  present  value  over  2026-2050  relative  to  the  baseline)  and,  more  importantly,  the 
expectation of new business creation and thus revenues (EUR 39.1 billion). Total net benefits for PTI 
centres are estimated at EUR 17.3 billion, expressed as present value over 2026-2050 relative to the 
baseline. As shown in section 6.1.2.1 (Table 11), net benefits per PTI centre would represent around 
6.3% of the turnover. It is further expected that PTI centres may be able to pass on the incurred costs 
related to investments in equipment to vehicle owners (businesses and citizens). This will vary from 
Member State to Member State and depend on whether PTI prices are regulated or not, as well as on 
the type of contract/agreement PTI providers have with the competent national authority. Thus, PO2 
is expected to lead to an increase in the profitability of PTI centres. 

As explained above, additional costs are expected to arise for businesses that own and use light and 
heavy-duty vehicles, either because of the expected increase in the frequency and costs of PTI or the 
extra  time  spent  during  roadside  inspections.  These  will  be  more  than  counterbalanced  by  cost 
savings  and  other  benefits,  in  particular  by  the  benefits  due  to  avoided  odometer  fraud.  The  net 
benefits  for  businesses  that  own  and  use  light  and  heavy-duty  vehicles  are  estimated  at  EUR  94 
billion, expressed as present value over 2026-2050 relative to the baseline. 

Vehicle manufacturers and garages will face comparatively lower costs, as explained above, and no 
costs  savings,  resulting  in  net  costs  of  EUR  55.9  million  and  EUR  460  million,  respectively, 
expressed as present value over 2026-2050 relative to the baseline.  

263 

 
 
 
International competitiveness 

This initiative has no evident impact on the international competitiveness of EU businesses related 
to the provision of PTI services that need to take place in the EU. Non-EU businesses in the specific 
sector  cannot  be  expected  to  benefit.  Since  the  corresponding  test  requirements  would  be  first 
introduced in  the EU,  garage equipment  and other testing  equipment  manufacturers  could  benefit 
from  a  possible  first  mover  advantage  that  can  also  arise  for  EU  manufacturers.  However,  the 
measures and requirements should apply equally to European and non-European manufacturers, to 
the extent that they have equal access to the EU market on the basis of the EU standards. Finally, EU 
based transport operators and other business that use vehicles on a frequent basis may experience 
some  extra  costs  as  a  result  of  the  more  demanding  measures  and  time  spent  during  roadside 
inspections  but  would  at  the  same  time  benefit  significantly  from  the  avoided  odometer  fraud. 
Transport operators from third countries active in Europe may benefit from some reduced PTI costs 
in comparison to their EU competitors although they can still be subject to roadside inspections by 
authorities.  

Put  together,  there  is  no  evidence  of  a  strong  positive  or  strong  negative  impact  on  international 
competitiveness. Businesses in equipment manufacturing sectors may benefit from the first mover 
advantage while transport operators may face stricter PTI requirements that will not arise for their 
counterparts outside Europe but active in Europe. Those non-EU hauliers will however equally be 
subject to more advanced roadside inspections. These positive or negative impacts are expected to 
be limited. 

Capacity to innovate 

As  explained  in  section  6.1.5,  positive  impacts  on  innovation  are  expected  from  requiring  more 
stringent and advanced test methods that also need to be adjusted to the general requirement for a 
PTI to be quick, simple and affordable. The initiative would provide garage and testing equipment 
manufacturers with new opportunities, mainly on the basis of increased demand that will arise from 
the  implementation  of  the  policy  measures.  The  measures  outlined  will  largely  rely  on  existing 
measurement and testing technologies, which are not expected to require significant innovation in 
design. However, they can still be expected to require adaptations and further improvements to meet 
the needs of PTI and roadside inspections, facilitating process innovation. There will also be a need 
to  establish  and  implement  the  accompanying  standards  for  the  widespread  adoption  of  the 
measurement and testing methods related to NOx and PN measurements, remote sensing, the use of 
ePTI and noise measurement, which can further facilitate their adoption but can also provide the basis 
for  the  development  of  alternative,  competing,  solutions.  To  the  extent  that  there  is  eventually  a 
broader  adoption  of  such  technologies,  a  possible  first  mover  advantage  can  arise  for  EU 
manufacturers.  However,  in  principle,  it  should  benefit  equally  European  and  non-European 
manufacturers, to the extent that they have equal access to the EU market based on the EU standards 
set.  

The consulted stakeholders expect a positive impact on the innovative capacity of the sectors affected 
from  measures  related  to  new  PTI/RSI  test  requirements,  improved  access  and  exchange  of 
information and the digitalisation of vehicle documents. 

Furthermore,  increased demand for new test methods and equipment  can be expected to  generate 
further development of relevant technologies by developers of measurement equipment, a viewpoint 
supported by the representatives of the sector in their contribution to the stakeholder consultation. 

264 

 
 
Together  with  that,  relevant  training  of  inspectors  to  the  new  test  methods  will  enhance  the 
availability of technical skills and expertise that can have a broader positive impact. As such, most 
of the common measures are expected to have some positive impact on innovation (PMC1 on the 
testing of electric vehicles, PMC2 using ePTI, PMC3 and PMC4 on new emission tests, PMC6 on 
digital PTI certificates, and PMC7 on more efficient exchange of vehicle data). 

While in the case of PO1a the digitalisation of the registration certificates (PM16) may require further 
innovation,  PO1b  would  introduce  remote  sensing  and  plume  chasing  (PM12)  to  monitor  air 
pollutants  and  noise  emitted  by  vehicles.  Remote  sensing  also  relies  on  existing  technologies  but 
requires adaptations to scale them up to cover the desired share of the vehicle fleet. Deploying these 
technologies at a larger scale than today would also necessitate process innovation. PO2 and PO3 
combine the benefits of both measures. 

SME competitiveness 

As explained in Annex 10 and in section 6.1.6, for PTI centres, while it was not possible to split the 
costs and benefits between SME and others due to the lack of data, a large part of costs and benefits 
are expected to be attributed to SMEs. In PO2, net benefits for PTI centres are expected to represent 
around 6.3% of the turnover. 

Garage  equipment  manufacturers  are  expected  to  benefit  from  additional  business  opportunities 
linked to higher demand for testing equipment, although such impacts were not possible to quantify. 

Garages, motor vehicle dealers, tyre and repair workshops, etc., mostly SMEs, will be affected by 
the requirement for Member States to set up a system to record odometer readings from the cars and 
vans registered in their territory (PMC9). As explained in section 6.1.2.2, total one-off and recurrent 
administrative costs would amount to EUR 460 million (EUR 706 per company), expressed as present 
value over 2026-2050. 

For  businesses  owning  vehicles,  as  explained  in  section  6.1.2.4,  PO2  is  expected  to  result  in  net 
benefits  estimated  at  EUR  94  billion,  expressed  as  present  value  over  2025-2050  relative  to  the 
baseline. Based on the available information, it was however not possible to assess how many of the 
businesses owning vehicles are SMEs. Only few of the measures in PO2 are expected to affect the 
road haulage sector largely composed of SMEs (e.g.,  PM13 on cargo securing inspections, which 
would result in minimal costs, while hauliers could also benefit from the savings of avoided emission 
tests at PTI after having passed a RSI or a remote sensing check). The overall impact on the road 
haulage sector is expected to be limited but rather positive, although the available data did not allow 
a split of the costs and benefits between the two groups of operators (i.e., SME and others). 

265 

 
 
 
 
ANNEX 6: BACKGROUND ON ROADWORTHINESS LEGISLATION AND PTI 
ORGANISATION IN MEMBER STATES 

This annex provides background information related to:  

• 
• 
• 

the evolution of the EU roadworthiness legislation; 
the way PTI is organised in Member States; 
the average prices of PTI in Member States. 

1.  EVOLUTION OF EU ROADWORTHINESS LEGISLATION 

Figure 9: Road safety policy and PTI in the EU 

Source: EUR-Lex, DEKRA presentation, CITA International Conference 2023, Rotterdam 

266 

 
 
  
 
2.  ORGANISATION OF PTI IN MEMBER STATES 

Table 266: Periodic technical inspection in Member States, passenger cars 

Conducted by 

Country 

Country 

Austria 

Frequency  
(in years) 
3-2-1-1- 

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- 

A 

B 

B 

B 

Ireland 

Italy 

Latvia 

Malta 

Lithuania 

3-2-2-2 

Luxembourg 

4-2-1-1- 

Frequency 
(in years) 
4-2-2-2-1-1 

4-2-2-2- 

Conducted by 

B 

D 

B 

B 

2-2-1-1-  

B & C & D 

4-2-2-2- 

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

B 

A 

B 

B 

Denmark 

4-2-2-2- 

The Netherlands 

Estonia 

Greece 

Spain 

4-2-2-2-1 

B 

Poland 

3-2-1-1- 

4-2-2-2- 

4-2-2-2-1- 

B & D 

B & D 

Portugal 

4-2-2-1- 

Romania 

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

B & D 

Finland 

4-2-2-2-1- 

B 

Sweden 

3 years – 2 years – 
14  months  –  14 
14 
months 
months 

– 

France 

Croatia 

4-2-2-2- 

2-1-1-1- 

B 

B 

Slovenia 

4-2-2-1- 

Slovakia 

4-2-2-2- 

Hungary 

4-2-2-2- 

B & D 

B 

B 

B 

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 
Sources:  https://road-safety.transport.ec.europa.eu/road-safety-member-states/roadworthiness-certificate-and-proof-
test_en, https://www.ereg-association.eu/publications/the-vehicle-and-driver-chain-in-europe/  

267 

 
 
 
 
 
 
 
 
 
 
3.  OVERVIEW OF PTI CONSUMER PRICES IN EU MEMBER STATES 

Table 267: PTI consumer prices by Member State 

MEMBER 
STATE 

PTI PRICE LIGHT VEHICLES 

PTI PRICE HEAVY 
VEHICLES 

REFERENCES 

Austria 

Vary from garage to garage: 

Petrol and Diesel cars  

€49.70 – 125.70 (average €82.38) 

Members  of  ÖAMTC  €49,70.  Members  of 
ARBÖ €59,90  

Electric cars 

€49,70 – 131,04 (average: €84,69 

Vary from deals between garage 
and transport businesses 

 Authority interview  

https://wien.arbeiterkammer.at/be
ratung/konsumentenschutz/auto/2
02305_KFZ-Pickerlkosten.pdf  

Belgium 

38.2€ (VAT 21% included)  

68.1€ (VAT 21% included)  

+ 4.90 (spark ignition) 

+ 14.60 (diesel) 

Bulgaria 

 For M1 vehicles the price including VAT is 50 
BGN (approx. 25,58 €) 

 For  M2  and  M3  vehicles  the 
price including VAT is 70 BGN 
(approx. 35,81 €) 

Croatia 

Technical  inspection  of  a  personal  vehicle  – 
20,25 € + VAT 

ECOtest DIESEL – 13,61 € + VAT 

Forms and technical inspection registers 2  – € 
1,24 + VAT (8,78) €Total – 43,88 € 

The price of PTI for L vehicles (without VAT) 
is 12,30 € 

 For PTI of M2 and M3 vehicles, 
the price without VAT (25%) is 
32,55 € 

Cyprus 

For M1 vehicles, the IKTEO (Private Technical 
Inspection 
Vehicles) 
Centres 
fee is 35 € (incl. VAT) 

for 

 For M2 vehicles, the IKTEO fee 
is 65 € (incl. VAT) 

For M3 vehicles, the IKTEO fee 
is 85 € (incl. VAT) 

 https://www.autoveiligheid.be/sit
es/default/files/tarieven_ak_2023.
pdf 

https://www.autocontrole.be/fr/tar
ifs  

https://dekra-
automotive.bg/annual-technical-
inspections 

 VEHICLE 
TECHNICAL 
INSPECTION  AND  VEHICLE 
REGISTRATION 
Price 
(plocice.hr) 

- 

https://narodne-
novine.nn.hr/clanci/sluzbeni/2022
_12_155_2459.html 

 The 
Motor 
(Roadworthiness 
Technical 
Law 
(cylaw.org) 

of  2007 

Vehicles 
and 
Tests 
Inspection  Centres) 
1(I)/2007 

- 

The  4  IKTEOs  licensed  by  the 
Education. 
Ministry 
of 
Transport/Price 
List 
(brief.com.cy) 

Τιμοκατάλογος 
Paralimni 
| 
(motgiovanis.com) 

– 

M.O.T 
Giovanis 

The  МОТ 
vehicle 
(pitsasinsurances.com) 

test:  governmental 
inspection 

Czechia 

Price for regular technical inspection of M1 and 
N1 vehicles: 1 200 CZK (approx. 49,09 €) 

Trailers  category  O1  up 
to 
750kg: 800 CZK (approx. 32,72 
€) 

 Price  list  -  Pronto  STK  s.r.o. 
(stkpraha.cz) 

268 

 
 
  
 
 
MEMBER 
STATE 

PTI PRICE LIGHT VEHICLES 

PTI PRICE HEAVY 
VEHICLES 

REFERENCES 

For category L vehicles (mopeds/motorcycles) 
the price is 800 CZK (approx. 32,72 €) 

Trailers category O2 from 750kg 
to  3500kg:  1100  CZK  (approx. 
44,99 €) 

Denmark 

Varies from garage to garage and depending on 
the time of the day. 

Varies 
from  deals  between 
garage and transport businesses 

In 2016, the average price was €50.  

Estonia 

 M1 vehicles - 43,95/49,95€ 

 M2 vehicles - 53,95/59,95€ 

M3 vehicles - 65,95/71,95 € 

 Authority interview 

https://www.europe-
consommateurs.eu/fileadmin/Med
ia/PDF/PDF_EN/Cross_border_c
ar_purchase_2016/PDF_EN/Coun
try_fact_sheets___purchase/Coun
try_fact_sheets_purchase_FINAL
-DK.pdf  

 Hinnakiri  |  Tehnoülevaatus  al. 
19€ 
Tehnoülevaatus.ee 
| 
(tehnoulevaatus.ee) 

Finland 

Vary from garage to garage – 25-70 EUR 

Authority interview 

France 

 Between 74,85 and 90 € 

 Between 74,85 and 90 € 

Germany 

Vary  from  garage  and  regions,  between  EUR 
133,90 - 145 Euro 

Greece 

 Passenger cars €45-60 

 Trucks (up to 3.5t) €54-70 

Motorcycles €20-35 

Taxi €30-45 

Recheck €3-6 

Hungary 

The price for passenger car inspection is HUF 
21,000-24,000  (EUR  54,68-62,49)  in  the  case 
of  four-wheel  drive  passenger  cars  HUF 
25,000-28,000 (EUR 65,09-72,90). 

Technical examination of trucks 
for  2-4  wheel  drive  vehicles 
costs HUF 22,000-26,000 (EUR 
57,28-67,7)  and  HUF  27,000-
30,000 (EUR 70,30-78,11) 

contrôle 
 Prix 
moncontroletechnique.fr 

technique 

| 

 https://www.handelsblatt.com/un
ternehmen/tuev-kosten-2023-so-
teuer-sind-hauptuntersuchung-
und-abgasuntersuchung-aktuell-
/27005938.html 

 https://www.gocar.gr/news/feed/
28822,Poso_kostizei_to_KTEO.h
tml 

https://www.checkyourcar.gr/ 

 2023  Műszaki  vizsga  ára  (Jármű 
típus szerint) – Qjob.hu 

Ireland 

 55 EUR 

 https://www.rsa.ie 

Italy 

If  performed  by 
the  national  authority 
“Motorizzazione civile”, the cost of PTI is 45 €.  

 Same as light vehicles 

If performed by private inspection centres, the 
cost varies depending on the centre: the average 
the price for cars in 2023 ranges between € 50 
and € 80. 

Example of a cost breakdown of inspection at 
private centres - € 54.95 plus VAT, DMS fees 
and payment commissions: 54.95 € mandatory 
revision  fee  +  12.09  €  VAT  22%  on  the 

269 

https://www.rattiauto.it/it-
it/blog/curiosita/revisione-auto-
2023-prezzi-e-
rimborsi#:~:text=Per%20effettuar
e%20la%20revisione%20auto,eur
o%20e%20gli%2080%20euro 

https://www.revisioneauto.eu/do
mande-frequenti/revisione-auto-
normativa-costi-scadenza-
sanzioni 

 
 
  
  
  
  
MEMBER 
STATE 

PTI PRICE LIGHT VEHICLES 

PTI PRICE HEAVY 
VEHICLES 

REFERENCES 

compulsory audit fee + 10.20 € DMS fee + 1.76 
€ DMS fee payment commission 

Latvia 

Basic test for a vehicle of category M1 - 29,40 
€ 

 Basic  test  for  a  vehicle  of 
category M2- 32,97 € 

test  for  a  vehicle  of 

Basic 
category M3 - 50,19 € 

https://assicurazioni.segugio.it/ne
ws-assicurazioni/revisione-auto-
modalita-scadenze-e-costi-per-il-
2023-
00037311.html#:~:text=In%20par
ticolare%2C%20presso%20la%2
0Motorizzazione,euro%20a%207
9%2C02%20euro. 

Bus  with  a  laden  weight  of  more 
than  5  tonnes  (category  M3)  | 
Payments for technical inspection 
|  Technical  inspection  |  Vehicle 
(csdd.lv) 

Lithuania 

For M1 vehicles prices for technical inspections 
range from 23 to 28,90 € 

 Inspection  of  M2  class  small 
buses – 26, 6 € 

Compulsory 
testing prices | TUVLITA 

roadworthiness 

For motorcycles/mopeds, the price is 11,30 € 

Inspection  of  M3  class  buses, 
trolleybuses – 37,8 € 

of  M3 

Inspection 
class 
connected  buses,  trolleybuses  – 
42,8 € 

Luxembourg 

 64 EUR 

 77 EUR 

Malta 

 VRT  testing  for  car  now  costs  €  30.27,  as 
against the € 25.27 that used to be charged until 
2022 

https://www.snct.lu/clients-
particuliers/tarifs-du-controle-
technique 

Cost of VRT testing up €5 as from 
January - The Malta Independent 

Netherlands 

 Varies from garage to garage (and depends on 
age of vehicle): 

e.g., €42-78.50, or €43.10-52.80 

Varies from garage to garage: 

https://vanabeelen.nl/tarieven 

e.g., €100-193 or €68.10 

https://www.km.be/autokeuring/ta
rieven  

Poland 

 The  cost  of  periodic  technical  inspection  is 
determined  by  the  ministry  and  in  the  case  of 
passenger cars it is PLN 99 (approx. € 21,33). 
Owners  of  vehicles  with  LPG/CNG  gas 
installations pay PLN 162 (approx. 34,90 €) 

Motorbikes: 62 PLN incl. VAT (approx. 13,32 
€) 

 Passenger  cars,  buses  designed 
to carry no more than 15 people 
including  the  driver,  lorries:  98 
PLN incl. VAT (approx. 21,05 €) 

Buses  designed  to  carry  more 
than  15  people  including  the 
driver:199  PLN 
incl.  VAT 
(approx. 42, 75 €) 

 https://beesafe.pl/porady/ile-
kosztuje-przeglad-
samochodu/#:~:text=Koszt%20ok
resowego%20przegl%C4%85du
%20technicznego%20ustalany,z
%20gazem%20kosztuje%20162
%20z%C5%82ote. 

https://www.infor.pl/akt-
prawny/DZU.2004.223.0002261,r
ozporzadzenie-ministra-
infrastruktury-w-sprawie-
wysokosci-oplat-zwiazanych-z-
prowadzeniem-stacji-kontroli-
pojazdow-oraz-
przeprowadzaniem-badan-
technicznych-pojazdow.html 

https://isap.sejm.gov.pl/isap.nsf/D
ocDetails.xsp?id=WDU20042232
261 

270 

 
 
  
MEMBER 
STATE 

PTI PRICE LIGHT VEHICLES 

PTI PRICE HEAVY 
VEHICLES 

REFERENCES 

Portugal 

 Light-duty vehicles: 27.80 € 

 Heavy-duty vehicles: 41,60 € 

Mopeds: 14.00 € 

Romania 

ITP fee Taxi or Driving School = 80 lei (approx. 
16,09 €) 

ITP  fee  Petrol  or  petrol  + LPG  cars  =  120  lei 
(approx. 24,14 €) 

ITP fee Diesel cars = 150 lei (approx. 30,18 €) 

ITP fee Motorcycles = 120 lei (approx. 24,14 €) 

ITP fee Mopeds = 120 lei (approx. 24,14 €) 

fee  Minibuses, 
ITP 
motorhomes, 
vans,  mixed, 
specialised  =  150  lei  (approx. 
30,18 €) 

ITP  fee  Vehicles  with  4x4  all-
wheel  drive  =  150  lei  (approx. 
30,18 €) 

Realizar as Inspeções Periódicas a 
Veículos - ePortugal.gov.pt 

PTI  tariffs  -  periodic  technical 
inspection (itp-automoto.ro) 

Slovakia 

 PTI prices vary greatly between the eastern and 
western areas. As an example, in Bratislava PTI 
price  for  passenger  cars,  vans,  tricycles  and 
quads is 45 € including VAT.  

 In  Bratislava,  the  PTI  price  for 
M2 and M3 vehicles is 70 € 

https://www.dekra.sk/en/pti-
bratislava-petrzalka/ 

Slovenia 

 Passenger car (weight up to 2.5 T): 36,74 € 

 Bus (M2): 84,45 € 

 Roadworthiness tests | AMZS 

Passenger car (weight over 2.5 T): 46,28 € 

Motorcycle  and  quadricycle  (L1  to  L7)  and 
Moped wheel (L1 to L5): 19,09 € 

Coach  articulated 
(M3)  and 
truck and towing vehicles (N3): 
96,86 € 

Spain 

 30,39€ (40,95€ with VAT) 

 49,73€ (64,35€ with VAT) 

 ITVASA - Tarifas de vehículos 

Sweden 

 64 EUR 

Average price across vehicle types 
– CITA survey 

Source: VVA (2023), Evaluation support study and own elaboration 

271 

 
 
  
 
 
 
 
  
 
ANNEX 7: DETAILED DESCRIPTION OF THE RETAINED POLICY 
MEASURES 

1.  COMMON MEASURES INCLUDED IN THE POLICY OPTIONS 

PMC1 – Adapt PTI to electric and hybrid vehicles (safety, environmental 
performance, standardised data), including training of inspectors 

Concerns: Directive 2014/45/EU (PTI) 

The  measure  will  introduce  new  items  to  be  tested  as  part  of  PTI  concerning  vehicles 
equipped  with  high-voltage  systems,  such  as  battery  electric  and  hybrid  vehicles.  The 
following groups of items could be included in Annex I of Directive 2014/45/EU in the 
section referring to electrical equipment: 

•  Visual inspection of the traction battery cover and the batteries; 

•  Visual  inspection  and/or  operation  of  the  high  voltage  wiring  harness  and 

connectors, including the charging cable; 

•  Visual  inspection  and  operation  of  high  voltage  electrical  and  electronic 

equipment; 

•  Anti-starting system: functional check by verifying that the vehicle cannot move 

by itself with the charging cable plugged. 

As in the case of all other test items, deficiencies would be categorised as minor, major or 
dangerous,  depending  on  the  reason  for  failure,  such  as  slightly/heavily  deteriorated  or 
defective items. 

PMC2 – Update PTI and RSI due to new requirements in General Safety Regulation 
and  checking  emission  reduction  systems  (new  test  items,  including  checks  of 
software status/integrity), by reading on-board diagnostics 

Concerns: Directive 2014/45/EU (PTI) and Directive 2014/47/EU (RSI) 

This measure will introduce new items to be tested as part of PTI and RSI using the on-
board diagnostic (OBD) scanners connected to the electronic vehicle interface (OBD port). 
Since May 2023, testing centres are required to be equipped with such scan tools, however, 
their use has been limited so far. The current PTI and RSI Directives do not require the 
actual  use  of  OBD  scanners  but  refer  to  them  as  an  alternative  to  visual  inspection  (of 
warning  devices)  for  the  checking  of  certain  safety  systems,  such  as  anti-lock  braking 
system  (ABS),  electronic  brake  system  (EBS),  Electronic  Power  Steering  (EPS),  the 
functioning of safety belts and airbag systems and the Electronic Stability Control (ESC). 

Thanks to recently developed standards448, it is now also possible to query ePTI-relevant 
system  information,  including  software  identification,  software  integrity,  current  and/or 

448 ISO 20730-1:2021 and 20730-3:2021, https://www.iso.org/standard/73801.html  

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stored values, and to electronically test the safety systems required by the General Safety 
Regulation,  such  as:  automated  lane  keeping  system  (ALKS),  automated  braking, 
intelligent speed assistance, reversing detection with camera or sensors, acoustic vehicle 
alerting to prevent collisions with pedestrians or cyclists, emergency braking signal, or tyre 
pressure monitoring systems. 

Using  ePTI  will  also  allow  checking  additional  safety-relevant  items,  like  automatic 
lighting, adaptative headlights, speed limiter and adaptative cruise control. 

PMC3 - Mandatory PN testing of LDVs and HDVs equipped with particle filter, at 
PTI, and of HDVs at technical roadside inspections of commercial vehicles  

Concerns: Directive 2014/45/EU (PTI) and Directive 2014/47/EU (RSI) 

The  measure  will  require  using  particle  number  (PN)  measurement  for  the  exhaust  gas 
emission testing (item 8.2 in the list of items to be tested under the PTI and RSI Directive). 
This would replace the currently required exhaust gas opacity test first for diesel vehicles 
equipped with particle filters, at PTI, and for HDVs, at technical roadside inspections of 
commercial vehicles. The focus is on these vehicles as they are subject to a solid particle 
number limit at their type-approval (from Euro 5b LDVs and Euro VI HDVs), which is 
used as  a reference point  to  determine the threshold  for high-emitting  vehicles.  In fact, 
three Member States (BE, NL and DE) have already introduced such a test for Euro 5 and 
Euro 6/VI vehicles and the measure is about applying harmonised measurement across the 
EU. In the case of pre-Euro 5 and Euro VI vehicles equipped with DPF, Member States 
would  be  required  to  indicate  the  result  of  emissions  higher  than  the  limit  on  the 
roadworthiness  certificate  to  draw  the  attention  of  the  owner  that  the  filter  needs  to  be 
replaced. Alternatively, e.g., where the vehicle tax is differentiated based on the presence 
or not of a particle filter, Member States may allow to de-register the filter and apply higher 
vehicle taxes to such vehicles. 

The  test  requirements  will  be  based  on  the  procedure  described  in  the  Commission’s 
Recommendation on PN measurement for the PTI of vehicles equipped with compression 
ignition  engines449,  which  allow  for  a  fast,  simple  and  inexpensive  test.  The  use  of  the 
currently recommended pass/fail limit of 250.000/cm3 would be required.  

Initially, older vehicles not equipped with DPF would continue to be checked using the 
currently required opacity testing, which was adapted to the air pollutant emission limits 
of  earlier  standards  (pre-Euro  5).  The  Commission  would  have  to  consult  the 
Roadworthiness Expert Group (RWEG) to investigate the technical feasibility of using PN 
measurement for those vehicles with higher thresholds, while ensuring that this does not 
generate disproportionate costs, notably through the need to replace existing equipment. 

Since the equipment used for PN-measurement are portable devices, the same test method 
can be applied at roadside inspections, including for checks following the identification of 
a high-emitting vehicle using remote sensing technology (required by PM13). 

449 https://eur-lex.europa.eu/eli/reco/2023/688/oj  

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Later, once the corresponding test method is developed for testing vehicles equipped with 
positive ignition engines, PN measurement should also be extended to them. As soon as 
sufficient  data  from  tailpipe  emission  testing  at  PTI  and  readings  from  the  on-board 
monitoring  system  (OBM)  of  Euro  7  vehicles  provide  confidence  as  regards  the 
equivalence of OBM with tailpipe tests, Member States may authorise the use of OBM 
only. 

PMC4 - Mandatory  NOx-testing of LDV and HDV at PTI,  and HDVs at roadside 
inspections 

Concerns: Directive 2014/45/EU (PTI) and Directive 2014/47/EU (RSI) 

Similar to PN testing under PMC3, this measure will require the testing of NOx emissions 
at PTI and RSI for light and heavy vehicles, first for diesel, focussing on the identification 
of malfunctioning SCR systems. Later, once the test method is adapted to positive ignition 
engines,  also  vehicles  powered  by  petrol  and  liquefied  or  compressed  natural  gas 
(LNG/CNG) could be tested. The test procedure has been developed by the Commission’s 
Joint  Research  Centre450  with  the  technical  and  metrological  requirements  of  the 
instruments and a NOx threshold value expected to be defined by the end of 2023. The 
measure would therefore likely be implemented through a delegated act amending point 
8.2 in the list of items to be tested under the PTI and RSI Directives. 

The test procedure is being set up in a way that it aligns with the procedure applied for PN 
testing, in order to allow for simultaneous PN and NOx testing, which in the future could 
also be performed using one single instrument featuring both particle and NOx analysers. 
This will allow keeping the testing time as it is today and limit the additional equipment 
costs. 

As in the case of PN testing, as soon as sufficient data from tailpipe emission testing at PTI 
and  readings  from  the  on-board  monitoring  system  (OBM)  of  Euro  7  vehicles  provide 
confidence as regards the equivalence of OBM reading with tailpipe tests, Member States 
may authorise the use of OBM only. 

PMC5 - Mandatory roadworthiness testing following significant modifications of the 
vehicle (e.g. change of class, propulsion system)  

Concerns: Directive 2014/45/EU (PTI)  

This measure will require vehicles that have undergone major technical modifications to 
pass  a  roadworthiness  test.  Such  modifications  may  include  changes  to  the  propulsion 
system, retrofitting the emission control system, modifications to the chassis, wheels and 
tyres and/or the engine  performance of the vehicle and may thus  have both  safety- and 
emissions-related impacts. 

PMC6 – Require the roadworthiness certificate in electronic format only 

450 https://www.mdpi.com/1996-1073/16/14/5520  

274 

 
 
 
Concerns: Directive 2014/45/EU (PTI)  

the  current  PTI  Directive  allows 

the  use  of  “electronically  produced” 
While 
roadworthiness  certificates,  it  requires  a  certified  printout  to  be  handed  to  the  person 
presenting  the  vehicle  for  PTI.  The  measure  will  limit  the  requirement  to  issuing  an 
electronic document only, while providing a printout will be left as an option for Member 
States. 

The exchange of PTI-related data under PMC7 will allow enforcing authorities to check 
the status of any vehicle registered in the EU in the case of a roadside check or for the 
purpose of re-registration, without the need for the owner of the vehicle to present a printed 
certificate. 

PMC7 – Provide electronic access to relevant data, including on PTI reports stored 
in national databases, to the registration authorities of other EU Member States using 
a common interface 

Concerns: Directive 2014/46/EU (VRD) 

The  current  VRD  Directive  requires  that  Member  States  assist  each  other  in  the 
implementation of the Directive and indicates that this may be done by exchanging vehicle-
related information by electronic means. However, it does not specify the means and does 
not  actually  require  such  data  exchange.  This  measure  will  require  that  Member  States 
provide access to other Member States requesting registration or PTI-related vehicle data 
for the vehicles registered in their territory. Such exchanges already take place on bilateral 
basis using EUCARIS451, albeit this is not systematically the case for every Member State. 

In  order  to  facilitate  the  data  exchange,  the  measure  would  require  Member  States  to 
connect their national databases (vehicle registers and related PTI databases as the case 
may  be)  to  the  MOVE-HUB  platform  developed  and  run  by  the  Commission  for  the 
purpose of exchanging various road transport-related information among Member States. 

The EUCARIS peer-to-peer network and the Commission’s hub-and-spoke network are 
the connectivity layer to send messages from one Member State to another – there is no 
significant difference in the development effort between the two. When implementing a 
new message type, Member States have two options, they can develop their own software, 
or they can use the EUCARIS module for that message type. This choice is independent 
of the routing of the messages via the hub. 

The methodology of the EUCARIS software sending messages via MOVE-HUB is well 
known  and  already  implemented  for  in  similar  road  transport  related  applications  like 
ERRU,  RSI,  ProDriveNet  and  TACHOnet;  for  these  solutions  it  is  specified  in  the 
corresponding  legislation  that  messages  must  be  routed  via  the  hub.  RESPER  and  the 
ODOCAR pilot use a hybrid solution, routing messages both on the EUCARIS peer-to-
peer network and via the hub. 

451 https://www.eucaris.net/  

275 

 
 
 
The  Proposal  for  the  ELV  Regulation  referred  to  in  section  1  would  also  require  that 
messages between national (registration) authorities and customs are routed via MOVE-
HUB for the purpose of determining whether or not a vehicle is eligible for export, i.e.,, 
roadworthy is based on the information from the Member State where it was last registered. 

The use of MOVE-HUB for message routing over EUCARIS is based on the following 
considerations: 

•  The Commission has the competence to enforce the application of EU legislation; 

•  MOVE-HUB can monitor the exchange for compliance with the legislation; 

•  The Commission can follow-up message exchange errors with Member States. 

In both cases, there is no need to develop additional software to gather messaging statistics. 
In addition, the fact that the hub is a single point of failure (a possible disadvantage over a 
peer-to-peer  network),  is  mitigated  by  relying  on  the  Commission’s  highly  redundant 
network layer and by having redundant servers in the application layer. 

PMC8  –  Harmonisation  and  regular  update  of  the  technical  data  in  the  vehicle 
registration documents (of currently optional content) 

Concerns: Directive 2014/46/EU (VRD) 

Apart  from  a  set  of  mandatory  data  elements  to  be  included  in  vehicle  registration 
documents, the VRD Directive also provides for a series of optional elements that Member 
States  include  or  not  according  to  their  needs  and  preferences,  taking  into  account  the 
limited space on the currently required physical registration certificate. Optional data items 
include  e.g.  the  vehicle  category,  the  number  of  axles,  data  about  the  environmental 
performance of the vehicle, etc. For example, item V.7 of the registration certificates refers 
to CO2 emissions (in g/km for light vehicles), but it does not specify whether this should 
be the emissions measures in accordance with the NEDC or the more recent WLTP testing 
procedures452. 

The measure aims at harmonising the set of data included in vehicle registration documents 
and  provides  for  their  update  in  case  relevant  vehicle  characteristics  change  due  to 
modifications  (e.g.,  to  the  engine,  the  chassis,  or  the  emission  control  system).  This 
requires the harmonisation of those data items in national vehicle registers and their update 
as soon as they are modified. 

As indicated in the evaluation, there is also a need to align certain data elements with the 
data elements record in the certificate of conformity. 

PMC9  –  MSs  to  record  odometer  readings  in  a  national  database  and  make  the 
records available to other MSs in the case of re-registration  

Concerns: Directive 2014/45/EU (PTI) and Directive 2014/46/EU (VRD) 

452 Both developed by the UNECE: https://unece.org/press/unece-adopts-more-accurate-fuel-efficiency-and-
co2-test-new-cars-wltp; see also https://www.wltpfacts.eu/  

276 

 
 
 
For the purpose of reducing odometer fraud, the PTI Directive requires the recording of 
vehicle mileage at each PTI and that its manipulation be a punishable offence. However, 
PTIs are only conducted every year at most (in many Member States only every two years), 
with the first PTI taking place only after four years in most cases. A significant part of 
odometer fraud will already have happened by that time since larger price gains can be 
achieved by rolling back the odometers of relatively new vehicles. 

This measure would replicate the national systems established by Belgium (Car-Pass453) 
and the Netherlands (Nationale Auto Pas, NAP)454 across all Member States. Both systems 
collect odometer readings from vehicles in between PTIs and well before the first PTI and 
exchange odometer history data between the national databases. The readings are provided 
by various vehicle repair workshops, including tyre and windscreen repair services as well 
as by manufacturers though their dealer management systems. In Belgium, manufacturers 
provide odometer readings from connected cars at least four times a year. In comparison 
to the Belgian Car-Pass system, PMC9 does not require the issuing of a certificate as part 
of a vehicle transaction455. In the Dutch NAP system, the delivery of the vehicle report is 
free of charge. 

The measure requires that Member States establish such national databases and feed them 
with odometer readings in a similar way. Since the issue is of particular concern in the case 
of  cars  and  vans,  those  vehicles  would  have  to  be  covered  as  a  minimum.  Where  the 
registration  of  a  vehicle  is  moved  to  another  Member  States,  the  Member  State  of 
registration  would  have  to  share  the  mileage  history  of  that  car  or  van  with  the  re-
registering Member States. 

Figure 10: Overview of the Car-Pass system 

453 https://www.car-pass.be/en/about-car-pass  
454 https://www.rdw.nl/en/buying-a-car/tips-for-buying-a-car  
455 This currently costs around EUR 10 in Belgium and provides the main source of revenue to support the 
operation of the system in the country. 

277 

 
 
 
 
 
2.  POLICY MEASURES INCLUDED ONLY IN SOME OF THE POLICY OPTIONS 

PM1  -  RSI  for  heavy/powerful  motorcycles  (L  category  >  125cm3)  as  alternative 
measure, in Member States where they are not subject to PTI (i.e., using the available 
opt-out)  

Concerns: Directive 2014/45/EU (PTI) and Directive 2014/47/EU (RSI) 

The measure would apply to L-category vehicles with an engine displacement exceeding 
125cm3, i.e., vehicles that are currently in the scope of the PTI Directive with a possibility 
for Member States to apply alternative road safety measures instead of PTI. As such, it 
would only affect the Member States that make use of the opt-out456 by requiring that the 
alterative  measure  be  roadside  inspection  for  these  vehicles.  The  share  of  the  vehicle 
subject to RSI every year is must be 5% of the corresponding fleet in the Member States 
concerned. 

PM2 – Mandatory PTI for motorcycles above 125cm3 (remove opt-out) 

Concerns: Directive 2014/45/EU (PTI)  

This measure would simply remove the existing possibility to apply alternative road safety 
measures  instead  of  making  heavy  motorcycles  subject  to  PTI.  Just  like  the  previous 
measures, this would affect a few Member States. It would however leave the choice of 
the frequency of testing to Member States, as it is the case today. 

PM3  –  Extend  PTI  to  all  motorcycles  (i.e.,  incl.  from  50cm3  =  all  L3e,  L4e),  plus 
tricycles (L5e) and heavy quadricycles (L7e)  

Concerns: Directive 2014/45/EU (PTI) 

This measure would extend the scope of the PTI Directive to all motorcycles, i.e., including 
smaller ones from 50cm3 (all L3e, L4e), plus tricycles (L5e) and heavy quadricycles (L7e). 
It would however leave the choice of the frequency of testing to Member States, as it is the 
case today for heavy motorcycles. 

PM4 – Mandatory PTI for light trailers (O1 and O2 categories) 

Concerns: Directive 2014/45/EU (PTI)  

This measure would extend the scope of the PTI Directive to all light trailers, including 
O1  (with  maximum  mass  not  exceeding  750  kg)  and  O2  categories  (maximum  mass 
exceeding 750 kg but not exceeding 3500 kg). It would however leave the choice of the 
frequency of testing to Member States, as it is the case today for heavy motorcycles. 

456 These Member States are BE (only requires a roadworthiness test before selling the vehicle or after an 
accident), FI, IE, MT, NL, PT (only testing vehicles with engines > 250 cm3). France has not introduced PTI 
for motorcycles up to now, but the French authorities have announced the intention to do so in 2024. Denmark 
does not have mandatory PTI but since 1 January 2022 it has introduced roadside inspections. 

278 

 
 
 
PM5  –  Annual  emission  testing  for  light  commercial  vehicles  (N1)  instead  of  the 
currently required 4-2-2- frequency 

Concerns: Directive 2014/45/EU (PTI) 

The measure will increase the minimum frequency of emission testing for vans and require 
annual  testing  from  the  first  year  following  the  date  of  first  registration  of  the  vehicle. 
While a few Member States apply more frequent PTI to vans that the minimum frequency 
required by the PTI Directive (i.e., first test within 4 years of the date of first registration 
and every 2 years thereafter), most Member States apply the minimum requirements. 

As such, it will increase the number of vehicles to be tested per year, however, vehicles 
that are subject only to emission testing would not have to occupy the capacity of PTI lanes 
as such tests can be carried out using the portable measurement devices. 

PM6 – Mandatory yearly testing for vehicles that are 10-year-old or older 

Concerns: Directive 2014/45/EU (PTI)  

The measure will increase the frequency of roadworthiness testing for cars and vans (M1 
and  N1  vehicles)  and  require  annual  PTI  after  10  years  following  the  date  of  first 
registration of the vehicle. As indicated in Annex 6, a number of Member States457 already 
apply yearly PTI to cars and vans beyond a certain age instead of the minimum frequency 
of 2 years following the first PTI required by the PTI Directive. The other 11 MS apply 
the minimum requirements. 

PM7 – PTI certificate issued in any EU MS is recognised by the MS of registration + 
further harmonisation of test methods 

Concerns: Directive 2014/45/EU (PTI) 

Under the current  PTI rules,  for the purposes of free circulation  and of  re-registering a 
vehicle that has already been registered in another Member State, the PTI certificate issued 
in that other Member State must be recognised by each Member State as if it had itself 
issued  that  certificate,  provided  that  the  PTI  certificate  is  still  valid  in  terms  of  the 
frequency intervals established for PTI by the re-registering Member State. 

However,  such  recognition  is  not  required  for  the  purpose  of  complying  with  periodic 
testing  requirements.  In  fact,  the  PTI  Directive  requires  that  PTI  is  carried  out  by  the 
Member State of registration or by bodies or establishments designated and supervised by 
that Member State. 

The  measure  would  require  that  the  Member  State  of  registration  recognises  PTI 
certificates issued in the EU for the purpose of ensuring compliance with periodic testing 
of vehicles, provided that the PTI certificate is still valid in terms of the frequency intervals 
that Member State has established for PTI. In order for such a measure to be agreeable by 
Member  States,  it  is  necessary  to  further  harmonise  the  methods  of  testing  (i.e.  certain 

457 AT, BE, BG, EE, ES, FI, HR, IE, LV, LU, NL, PL, PT, RO, SE and SI. 

279 

 
 
 
items that Member States may currently test in different ways). Examples are brake testing 
for HDVs or efficiency testing of the suspension system. The measure would set specific 
requirements for these items. 

The reason why PTI certificate recognition is currently limited to allowing free circulation 
and re-registration (and it is not allowed to undergo PTI in a Member State other than the 
Member State of registration) is that the stringency of PTIs does differ among Member 
States while testing a relatively stable number of vehicles per year also ensures planning 
certainty for Member States, which is particularly relevant where the PTI service is subject 
to longer term contracts (concessions). Full recognition could lead to PTI shopping, unless 
there is almost full harmonisation of the test methods, which is considered in PM7. PM7 
is only part of the most ambitious option as such level of harmonisation may affect the 
structural organisation of PTI in certain Member States, e.g., advanced suspension testing 
requires more space that may be available in small commercial garages that are responsible 
for conducting PTIs in a number of cases. On the other hand, the recognition of PTIs via 
bilateral  agreements  (PM9)  could  be  a  first  step  towards  further  harmonisation  and 
enhanced free movement. 

PM8 – PTI certificate issued in any EU Member State to be recognised by the MS of 
registration for a period of up to 6 months (for passenger cars only), on the condition 
that the next PTI is conducted in the MS of registration 

Concerns: Directive 2014/45/EU (PTI) 

To further facilitate free movement and not to oblige citizens spending time in a Member 
State other than the Member State of registration of the vehicle they are using to travel 
abroad,  PM8  would  require  the  Member  State  of  registration  to  recognise  the  PTI 
certificate issued in another Member State where the vehicle could undergo PTI when it is 
due. The validity of this certificate could be up to six months. 

The measure applies to passenger cars, on condition that the next PTI is conducted in the 
Member  State  of  registration.  It  would  complement  the  provision  of  the  PTI  Directive 
requiring  that  PTI  is  carried  out  by  the  Member  State  of  registration  or  by  bodies  or 
establishments designated and supervised by that Member State. 

PM9 – PTI in another EU MS recognised by MS of registration based on bilateral 
agreement 

Concerns: Directive 2014/45/EU (PTI) 

PM9 would explicitly allow establishing bilateral agreements between Member States in 
order to recognise each other’s PTI certificates. This measure would leave the choice of 
concluding such agreements and thus recognising PTI certificates issued in other Member 
States. Member States would have the freedom to apply such agreements to any vehicle 
category. The measure would complement the provision of the PTI Directive requiring that 
PTI  is  carried  out  by  the  Member  State  of  registration  or  by  bodies  or  establishments 
designated and supervised by that Member State. 

280 

 
 
 
PM10 – More advanced testing of noise for motorcycles 

Concerns: Directive 2014/45/EU (PTI) 

The current PTI Directive requires subjective evaluation of the noise suppression system, 
“unless the inspector  considers that the noise level  may be borderline, in  which case a 
measurement  of  noise  emitted  by  stationary  vehicle  using  a  sound  level  meter  may  be 
conducted” (point 8.1 of Annex I). The same requirement is included in Annex II of the 
RSI Directive applicable to HDVs, which also indicates that the item “can only be checked 
to some extent without the use of equipment”. 

The  measure  would  require  the  use  of  noise  measuring  equipment  when  the  inspector 
considers that the noise level may be borderline. Such measurement could be inspired by 
the methods described in UN Regulation 41 for pass-by noise tests458, even though not all 
the conditions of such a test applied in the case of type-approval may be fulfilled at PTI 
centres (for example, there may not be sufficient space and whether conditions  will not 
always  be  favourable  to  fully  comply  with  Regulation  41).  Therefore,  a  simplified  test 
should be carried out. Few MSs (DE, ES, HR and SK) are already measuring L-vehicles 
noise emissions at PTI. 

PM11 – Data governance: further define the procedures and the means of access to 
vehicle technical information by testing centres free of charge   

Concerns: Directive 2014/45/EU (PTI) 

Recital  17  of  the  PTI  Directive  explains  the  rationale  behind  this  measure:  “For  the 
inspection of vehicles, and especially for their electronic safety components, it is crucial 
to  have  access  to  the  technical  specifications  of  each  individual  vehicle.  Consequently, 
vehicle manufacturers should provide the data needed for verification of the functionality 
of safety and environment-related components. The provisions concerning access to repair 
and  maintenance  information  should  likewise  be  applied  for  that  purpose,  allowing 
inspection centres to have access to all information necessary for roadworthiness testing. 
The data should include the details that allow the functionality of the vehicle safety systems 
to  be  monitored  in  a  way  that  allows  such  systems  to  be  tested  in  a  periodic  technical 
inspection  environment.  This  is  of  crucial  importance,  especially  in  the  field  of 
electronically controlled systems, and should cover all elements that have been installed 
by the manufacturer.” 

Accordingly, Article 4(3) required the Commission to adopt implementing acts to define a 
set  of technical  information  necessary for roadworthiness  testing  and  for  the use of the 
recommended  test  methods,  and  detailed  rules  concerning  the  data  format  and  the 
procedures  for  accessing  the  relevant  technical  information.  It  also  requires  that 
manufacturers make the technical information available to testing centres and competent 
authorities “free of charge or at a reasonable price” and in a non-discriminatory manner. 

458 Regulation No 41 of the Economic Commission for Europe of the United Nations (UN/ECE) — Uniform 
provisions concerning the approval of motor cycles with regard to noise (OJ L 317 14.11.2012, p. 1, ELI: 
http://data.europa.eu/eli/reg/2012/41/oj) 

281 

 
 
 
In addition, it requires that the Commission examines the feasibility of establishing a single 
point of access for that technical information. 

As  a  result,  Implementing  Regulation  2019/621459  defines  a  basic  set  of  technical 
information  and  lays  down  the  principles  of  the  procedure  for  accessing  such  data  and 
regarding their format, however, it fails to specify them in sufficient detail, leaving a large 
room for manoeuvre to manufacturers to define their own procedures and data formats. 

These  issues,  specifically  regarding  in-vehicle  data  is  being  addressed  by  the  ongoing 
initiative on access to vehicle data, functions and resources460. The proposal on access to 
in-vehicle data should provide for non-discriminatory access to such data in a harmonised, 
machine-readable format, which will be key for vehicle inspection. However, it is unlikely 
that  it  will  specify  the  means  of  data  access  specifically  for  the  purpose  of  vehicle 
inspection, which is the focus of this measure.  

The  specific  requirements  would  be  laid  down  in  an  implementing  act  amending 
Implementing Regulation 2019/621 and would aim at establishing a single point of access 
for  the  necessary  technical  information,  e.g.,  through  an  independent  body  that  would 
collect the vehicle data from manufacturers and distribute it to competent authorities and 
authorised PTI centres. Such a solution has notably been called for by CITA. 

PM12 – NOx, PM, and noise measurement by remote sensing in RSI of all vehicles 
(with option for simplified PTI if vehicle passed recent RSI) 

Concerns: Directive 2014/47/EU (RSI) 

PM12 requires the use of remote sensing technology for measuring NOx, PM, and noise 
emissions of all vehicle types and all emission classes. This will allow the monitoring of 
the emissions of a very significant part of the vehicle fleet, depending on the exact scale 
of implementation in the Member States. It also includes the option for a simplified PTI if 
a  vehicle  successfully  passed  a  recent  RSI  (including  by  remote  sensing).  That  is,  the 
Member  State  of  registration  may  exempt  the  vehicle  from  the  emission  and/or  noise 
testing during the next PTI if the result of the RSI is less than 6 months old. A successful 
RSI result could include not only if the vehicle is stopped and checked at the roadside but 
also if it has passed a (specified number of) emission screening by remote sensing with the 
results consistently showing low emissions. 

The use of stationary remote sensing units may be replaced or complemented by plume 
chasing, which can be a viable alternative, notably to measure NOx emissions from HDVs. 
The  figures  below  illustrate  available  technologies  that  could  be  used  to  fulfil  the 
requirements of PM12 as regards pollutant emissions. Monitoring noise by remote sensing 

459  Commission  Implementing  Regulation  (EU)  2019/621  of  17  April  2019  on  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, https://eur-lex.europa.eu/eli/reg_impl/2019/621/oj  
460  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13180-Access-to-vehicle-data-
functions-and-resources_en  

282 

 
 
 
allows identifying individual noisy vehicles even in dense traffic, as demonstrated by the 
NEMO project461, allowing local and national authorities to take remedial action. 

The introduction of this measure will require remote sensing equipment (for NOx and PM) 
and acoustic cameras (a range of microphones for noise) by national enforcing authorities. 

Figure 11: Remote sensing solutions 

Figure 12: Plume chasing 

Source: MODALES and CARES projects, https://modales-project.eu/wp-
content/uploads/2021/10/ITSWC2021-Beyond-Eco-driving-2-CARES_HERE.pdf 

PM13 – Mandatory inspection of cargo securing  

Concerns: Directive 2014/47/EU (RSI) 

The  current  RSI  Directive  provides  for  the  standards  applicable  to  cargo  securing 
inspections,  however  the  inspection  of  cargo  securing  itself  remains  optional.  As  such, 
Member States have only partially implemented the use of those standards. The measure 
requires Member States to apply the methods described in Annex III of the Directive and 
the inspectors conducting such inspections to undergo appropriate training. 

461 https://nemo-cities.eu/remote-sensing-device-for-noise/  

283 

 
 
 
 
 
 
Following the adoption of the RSI Directive in 2014, the Commission presented guidelines 
for Member States and practitioners on the best practices in cargo securing462 referring to 
various types of cargo. The first principle provided for in Annex III of the RSI Directive 
is illustrated the figure below. 

Figure 13: Forces resulting from acceleration and deceleration that cargo securing must withstand 

Source: Cargo securing for road transport – 2014 European best practices guidelines 

PM14 – Extend the scope of application of roadside inspections to light commercial 
(N1) vehicles 

Concerns: Directive 2014/47/EU (RSI) 

PM14  requires  that  Member  States  apply  technical  roadside  inspection  to  vans,  i.e., 
commercial vehicles with a maximum permissible laden mass not exceeding 3.5 tonnes. 
Since the number of these vehicles in the EU fleet is about four times the number of HGVs, 
a lower target would be applied to them, e.g., 2% instead of the 5% share that Member 
States are supposed to aim for in the case of RSI for HDVs. 

462  European  Commission  (2014),  Cargo  securing  for  road  transport  –  2014  European  best  practices 
guidelines, Publications Office, https://data.europa.eu/doi/10.2832/80373  

284 

 
 
 
 
For testing vans at RSI, largely the same inspection units could be used as for HDVs. RSI 
for  vans  could  be  particularly  useful  to  detect  vehicles  with  defective  emission  control 
systems, including tampered ones, which may relatively easily avoid being caught at PTI. 
The mere fact that a van may be subject to roadside checks is expected to play a deterrent 
role. 

PM15 – Extend the scope of application of roadside inspections to 2- and 3-wheeled 
vehicles (L-vehicles from L3) 

Concerns: Directive 2014/47/EU (RSI) 

This  measure  requires  that  Member  States  apply  technical  roadside  inspection  to 
motorcycles. Taking into account the number of these vehicles in the EU fleet a target of 
1% would be applied. 

RSI  for  motorcycles  could  be  particularly  useful  to  detect  vehicles  with  defective  and 
tampered noise suppression systems, which may very easily avoid being caught at PTI. 
Here again, the fact that motorcycles may be subject to roadside checks is expected to play 
a deterrent role. 

PM16 – Introduce issuing the registration certificates in digital format to gradually 
replace current paper (and smart card) documents 

Concerns: Directive 2014/46/EU (VRD) 

The VRD Directive currently requires that  registration certificates  be  issued  either as a 
paper document or as a smart card. The measure will introduce the requirement to issue 
new registration certificates in a digital format. The technical details of the digital/mobile 
registration certificate will be defined in an implementing act and refer to the relevant ISO 
standards as in the case of the digital driving licence. Just like the mobile driving licence, 
the  digital  registration  certificate  will  rely  on  the  eIDAS  initiative  whose  legislative 
proposal463 is still discussed by the co-legislators and certain technical features are not yet 
consolidated in detail. 

The measure applies to all vehicle categories that are subject to registration in the Member 
States. For the purposes of identifying vehicles in road traffic as well as for re-registration, 
Member States will have to recognise the digital version of the registration certificate. As 
the physical documents, the digital vehicle registration certificate would be used to confirm 
the registration of the vehicle, to check certain technical data about it (the digital version 
could store more data than the paper version), and to allow verification by the authorities. 
With the digital certificate enforcers can have direct access to the vehicle register, and it is 
also significantly easier to update than the physical documents. 

The  figures  below  illustrate  the  processes  involved  in  issuing,  using,  and  updating  the 
digital certificate, and its possible appearance. 

463 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52021PC0281  

285 

 
 
 
Figure 14: Issuing the digital registration certificate 

Figure 15: Layout of a digital registration certificate 

Source:  Presentation by the Federal Ministry for Digital  and Transport, Germany, at the  meeting of the 
Expert Group on Roadworthiness and Vehicle Registration Documents, September 2022 

PM17 – Add new data to the vehicle register – minimum mandatory set (including 
among others: country of 1st registration, registration status, PTI status, changes due 
to transformation)  

Concerns: Directive 2014/46/EU (VRD) 

This measure will provide for a minimum set of mandatory data to be registered by member 
States. New data elements could include among others: 

286 

 
 
 
 
•  Country where the vehicle was registered for the first time; 

•  Vehicle status (e.g. de-registered, temporarily de-registered, suspended, exported, 

end-of-life, destructed) (see below) 

•  PTI status (passed with no or minor defects, limited validity with major defects, 

failed – critical defects) and  

i. 

ii. 

validity of the roadworthiness certificate (including expiry date),  

status  of  the  battery  (for  EVs):  battery  identification  number;  and 
information if the battery has been repaired or replaced; 

•  Changes in documentation or transformation – any important vehicle refurbishment 

to be approved and registered (process not yet harmonised);  

•  For a vehicle which is permanently de-registered, information on the reasons for 
de-registration,  based  on  the  assessment  accompanying  the  proposal  for  the 
revision of the legislation on end-of-life vehicles. 

i. 

Based  on  what  most  Member  States  already  record,  a  longer  list  of  data  items  to  be 
recorded has been proposed by EReg464. 

464  https://www.ereg-association.eu/media/2742/final-report-topic-group-xxi-proposal-on-the-registration-
of-vehicle-data.pdf  

287 

 
 
 
 
 
ANNEX 8: DISCARDED POLICY MEASURES 

The possibility to  adopt  further recommendations or a communication from  the Commission  was 
discarded at early stage as non-regulatory measures could not be sufficiently effective in addressing 
the problems identified and would have limited effect on harmonisation. Most stakeholders, including 
public authorities participating in the open public consultation, agreed that a legislative review of the 
RWP would be more effective (see also Annex 2). 

Out  of  the  more  than  40  policy  measures  discussed  at  five  meetings  with  the  Expert  Group  on 
Roadworthiness and vehicle registration documents (RWEG), the following measures are among the 
discarded ones: 

•  Extending the scope of the PTI Directive to mopeds (vehicle category L1 and L2) was discarded 
due to subsidiarity and proportionality reasons. While making mopeds subject to PTI could have 
significant  positive  impact  on  road  safety  and  air  pollutants  reduction,  these  vehicles  are  used 
locally, and the cost-benefit ratio could vary significantly depending on the specific local context 
(including the electrification of the fleet465, which will significantly reduce the negative impacts 
of these vehicles on air and noise pollution over time). There would be also technical feasibility 
issues  with  such  measure  since  some  Member  States  do  not  require  registration  of  mopeds. 
Therefore, from a subsidiarity and proportionality point of view, the testing of mopeds would best 
be left for Member States to legislate. 

•  Extending the scope of the PTI Directive to agricultural tractors (category T with design speed 
exceeding  40km/h)  was  discarded  as  there  was  not  sufficient  evidence  of  the  road  safety  and 
environmental/health risk posed by these vehicles, due to their limited use of public roads. 

•  Setting  maximum  mileage  limit  between  two  PTIs  (e.g.,  100,000  km/200,000  km)  was 
discarded as there are practical difficulties in monitoring mileage and calling vehicles for tests. It 
could also create additional incentives for odometer tampering. 

•  Requiring a roadworthiness test following a crash with significant damage (affecting the main 
safety components) was not retained on the grounds of the difficulty to find a commonly agreed 
definition for significant damage (legal feasibility). 

•  New test methods - continuous technical inspection (CTI) (for autonomous vehicles) was not 
retained as it was considered by the experts of the RWEG to be premature to define such methods 
at this stage of autonomous mobility development.  

The table below provides the full list of discarded policy measures (13) and the reason for discarding 
them. 

Table 268: Discarded policy measures and the reason for discarding them 

Measure 

Reason for being discarded 

Extend scope of RWP to mopeds (i.e.L1e-B and 
L2e) 

There are technical feasibility issues with such measure since some 
Member States do not require registration of mopeds. Moreover, 
these vehicles are used locally, and the cost-benefit ratio could vary 

465 For example, in the Netherlands, the share of electric mopeds in the sales of mopeds increased from 3% in 2017 to 
46% in 2022. The share in the EU was 34% in 2022. 

288 

 
 
 
Measure 

Reason for being discarded 

significantly depending on the specific local context (including the 
electrification  of  the  fleet,  which  will  significantly  reduce  the 
negative impacts of these vehicles on air pollution over time). Due 
to subsidiarity and proportionality point of view, this measure was 
discarded.  

Extending  the  scope  of  the  PTI  Directive  to 
agricultural  tractors  (category  T  with  design 
speed exceeding 40km/h) 

There  was  not  sufficient  evidence  of  the  road  safety  and 
environmental/health  risk  posed  by  these  vehicles  due  to  their 
limited use of public roads. 

Setting  maximum  mileage  limit  between  two 
PTIs  (maximum  limit  to  be  determined  e.g. 
100,000 km/200,000 km) 

There are  practical difficulties in monitoring mileage and calling 
vehicles  for  tests.  It  could  also  create  additional  incentives  for 
odometer tampering. The measure was discarded due to technical 
feasibility reasons. 

To  make  PTI  mandatory  before  transfer  of 
ownership of a vehicle 

The  PTI  Directive  requires  that  the  roadworthiness  certificate  be 
recognised,  as  a  matter  of  principle,  “in  the  event  that  the 
ownership of the vehicle – having a valid proof of roadworthiness 
test – changes”.  There  are also practical questions as regards the 
implementation  of  such  a  measure  (length  of  validity  of  a  new 
certificate required before sales). Limited support among Member 
States. Discarded due to unnecessary burden on vehicle owners and 
lack of evidence regarding potential benefits.  

PTIs  mandatory  for  crashed  vehicles  with 
significant  damage  (affecting  the  main  safety 
components) 

Difficulties in defining significant damage in a consistent way and 
limited  support  among  stakeholders  during  the  consultations. 
Discarded due to legal and political feasibility reasons. 

To require that PTI certificate issued in a third 
country outside the EU is recognised by MS of 
registration 

No  support  among  Member  States  authorities  during 
the 
consultations. Difficulties to monitor/ensure quality of PTI in third 
countries.  Discarded  due  to  technical  and  political  feasibility 
reasons. 

To  require 
that  results  of  on-board  fuel 
consumption  monitoring  (OBFCM  required  by 
Regulation  2021/392)  are  reported  on  the  PTI 
certificate 

Measure  considered  not  directly 
the  RWP. 
Nevertheless, Member States are not prevented from reporting that 
information on the PTI certificate. 

relevant 

for 

Require  more  advanced  testing  of  braking 
(regenerative braking) 

Limited  support  and  considered  as  not  relevant  from  the  vehicle 
roadworthiness perspective (rather a question of energy efficiency) 

New 
test  methods  -  continuous 
inspection (CTI) (for autonomous vehicles) 

technical 

Considered by the experts of the RWEG to be premature to define 
such  methods  at  this  stage  of  autonomous  mobility  development 
(technical feasibility reasons).  

Extend  the  scope  of  application  of  roadside 
inspections to motorhomes 

Very  limited  expected  impact  and  very  limited  support  among 
Member States authorities.  

Improve  administrative  processes  regarding 
handling prohibitions/suspensions after roadside 
inspection  and  self-cancelling  prohibitions 
following subsequent PTI 

Limited support among experts as not considered to be a key issue 
and  there  was  not  sufficient  evidence  about  the  extent  of  the 
problem the measure would address. 

289 

 
 
Measure 

Reason for being discarded 

New  data  items  necessary  for  the  treatment  of 
end-of-life vehicles (ELV) 

Considered  outside  the  scope  of  this  initiative  since  already 
covered by the impact assessment prepared for the revision of the 
legislation  on  ELV  (but  aiming  at  amending  the  Directive  on 
vehicle registration documents). 

Improve  administrative  processes  by  requiring 
that re-registration of vehicles in another MS is 
conducted online (on the basis of the presence of 
appropriate IT system) 

Considered  as  going  beyond  what  is  necessary  to  address  the 
problem and is considered to be already sufficiently covered by the 
SDG Regulation. 

290 

 
 
ANNEX 9: COMPARISON OF POLICY OPTIONS IN TERMS OF MEETING THE OBJECTIVES 

Strongly negative 

Negative 

No or limited impact 

Positive 

Strongly positive 

Unclear 

Impact 

PO1a 

PO1b 

PO2 

PO3 

General objective 1: Improve road safety in the EU 

%  reduction  in  the  level  of 
fatalities  and 
injuries  and 
associated external costs 

Expected  reduction  of  fatalities  by  4,661, 
severe injuries by 42,272 and slight injuries 
by  239,803  (cumulative  over  2026-2050, 
relative to the baseline). 

Expected reduction of fatalities by 6,847, 
severe  injuries  by  64,640  and  slight 
injuries  by  364,155  (cumulative  over 
2026-2050, relative to the baseline). 

Estimated  external  cost  savings  of  EUR 
48.1  billion,  expressed  as  present  value 
over 2026-2050 relative to the baseline. 

Estimated external cost savings of EUR 
73.9  billion,  expressed  as  present  value 
over 2026-2050 relative to the baseline.  

(++) 

(+++) 

Expected  reduction  of  fatalities  by 
6,912,  severe  injuries  by  64,885  and 
slight injuries by 365,665 (cumulative 
over  2026-2050, 
the 
baseline). 

relative 

to 

Estimated  external  cost  savings  of 
EUR 74.2 billion, expressed as present 
value  over  2026-2050  relative  to  the 
baseline. 

(+++) 

Expected reduction of fatalities by 7,013, severe 
injuries by 65,686 and slight injuries by 368,498 
(cumulative over 2026-2050, relative to the 
baseline). 

Estimated  external  cost  savings  of  EUR  75.2 
billion,  expressed  as  present  value  over  2026-
2050 relative to the baseline. 

(+++) 

General objective 2: Contribute to sustainable mobility 
%  reduction  in  the  level  of 
pollutant  emissions  from  road 
transport 
associated 
and 
external costs 

Expected  reduction  of  NOx  emissions  by 
3,176 kt over 2026-2050 (16.8% reduction 
from the baseline) 

Expected  reduction  of  PM  emissions  by   
135  kt  over  2026-2050  (12.7%  reduction 
from the baseline) 

Expected reduction of NOx emissions 
by 3,925 kt over 2026-2050 (20.8% 
reduction from the baseline) 

Expected reduction of NOx emissions 
by 3,969 kt over 2026-2050 (21.0% 
reduction from the baseline) 

Expected reduction of NOx emissions by 3,970 
kt over 2026-2050 (21.0% reduction from the 
baseline) 

Expected reduction of PM emissions by 
196 kt over 2026-2050 (18.5% reduction 
from the baseline) 

Expected reduction of PM emissions 
by 199 kt over 2026-2050 (18.7% 
reduction from the baseline) 

Expected reduction of PM emissions by 199 kt 
over 2026-2050 (18.7% reduction from the 
baseline) 

Estimated  external  cost  savings  of  EUR 
58.7  billion,  expressed  as  present  value 
over 2026-2050 relative to the baseline. 

Estimated external cost savings of EUR 
75.2 billion, expressed as present value 
over 2026-2050 relative to the baseline. 

(++) 

(+++) 

Estimated external cost savings of 
EUR 76.1 billion, expressed as 
present value over 2026-2050 relative 
to the baseline. 

(+++) 

Estimated external cost savings of EUR 76.1 
billion, expressed as present value over 2026-
2050 relative to the baseline. 

(+++) 

291 

 
 
 
Strongly negative 

Negative 

No or limited impact 

Positive 

Strongly positive 

Unclear 

Impact 

PO1a 

PO1b 

PO2 

PO3 

% reduction in the level of noise 
from 
and 
transport 
associated external costs 

road 

Limited  impact  on  noise  levels  by  a  1% 
reduction  of  share  of  share  of  motorcycle 
high emitters   

Significant  impact  on  noise  levels  by 
expected  reduction  of  high  emitters  by 
12.5% for M1 and N1 and 31.1% for L3-
L7 

Significant  impact  on  noise  levels  by 
expected reduction of high emitters by 
12.5%  for  M1,  12.5%  for  N1  and 
30.7% for L3-L7 

Significant impact on noise levels by expected 
reduction of high emitters by 12.5% for M1, 
16.4% and N1 and 33.4% for L3-L7 

Estimated external cost savings of EUR 0.2 
billion,  expressed  as  present  value  over 
2026-2050 relative to the baseline. 

(0/+) 

Estimated external cost savings of EUR 
7.3  billion,  expressed  as  present  value 
over 2026-2050 relative to the baseline. 

Estimated  external  cost  savings  of 
EUR 7.3 billion, expressed as present 
value  over  2026-2050  relative  to  the 
baseline. 

(++)  

(++) 

Estimated  external  cost  savings  of  EUR  7.8 
billion,  expressed  as  present  value  over  2026-
2050 relative to the baseline. 

(++) 

General objective 3: Facilitate the free movement of persons and goods in the EU 
Removal  of  obstacles  to  re-
registration  of  vehicles 
in 
another MS  

Positive  contribution  based  on  enhanced 
access  to  other  MS  PTI  databases  via  the 
common 
the 
harmonisation  of  the  vehicle  registration 
documents (PMC8) 

(PMC7)  and 

interface 

Positive contribution based on enhanced 
access to other MS PTI databases via the 
common 
the 
harmonisation of the vehicle registration 
documents (PMC8)  

interface  (PMC7)  and 

based 

contribution 

Positive 
on 
enhanced  access  to  other  MS  PTI 
databases  via  the  common  interface 
(PMC7)  and the harmonisation of the 
documents 
vehicle 
(PMC8) 

registration 

Additional  positive  contribution  towards 
removal  of  obstacles  on  the  basis  of  the 
digital  vehicle 
registration  certificate 
(PM16)  combined  with  additional  data 
included in the vehicle register (PM17)  

(++) 

(+) 

Removal of obstacles related to 
the roadworthiness testing of 
vehicles (recognition of 
certificates issued by other 
MSs) 

Positive but partial impact on the removal 
of obstacles dependent on the level/number 
of  bilateral  agreements  signed  that  are 
expected  to  cover  only  part  of  the  EU 
Member States   

Positive 
impact  on  the  removal  of 
obstacles  expected  due  to  the  EU-wide 
recognition of PTI certificates in another 
Member  State  but 
to 
passenger cars and only for a period of 6 
months 

limited  only 

Additional 
contribution 
positive 
towards  removal  of  obstacles  on  the 
basis of the digital vehicle registration 
certificate  (PM16)  combined  with 
additional data included in the vehicle 
register (PM17)  

(++) 
Positive  impact  on  the  removal  of 
obstacles expected due to the EU-wide 
recognition  of  PTI  certificates 
in 
another Member State but limited only 
to passenger cars and only for a period 
of 6 months  

(+) 

(++) 

(++) 

292 

Positive contribution based on enhanced access to 
other MS PTI databases via the common interface 
(PMC7)  and  the  harmonisation  of  the  vehicle 
registration documents (PMC8) 

Additional positive contribution towards removal 
of obstacles on the basis of the digital vehicle 
registration certificate (PM16) combined with 
additional data included in the vehicle register 
(PM17)  

(++) 
Positive impact on the removal of obstacles 
expected due to the EU-wide recognition of PTI 
certificates in another Member State extended to 
all vehicles without time limit 

(+++) 

 
 
 
 
 
 
 
Strongly negative 

Negative 

No or limited impact 

Positive 

Strongly positive 

Unclear 

Impact 

PO1a 

PO1b 

PO2 

PO3 

Specific objective 1: Ensure the adequacy, consistency, objectivity, and quality of roadworthiness testing of today's and tomorrow's vehicles 

Use  of  available  test  methods 
and  procedures  appropriate  to 
assess  the  roadworthiness  of 
vehicles, including new internal 
combustion  engine and electric 
vehicles  and  their  electronic 
safety  and  emission  control 
systems 

Use  of  available  test  methods 
and  procedures  appropriate  to 
assess  the  roadworthiness  of 
vehicles including new  internal 
combustion  engine and electric 
vehicles  and  their  electronic 
safety  and  emission  control 
systems 

Use  of  new  test  methods  in  PTI  and  RSI 
ensuring that ADAS and other GSR related 
technologies  operate  as  expected  and 
update of PTI to cover the safety of electric 
vehicles  

Use of new test methods in PTI and RSI 
ensuring  that  ADAS  and  other  GSR 
related technologies operate as expected 
and update of PTI to cover the safety of 
electric vehicles  

Use  of  new  test  methods  in  PTI  and 
RSI  ensuring  that  ADAS  and  other 
GSR  related  technologies  operate  as 
expected  and  update  of  PTI  to  cover 
electric vehicles  

Use of new test methods in PTI and RSI ensuring 
that ADAS and other GSR related technologies 
operate as expected and update of PTI to cover 
electric vehicles safety aspects  

scope  extension  of  RSI 

Small 
motorcycles (8.6% of the fleet covered) 

for 

(+) 

Adoption of new and effective test methods 
to measure NOx and PN emissions during 
PTI and RSI for all vehicle categories (ICE)  

Small  extension  of  the  scope  of  RSI  for 
motorcycles (8.6 % increase)  

(+) 

Systematic cargo securing inspections  

Systematic cargo securing inspections  

Significant  increase  in  the  number  of 
vehicles covered at PTI: M1/N1 vehicles 
over  10  years  old  (increase  by  42.1 
million  PTI  for  M1  in  2030  and  4.5 
for  N1).  Small 
million 
extension of the number of motorcycles 
tested at PTI (8.8% increase)  

inspections 

(+++) 

Adoption  of  new  and  effective  test 
methods 
to  measure  NOx  and  PN 
emissions  during  PTI  and  RSI  for  all 
vehicle  categories  (ICE),  including  the 
use of remote sensing and plume chasing  

Significant  increase  in  the  scope  of 
vehicles covered for N1 vehicles (annual 
tests  from  year  1)  (increase  by  14.2 
million emission inspection in 2030) and 
for all M1/N1 vehicles over 10 years old 
(increase by 42.1 million PTI for M1 in 
2030 and 4.5 million inspections for N1) 
and  a  small  extension  of  the  number  of  
motorcycles 
(8.8% 
increase) 

tested  at  PTI 

(+++) 

Significant  increase  in  the  number  of 
vehicles  covered  at  PTI:  M1/N1 
vehicles over 10 years old (increase by 
42.1  million  PTI  for  M1  in  2030  and 
4.5 million inspections for N1). Small 
extension  of  the  scope  of  RSI  for 
motorcycles 
and  higher 
covered 
frequency (8.6% increase)  

(+++) 

Adoption  of  new  and  effective  test 
methods  to  measure  NOx  and  PN 
emissions  during  PTI  and  RSI  for  all 
vehicle categories (ICE), including the 
use  of  remote  sensing  and  plume 
chasing  

Significant  increase  in  the  scope  of 
vehicles  covered  for  N1  vehicles 
(annual tests from year 1) (increase by 
14.2  million  emission  inspection  in 
2030) and for all M1/N1 vehicles over 
10 years old (increase by 42.1 million 
PTI  for  M1  in  2030  and  4.5  million 
inspections  for  N1)  and  a  small 
extension  of  the  scope  of  RSI  for 
motorcycles (8.8% increase) 

(+++) 

Systematic cargo securing inspections  

Significant increase in the number of vehicles 
covered  at PTI: M1/N1 vehicles over 10 years 
old (increase by 42.1 million PTI for M1 in 2030 
and 4.5 million inspections for N1) and a further 
extension of the scope for motorcycles (9% 
increase)  

(+++) 

Adoption of new and effective test methods to 
measure NOx and PN emissions during PTI and 
RSI for all vehicle categories (ICE), including 
the use of remote sensing and plume chasing  

Significant increase in the scope of vehicles 
covered for N1 vehicles (annual tests from year 
1) (increase by 14.2 million emission inspection 
in 2030) and for all M1/N1 vehicles over 10 
years old (increase by 42.1 million PTI for M1 in 
2030 and 4.5 million inspections for N1) and 
further extension of the scope of PTI for 
motorcycles (9% increase)  

(+++) 

293 

 
 
 
Strongly negative 

Negative 

No or limited impact 

Positive 

Strongly positive 

Unclear 

Impact 

PO1a 

PO1b 

PO2 

PO3 

of 

defective 

Specific policy objective 2: Significantly reduce fraud and tampering and improve the detection of defective vehicles 
Expected  reduction  of  vehicles  with 
Expected 
reduction  of  vehicles  with 
Impact (% of reduction) on the 
defective  emission  control  systems  for 
defective  and  tampered  emission  control 
and 
number 
NOx and  PN/PM  (high emitters) on the 
systems  for  NOx  and  PN/PM  (high 
tampered  vehicles  in  terms  of 
basis of advanced PTI and RSI by up to 
emitters) on the basis of advanced PTI by 
emission control systems 
48% by 2030 and 56% by 2050 for NOx 
up  to 33% by  2030  and  42%  by 2050  for 
and 43% by 2030 and 53% by 2050 for 
NOx and 26% by 2030 and 38% by 2050 
PN  (weighted  average  for  the  whole 
for  PN  (weighted  average  for  the  whole 
fleet)  
fleet)  

Expected  reduction  of  vehicles  with 
defective emission control systems for 
NOx and PN/PM (high emitters) on the 
basis of advanced PTI and RSI by up 
to 48% by 2030 and 56% by 2050 for 
NOx  and  43%  by  2030  and  53%  by 
2050 for PN (weighted average for the 
whole fleet)  

Expected reduction of vehicles with defective 
emission control systems for NOx and PN/PM 
(high emitters) on the basis of advanced PTI and 
RSI by up to 48% by 2030 and 56% by 2050 for 
NOx and 43% by 2030 and 53% by 2050 for PN 
(weighted average for the whole fleet)  

(+++) 

(++) 

(+++) 

(+++) 

Impact  (%  reduction)  on  the 
vehicles  with 
number 
tampered 
emission/noise 
control system 

of 

Very  limited  impact  on  identification  of 
tampered  vehicles  focusing  on  HGVs  as 
part  of  the  advanced  RSI  inspections  and 
for  motorcycles  (for  those  MSs  that  use 
RSI)  

(0/+) 

Impact (% reduction) on level of 
and 
odometer 
for 
associated  cost  savings 
consumers 

tampering 

reduction 

estimated 

of 
to  help 

odometer 
Significant 
tampering 
avoid 
tampering  for  4.7  million  M1  and  N1 
vehicles  in  2030  and  5.1  million  in  2050, 
64% of which related to cross border sales.  

Benefits of EUR 118.3 billion to businesses 
owners  of  vehicles  and  EUR  65.7  billion 
consumers  for 
the  period  2026-2050, 
expressed  as  present  value  relative  to  the 
baseline. 

(+++) 

impact  on 

identification  of 
Positive 
tampered  vehicles  covering  all  vehicle 
categories on the basis of advanced RSI 
inspection combined with the use remote 
sensing and plume chasing (for HGVs) as 
part of RSI  

Significant impact on identification of 
tampered vehicles covering all vehicle 
categories  on  the  basis  of  advanced 
RSI inspection combined with the use 
remote sensing and plume chasing (for 
HGVs)  as  part  of  RSI  and 
the 
introduction of RSI for N1  

Significant impact on identification of tampered 
vehicles covering all vehicle categories on the 
basis of advanced RSI inspection combined with 
the use of remote sensing and plume chasing (for 
HGVs) as part of RSI and the introduction of RSI 
for N1 and motorcycles  

(+) 

reduction  of  odometer 
Significant 
tampering  estimated 
to  help  avoid 
tampering  for  4.7  million  M1  and  N1 
vehicles in 2030 and 5.1 million in 2050, 
64%  of  which  related  to  cross  border 
sales.  

(++) 
Significant reduction of odometer 
tampering estimated to help avoid 
tampering for 4.7 million M1 and N1 
vehicles in 2030 and 5.1 million in 
2050, 64% of which related to cross 
border sales. 

to 
Benefits  of  EUR  118.3  billion 
businesses owners of vehicles and EUR 
65.7  billion  consumers  for  the  period 
2026-2050,  expressed  as  present  value 
relative to the baseline. 

Benefits of EUR 118.3 billion to 
businesses owners of vehicles and 
EUR 65.7 billion consumers for the 
period 2026-2050, expressed as 
present value relative to the baseline. 

(+++) 

Significant  reduction  of  odometer  tampering 
estimated to help avoid tampering for 4.7 million 
M1  and  N1  vehicles  in  2030  and  5.1  million  in 
2050, 64% of which related to cross border sales. 

Benefits of EUR 118.3 billion to businesses 
owners of vehicles and EUR 65.7 billion 
consumers for the period 2026-2050, expressed 
as present value relative to the baseline 

(+++) 

(+++) 

(+++) 

294 

 
 
 
Strongly negative 

Negative 

No or limited impact 

Positive 

Strongly positive 

Unclear 

Impact 

PO1a 

PO1b 

PO2 

PO3 

Specific policy objective 3: - Improve electronic storage and exchange of relevant vehicle identification and status data 

time/costs 
of 
Reduction 
associated  with  the  access  and 
exchange  of  relevant  vehicle 
data  by  inspection  centres  and 
enforcement  and  registration 
authorities 

Positive  impact  on  costs  for  authorities 
estimated at EUR 642 million for the period 
2026-2050  on  the  basis  of  the  enhanced 
access to electronic data related to PTI for 
combined  with 
authorities 
relevant  vehicle 
enhanced  access 
technical 
information  for  PTI  centres 
(PM16)  with  additional  savings  of  up  to 
EUR 1.43 billion for the period 2026-2050  

(PMC7) 
to 

Positive  impact  on  costs  for  authorities 
estimated  at  EUR  642  million  for  the 
period  2026-2050  on  the  basis  of  the 
enhanced  access 
to  electronic  data 
related to PTI for authorities (PMC7)  

(+) 

(+++) 

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

Positive  impact  on  the  basis  of  the 
enhanced  access  to  electronic  data 
related to PTI for authorities estimated 
at  EUR  642  million  for  the  period 
2026-2050  (PMC7)  combined  with 
enhanced  access  to  relevant  vehicle 
technical  information  for  PTI  centres 
(PM16)  with additional  savings  of  up 
to  EUR  1.43  billion  for  the  period 
2026-2050  

(+++) 

Positive impact on the basis of the enhanced 
access to electronic data related to PTI for 
authorities estimated at EUR 642 million for the 
period 2026-2050 (PMC7) combined with 
enhanced access to relevant vehicle technical 
information for PTI centres (PM16) with 
additional savings of up to EUR 1.43 billion for 
the period 2026-2050  

(+++) 

295 

 
 
 
ANNEX 10: SME TEST 

Step (1) of SME test (identification of affected businesses).  

In the road transport sector 99% of companies are SMEs (enterprises employing up to 250 people and 
with a turnover of less than EUR 50 million466). Roadside inspections under the RSI Directive have 
been specifically targeted at commercial vehicle fleets, which are predominantly operated by SMEs. 
The exact number of SMEs among PTI centres could not be established since there are no statistics 
on the share of PTI centres that are SMEs and due to the situation where in each Member State there 
are different PTI organisational models in place. In some Member States (e.g. Sweden) there are a 
few big companies that provide PTI services while in others (e.g. Netherlands), there are multiple 
small independent garages. In the majority of the Member States, there is a mix of a small number of 
large PTI centres and a large number of small (SMEs) ones. Garages, motor vehicle dealers, tyre and 
repair stations, affected by the requirement for Member States to set up a system to record odometer 
readings from the cars and vans registered in their territory, are almost entirely SMEs (above 99% of 
the companies are SMEs). 

Step (2) of SME test (consultation of SME stakeholders).  

In the OPC, looking at the responses of companies, i.e., those organisations that classified themselves 
as a ‘company or business organisation’ and which are clearly a company, there were 21 separate 
responses from SMEs  and 16 from  larger  companies.  In the context of the OPC and the  targeted 
stakeholder consultation, the responses suggested a higher sensitivity of SME respondents towards 
the  expected  costs  of  some  of  the  measures  (extension  of  scope  of  PTI  and  RSI  in  the  case  of 
motorcycles  and  vans,  and  for  more  demanding  tests),  mainly  in  relation  to  the  costs  for  new 
equipment and facilities for small PTI centres and for small transport companies.  

According  to  the  stakeholders  consulted  in  the  survey,  a  slightly  positive  impact  on  the  SME 
competitiveness would be expected from measures related to access and exchange of information, 
extended scope of RSI and new RSI test methods, new PTI/RSI test requirements, vehicle registration 
measures  and roadworthiness certificates in  electronic format.  Some stakeholders also  considered 
there should be a positive impact for SMEs despite the additional cost on equipment. They stated that 
the policy options should have a positive economic impact because vehicles, which need a mandatory 
PTI also need to be maintained regularly and this is normally done by garages, tyre and repair stations, 
which  almost  entirely  SMEs.  On  the  other  hand,  the  survey  responses  showed  that  SMEs  are 
concerned by the financial burden these new testing requirements and equipment adaptations  may 
pose on them. These additional costs can be particularly challenging for smaller PTI centres to bear. 
It was also noted that some SMEs are involved in developing these new testing methods and could 
benefit from this. Regarding data access for SME technology companies, it was widely agreed that 
facilitating access would enhance the competitiveness of smaller firms, levelling the playing field in 

466 Eurostat: Services by employment size class. 
https://ec.europa.eu/eurostat/databrowser/view/SBS_SC_1B_SE_R2__custom_3493320/default/table 

296 

 
 
 
 
their  competition  against  larger  companies.  Harmonised  data  governance  should  be  particularly 
beneficial for SMEs. 

Step (3) of SME test (assessment of the impacts on SMEs).  

PTI  centres  are  affected  as  described  in  section  6.1.2.1.  The  additional  equipment  costs  for  PTI 
centres  mean  additional  revenues  for  garage  equipment  manufacturers,  many  of  which  are  also 
SMEs. It was however not possible to quantify these revenues. Beyond the impact of the common 
measures on SMEs, no additional impact on costs for PTI centres is expected for PO1a. Both PO1b 
and  PO2  will,  in  addition  to  the  common  measures,  include  increased  costs  for  SMEs  due  to 
additional emission tests for light commercial vehicles (PM5), extra tests on vehicles over 10 years 
old  (PM6),  equipment  and  training  of  inspectors  for  motorcycle  noise  testing  (PM10),  and  the 
additional emission tests for vehicles that are found as high emitters during remote sensing or plume 
chasing  and  are  sent  for  emission  tests  in  a  PTI  centre  (PM12).  PO1b  will  also  include  costs  for 
equipment and training of inspectors for the mandatory PTI for motorcycles above 125cm3 (PM2). 
PO3 (in addition to the common measures, plus PM5, PM6, PM10 and PM12) is expected to have 
an impact on SMEs through PM3, leading to motorcycle test adaptation costs. Additionally, PM4 
concerning PTI for light trailers requires the acquisition of supplementary devices. PM7, which aims 
to harmonise tests and procedures, is associated with increased expenses for SMEs operating testing 
centres due to the need to invest in standardised equipment. These measures collectively are expected 
to  lead  to  some  financial  challenges  for  SME  testing  centres  in  adapting  to  the  new  testing 
requirements,  in  particular  in  the  first  years  of  implementation,  and  provide  new  opportunities  to 
garage  equipment  manufacturers.  PO1b,  PO2  and  PO3  are  expected  to  have  the  most  significant 
impact on SMEs.  

As shown in section 6.1.2.1, all policy options are estimated to result in  adjustment costs for PTI 
centres, with the highest costs arising for PO3, and under PO2 and PO3 also in some increase in the 
administrative costs. The increase in costs for new equipment and facilities (estimated in the range 
of EUR 20,000 to EUR 100,000 per new PTI lane depending on the specific vehicle category) can 
have  a  greater  impact  on  some  smaller  PTI  centres  that  may  find  it  more  challenging  to  finance 
additional investments. On the other hand, in all policy options SMEs can expect to benefit from the 
additional business opportunities due to the extension of the scope and/or the frequency of PTI. The 
largest benefits due to the extension of the scope and/or the frequency of PTI are expected in PO3. 
Overall, as explained in section 6.1.2.1, PO2 is expected to result in the highest net benefits for PTI 
centres (EUR 17.3 billion, expressed as present value over 2026-2050), followed by PO3 (EUR 16.4 
billion) and PO1b (EUR 15.9 billion) while PO1a is expected to result in net costs (EUR 2.9 billion). 
Net benefits in PO2 represent around 6.3% of the turnover per PTI centre, in PO3 around 6% of the 
turnover, in PO1b around 5.8% of the turnover per PTI centre, while the net costs in PO1a around 
1.1% of the turnover. While it was not possible to split the costs and benefits between the two groups 
(i.e., SME and others), due to the lack of data, a large part of the net benefits in PO1b, PO2 and PO3 
and of the net costs in PO1a are expected to be attributed to SMEs.  

Garages, motor vehicle dealers, tyre and repair stations, etc., mostly SMEs, will be affected by the 
requirement for Member States to set up a system to record odometer readings from the cars and vans 
registered in their territory (PMC9) in all policy options. As explained in section 6.1.2.2, total one-
off and recurrent administrative costs would amount to EUR 460 million (EUR 706 per company), 
expressed as present value over 2026-2050. 

297 

 
 
Businesses owning vehicles. As explained in section 6.1.2.4, all policy options are expected to result 
in net benefits for businesses owning vehicles, estimated at EUR 117.8 billion in PO1a, EUR 94.2 
billion in PO1b, EUR 94 billion in PO2 and EUR 93.6 billion in PO3, expressed as present value 
over 2025-2050 relative to the baseline (in 2022 prices). Based on the available information, it was 
however not possible to assess how many of the businesses owning vehicles are SMEs. 

Only few of the measures are expected to affect the road haulage sector largely composed of SMEs 
(e.g., PM13 on cargo securing inspections in PO1b, PO2 and PO3, which would result in minimal 
costs, while hauliers could also benefit from the savings of avoided emission tests at PTI after having 
passed a RSI or a remote sensing check). The overall impact on the road haulage sector is expected 
to be limited but rather positive, although the available data did not allow a split of the costs  and 
benefits between the two groups of operators (i.e., SME and others). 

Step (4) of SME test (minimizing negative impacts on SMEs).  

A large part of costs and benefits for PTI centres are expected to be attributed to SMEs. Depending 
on the Member State, the additional costs for the SMEs due to the additional requirements per PTI 
may  be  passed  through  to  vehicle  owners.  Where  Member  States  do  not  regulate  prices,  the  PTI 
centres would likely be able to recover investment costs. Where Member States regulate the level of 
PTI charges, the costs may either be borne by the service provider or be recovered over a longer 
period. On the other hand, the higher costs due to the increased number of inspections (i.e. due to the 
extended scope) can be fully passed through to the vehicle owners and will represent benefits for the 
SMEs. Likewise, garages, motor vehicle dealers, tyre and repair workshops, which are mostly SMEs, 
will be affected by the requirement to set up a system to record odometer readings from the cars and 
vans registered in the same Member State. The related costs could be partly offset with pass-through 
of the costs to vehicle owners. 

For businesses owning vehicles, it was not possible to assess how many of the businesses owning 
vehicles  are  SMEs.  Measures  such  as  cargo  securing  inspections  are  expected  to  affect  the  road 
haulage sector largely composed of SMEs, which would result in minimal costs. On the other hand, 
hauliers would be able to benefit from the savings of avoided emission tests at PTI after having passed 
a RSI. The overall impact on the road haulage sector is expected to be limited but rather positive, 
although the available data did not allow a split of the costs and benefits between the two groups of 
operators (i.e., SME and others). 

A key issue highlighted by respondents in the stakeholder consultation in relation to SMEs are the 
aspects  related  to  the  renewal  of  testing  equipment:  the  financial  implications,  the  timeline  for 
completing  the  investment,  and  the  availability  of  support  or  financing  options  to  facilitate  this 
transition. One possible solution could be the extension of the transitional period for SMEs to update 
their  equipment/facilities.  A  smoother  transition  with  a  longer  time  for  adjustment  could  make  it 
easier for smaller PTI centres to prepare and minimise the negative impact.  

298 

 
 
 
ANNEX 11: LINKS BETWEEN THE CONCLUSIONS OF THE EX-POST 
EVALUATION AND THE IMPACT ASSESSMENT 

The  links  between  the  conclusions  of  the  ex-post  evaluation  and  the  impact  assessment  are 
summarised in the table below. 

Table 269: Links between the main conclusions of the ex-post evaluation and the impact assessment  

Main ex-post evaluation conclusions 

Impact Assessment  

Conclusions on relevance 

The RWP is not adapted to the latest technologies such as advanced 
driver assistance systems (e.g. ADAS) and electronic safety features, 
for  which  the  RWP  currently  does  not  provide  a  sufficiently 
comprehensive  framework.  It  does  not  contain  specific  testing 
protocols  which  would  ensure  the  compliance  and  maintenance  of 
electric, hybrid and hydrogen vehicles,  including software updates. 
Technical  inspections  would  have  to  be  updated  for  the  efficient 
acquisition  of  important  safety-related  data  and  the  monitoring  of 
new  sensors  and  functions.  Regarding  emissions,  some  of  the  PTI 
tests and equipment must be adapted as they are no longer capable of 
detecting  emission  failures  in  the  most  recent  internal  combustion 
engine vehicles. 

Conclusions on effectiveness 

Regarding roadworthiness emission checks, the effectiveness of the 
RWP is limited as the current test requirements under PTI and RSI 
are  not  suited  to  testing  the  functioning  of  recent  emission  control 
systems and must therefore be updated. Opacity testing measurement 
is outdated as it cannot detect diesel vehicles with defective particle 
filters or a tampered catalyst, which lead to high particle and NOx 
emissions.  Instead,  PN  and  NOx  measurement  should  be  used  to 
verify  newer  diesel  and  petrol  vehicles  to  detect  defects  and 
tampering with emission control systems.  
Regarding  improvement  of  the  exchange  of  information  on  testing 
results  between  Member  States, 
the  current  framework  for 
information exchange has not been effective. Although the legislation 
mentions  electronic  data  exchanges  between  Member  States 
authorities  as  a  possibility,  not  all  countries  use  this.  Even  if  the 
harmonisation  of  vehicle  registration  documents  made  it  easier  for 
citizens to register vehicles from other Member States and EEA, there 
is room for improvement of the digitalisation process, to make it even 
easier.  Re-registration  can  still  be  a  cumbersome  process  and  the 
RWP  currently  prevents  the  mutual  recognition  of  PTIs  between 
Member States, which represents a barrier to free movement. 

Conclusions on efficiency 

Digitalisation  can  help  in  streamlining  the  vehicle  re-registration 
process: the RWP should use the benefits of digital data exchange and 
more  harmonisation  of  vehicle  documents 
the 
administrative  burden  and  costs  associated  with  the  process.  Also, 
digital  (mobile)  vehicle  registration  documents  could  further 

reduce 

to 

dedicated 

addressing 

impact  assessment  analyses  specific 
The 
measures 
the 
to 
challenges  posed  by  recent  and  upcoming 
vehicle technology, in particular testing ADAS, 
software updates and electric vehicles. 
Similarly, measures aiming at improved access 
to  vehicle  data  for  the  purposes  of  vehicle 
testing  are  assessed.  As  for  emission  testing, 
measures to introduce new test methods based 
on  recent  technical  developments  to  replace 
outdated methods are defined. 

The impact assessment analyses the impacts of 
replacing  outdated  emission  test  methods  for 
modern  vehicles,  in  particular  exhaust  gas 
opacity testing required by the current PTI and 
RSI  Directives.  It  assesses  the  benefits  of 
measures  introducing  particle  number  (PN) 
counting  and  NOx-measurement,  as  well  as 
remote sensing and/or plume chasing. 

impact  assessment 

The 
looks  at  specific 
measures facilitating cross-border exchange of 
vehicle data. 
Similarly,  it  assesses  the  expected  effects  of 
various  alternatives  of  mutual  recognition  of 
PTI certificates.  

impact  assessment 

The 
looks  at  specific 
measures facilitating cross-border exchange of 
vehicle data to address the issue of inefficient 
the 
re-registration  processes,  for  example 
the 
harmonisation  of  registered  data  and 

299 

 
 
 
 
 
 
Main ex-post evaluation conclusions 

Impact Assessment  

facilitate  the  digitalisation  of  the  vehicle  registration  and  data-
keeping processes and reduce costs. 

interlinking  of  national  vehicle  registers,  as 
well  as  the  possible  introduction  of  digital 
registration documents. 

Conclusions on coherence 

improved 

instruments  could  be 

More  consistency  should  be  ensured  between  the  type-approval 
regulation  and  the  RWP.  The  coherence  between  the  RWP  and 
the 
relevant  EU 
standardisation  of  safety-relevant  vehicle  data  and  the  related 
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 could 
reduce  uncertainty  and  time  spent  on  searching  for  the  relevant 
information,  thus  improving  the  overall  accuracy  and  efficiency  of 
inspections. The RWP should be also better aligned with the General 
Safety Regulation (GSR) (EU) 2019/2144. 

through 

Roadworthiness testing relies to a large extent 
on  type-approval,  including  when  it  comes  to 
the 
safety-relevant  vehicle  data.  While 
initiative on access to in-vehicles data is meant 
to address the need to standardise data formats, 
this impact assessment considers a measure that 
aims to specify the means of access to such data 
for the purpose of vehicle inspection. 
It  also  analyses  the  impacts  of  a  measure 
focusing  on  testing  ADAS,  mandated  by  the 
GSR. 

Conclusions on EU Added Value 

framework 

The  RWP  sets  a  minimum  standard  for  all  Member  States  and 
for  detecting  and  addressing 
provides  a  basic 
roadworthiness defects, ensuring that all Member States take action 
to improve road safety. Further harmonisation of the minimum PTI 
and  RSI  requirements  would  be  useful  to  improve  consistency  of 
legislation, standards and practices within the EU. There is scope to 
improve mutual recognition of PTI inspections between the Member 
States,  which  would  add  value  to  the  EU  internal  market,  while  it 
would  also  help  to  increase  vehicle  safety  and  environmental 
protection. 

One aim of the initiative is to update the RWP 
to  evolving  technology,  to  maintain  its  added 
value. It therefore includes a series of measures 
aimed  at  further  improving  road  safety  and 
environmental  protection 
further 
harmonisation. 
Measures  are  also  defined  to  enhance  the 
mutual  recognition  of  PTIs  conducted  in 
another Member State. 

through 

300 

 
 
 
 
 
 
 
ANNEX 12: IMPACTS ON FUNDAMENTAL RIGHTS 

This annex discusses in more detail the impacts on fundamental rights. The policy options were assessed to 
determine if they have an impact on the fundamental rights and/or equal treatment of EU citizens. The 
starting point  of  the  assessment of the  fundamental rights is  the Charter of  Fundamental Rights of the 
European  Union467.  All  POs  were  assessed  having  regard  to  the  relevant  EU  instrument  and  it  was 
concluded that they maintain full respect for human and fundamental rights, and none will have any negative 
impact thereon.  

All options contain common measures (PMC3 and PMC4) to help reduce the level of air pollutant emissions 
from vehicles, thereby helping to improve the quality of the environment, in line with Article 37 of the 
Charter. However, options PO1b, PO2, and PO3 go further than option PO1a in this regard, due to measures 
PM5 (annual emission testing for light commercial vehicles), PM6 (yearly testing of vehicles that are 10-
year-old or older) and PM12 (NOx measurement in RSI by remote sensing and plume chasing).  

All  policy  options  contain  a  measure  (PMC1)  to  adapt  PTI  methods  to  the  testing  of  electric  vehicles 
including the training of inspectors. This will provide a safer workplace for vehicle inspectors. In addition, 
PO1b, PO2, and PO3 contain a measure (PM13) to include mandatory inspection of cargo securing in RSI. 
These  three  policy  options  will  therefore  provide  a  safer  working  environment  than  option  PO1a  for 
professional drivers (Article 31).   

All  policy  options  contain  a  measure  designed  to  combat  odometer  fraud  (PMC9),  thereby  increasing 
consumer protection (Article 38). Policy options PO3 as well as PO1b and PO2 each contain a measure 
(PM7 or PM8) to provide for mutual recognition of roadworthiness certificates. Policy options PO1a, PO2 
and PO3 contain a measure to digitalise registration documents (PM16). Therefore, PO2 and PO3 would 
have the greatest impact on assisting freedom of movement and residence (Article 45). 

All policy options contain a measure (PMC3) on PN measurement at PTI for light and heavy-duty vehicles 
and at RSI for commercial vehicles. However, policy options PO1b, PO2 and PO3 also contain a roadside 
inspection measure for NOx and PM measurement (remote sensing and plume chasing – PM12). Therefore, 
these three options go further than PO1a in ensuring that vehicles with tampered emission control systems, 
which could otherwise pass at PTI, will be caught at RSI. By ensuring that owners of non-tempered vehicles 
are  not  placed  at  a  disadvantage  compared  to  tampered  vehicles,  these  three  options  do  the  most  in 
promoting equality before the law (Article 3). 

PO2 and PO3 contain a measure on data governance (regarding cost-free access to vehicle testing by testing 
centres – PM11), which refers to technical data related to the vehicle’s specifications and current state (e.g., 
sensor values). All options include a measure on odometer readings (PMC9), which considers privacy issues 
when data is stored and exchanged. During the consultations, some stakeholders expressed concern over 
the data privacy issues in common measures related to the possibility of electronic roadworthiness electronic 
certificates,  and  access  thereto  (PMC6  and  PMC7).  From  a  road  safety  perspective,  the  automatic 
accessibility of certificates through a shared system holds significant advantages, particularly in facilitating 
cross-border inspections and enhancing consumer convenience. However, the implementation of a digital 

467 https://commission.europa.eu/aid-development-cooperation-fundamental-rights/your-rights-eu/eu-charter-
fundamental-rights_en  

301 

 
 
 
roadworthiness certificate demands a careful examination of potential privacy issues and the formulation of 
robust privacy protection measures. 

302 

 
 
ANNEX 13: IMPACTS ON THE FUNCTIONING OF THE INTERNAL MARKET 
AND COMPETITION 

As described in section 6.1.7, the existing divergence between vehicle registration documents and 
the information included and quality of the data stored in the vehicle registers creates challenges in 
coordinating  enforcement  actions  by  Member  States.  Furthermore,  the  non-recognition  of 
roadworthiness certificates among EU Member State creates additional trade barriers for cross-border 
operation  or  sale  of  vehicles,  hindering  the  efficient  functioning  of  the  internal  market,  business 
operations and the freedom of movement of people within the EU. All policy options are expected to 
have a positive impact on the functioning of the internal market. 

The  combination  of  the  measures  related  to  improving  the  availability  and  exchange  of  vehicle-
related  information,  making  the  roadworthiness  certificate  available  in  electronic  format, 
harmonising testing methods, the frequency of testing, requirements for the improvement of the PTI 
and the scope of testing, can have a positive impact on the functioning of the internal market and on 
competition. 

All policy options include the common measures on the harmonisation of testing methods (PMC3, 
PMC4), and requirements for improving PTI (PMC1, PMC2 and PMC5) which could facilitate the 
free  movement  of  vehicles,  since  more  harmonised  testing  across  Member  States  can  enhance 
consumer confidence in purchasing vehicles from other countries, thereby promoting competition. 
Odometer tampering concerns at the moment of purchasing a second-hand vehicle are addressed by 
PMC9 in all policy options. 

Harmonising  vehicle  registration  documents  across  Member  States  (PMC8)  can  have  a  positive 
contribution  to  internal  market  and  competition.  The  standardised  information  helps  to  verify  the 
vehicle's characteristics, and its registration status in the country of origin. This verification process 
helps to address potential obstacles to re-registration in another EU Member State, for example where 
the  vehicle  is  reported  stolen,  or  its  registration  certificate  is  suspected  of  being  fraudulent.  By 
harmonising  the  technical  data  in  vehicle  registration  documents,  the  measure  can  simplify  and 
streamline cross-border trade in vehicles within the EU. 

Providing electronic access to relevant data, including on PTI reports stored in national databases, to 
the  registration  authorities  in  another  Member  State  (PMC7),  is  also  expected  to  have  a  positive 
impact on the EU internal market, helping to avoid fraud and eliminate trade obstacles. An additional 
positive  impact  on  fraud  avoidance  is  expected  from  the  requirement  to  issue  roadworthiness 
certificates in electronic format only (PMC6). 

Qualitative assessment shows that PO2 and especially PO3 are expected to have the highest positive 
impact  on  the  internal  market  and  competition.  PO2  incorporates  additional  measures  aimed  at 
extending roadside inspections to light commercial vehicles, and facilitating access to vehicle data 
necessary for thorough testing by PTI centres. This comprehensive approach is expected to have a 
stronger impact than PO1a and PO1b due, to its emphasis on these factors. PO3 has a stronger positive 
impact due to PM7, which requires that a PTI certificate issued in any Member State is recognised 
by the Member State of registration, as well as further harmonisation of test methods. In addition, 
PO3 introduces mandatory PTI for all motorcycles and light trailers, which are not currently tested 
by all Member States. The inclusion of L-category vehicles in the scope of RSI (PM15) is expected 
to  reduce  the  number  of  tampered  vehicles.  PO3  applies  more  ambitious  measures  regarding  the 

303 

 
 
mutual recognition of the PTI certificates, and the standardisation of tests methods than provisions 
already included in the other policy options. As such, PO3 is expected to deliver the most significant 
positive impact on the internal market and competition. 

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ANNEX 14: COHERENCE, SUBSIDIARITY AND PROPORTIONALITY 
(DETAILED ANALYSIS) 

Coherence 

Internal  coherence assesses how various elements  of the proposed options are expected to  work 
together to achieve the objectives. Although all four policy options address the identified specific 
objectives and underlying problem drivers, they do so in different ways, and with a different level of 
intervention. 

The measures common to all policy options address different aspects of the problem covering test 
methods  and  procedures  for  both  PTI  and  RSI,  frequency  of  inspections  related  to  vehicles  with 
modifications,  and  measures  related  to  facilitating  exchange  of  PTI  and  registration  data  among 
Member States. There are no evident contradictions and inconsistencies among these measures. In 
some case there are possible synergies in terms of costs to implement them, such as the introduction 
of new test methods for PN and NOx, where the goal is to eventually use one single device and one 
single measurement for both tests. Importantly, the measure addressing odometer fraud, by increasing 
the number of readings and the exchange of relevant data in the case of cross-border sales, will benefit 
from the implementation of the measure that will facilitate the easier exchange of relevant data among 
Member States. 

PO1a focuses on better exchange of vehicle data and there are clear synergies between the common 
measures on the frequent update of data in vehicle registration and the introduction of a digital vehicle 
certificate. Digital vehicle certificate should also simplify the approach to the data to be included in 
vehicle certificate dataset and facilitate re-registration of vehicles and enforcement activities.  

PO1b has the focus more on testing and reducing safety- and emissions-related fraud and tampering 
and improving the detection of defective vehicles. It includes additional test methods and procedures 
besides those in the common measures. It aims at higher combined impact in terms of identification 
of  defective  vehicles,  for  example  through  measures  such  as  the  annual  emission  testing  of  light 
commercial vehicles. It also shows synergies with introducing mandatory PTI for motorcycles and 
the use of more advanced noise testing for motorcycles. The use of remote sensing and plume chasing 
for HDVs measuring NOx and particle emissions complements the new PTI and RSI methods, helps 
to  better  target  inspections  and  increases  the  share  of  the  vehicle  fleet  checked  between  PTI 
inspections. Given that it does not include any of the measures related to digital certificate or the 
extension of data to be included in the registration certificate, some of the combined benefits in PO1b 
are likely to be smaller.  

Synergies indicated in relation to PO1a and PO1b are expected to increase in the case of PO2 and 
PO3, containing more comprehensive sets of measures and even lead to extra synergies, for example 
due to measures on registration certificate and more harmonised registered data. Some measures such 
as introduction of RSI for vans will be complementary to the use of new testing methods (PN and 
NOx testing). PO3 goes even further than PO2 by including RSI for motorcycles, complementing the 
mandatory PTI for motorcycles with extended scope (>50cc), and by requiring PTI of trailers below 
3.5t (O1 and O2 categories).   

To  summarise,  all  policy  options  ensure  internal  coherence.  Among  the  four  options,  it  can  be 
concluded  that  PO2  and  PO3  are  expected  to  benefit  from  a  broader  range  of  synergies  that  can 

305 

 
 
contribute to a higher level of achievement of the objectives. 

External  coherence  focuses  on  the  compliance  of  the  initiative  with  other  EU  instruments  and 
relevant EU policies, as well as national policies and international obligations. All identified policy 
options show strong links to several EU instruments. 

All policy options appear consistent with the objectives and priorities set in the 2020 Sustainable 
and Smart Mobility Strategy (SSMS) and the EU Green Deal by ensuring that vehicles on the 
roads maintain an adequate level of safety and environmental performance over time. By the expected 
reduction in fatalities, all policy options are in line with the objectives set in the EU Road Safety 
Policy  Framework,  and  will  contribute  to  the  achievement  of  the  objective  of  50%  reduction  of 
fatalities and serious injuries by 2030. Still, PO2 and even more so PO3 are the policy options with 
the greatest level of contribution towards this objective. The proposed options are also expected to 
have a significant contribution towards the EU’s clean air policy objectives, including those of the 
Ambient Air Quality Directives and of the National Emission reduction Commitments Directive, by 
better identifying and reducing the presence of high polluters that represent a very large share of total 
emissions from road transport.  

All policy options are also consistent with the Single Digital Gateway Regulation by facilitating 
online access to vehicle-related information, relevant administrative procedures and assistance and 
problem-solving  services.  PO1b  is  less  coherent  than  the  other  options  as  it  does  not  include  the 
digitalisation  of  vehicle  registration  certificates  and  adding  further  data  to  the  vehicle  registers. 
Otherwise, the options are also serving the objectives of the EU’s Data Strategy for the development 
of  European  Data  spaces  for  public  administrations  that  can  support  enforcement  of  legislation, 
including  road  safety  and  environmental  legislation.  Exchange  of  information  related  to 
roadworthiness and registration data will have to be aligned with relevant rules on data protection 
(GDPR).  

All  options  are  consistent  with  the  General  Safety  Regulation.  They  will  ensure  that  any  new 
equipment introduced to ensure compliance with that Regulation will perform as expected and, as a 
result,  ensure  that  the  benefits  materialise.  All  policy  options  are  coherent  with  the  safety  and 
environmental requirements as set out in the Type-approval Regulations468. These Regulations also 
set out the market surveillance requirements for these vehicles. All policy options include measures 
which aim at ensuring that minimum standards are maintained by owners throughout the lifetime of 
the  vehicle.  They  include  alignment  between  PTI  and  RSI  testing  and  the  type-approval  process, 
including in relation to the use of ePTI. Remote sensing in RSI of all vehicles (part of PO1b, PO2 
and PO3) is particularly relevant for the purposes of market surveillance as it allows screening a large 
part  of  the  vehicle  fleet  providing  valuable  insight  into  recurrent  issues  with  specific 
technologies/solutions used as part of emission control systems, vehicle models, model years etc. 

Further  to  that,  there  are  expected  synergies  with  the  new  Euro  7  Regulation  for  all  options, 
including the use of On-Board Monitoring functions to facilitate the assessment of NOx emissions 
during PTI and RSI inspections. Finally, all policy options are coherent with the requirements of the 
legislation  on  end-of-life  vehicles  (ELV),  through  providing  electronic  access  to  data  to  the 
registration authorities of other EU Member States and adding new, including ELV-related data to 

468 i.e. Regulation (EU) 2018/858 for most passenger and freight vehicles and their trailers, Regulation (EU) 167/2013 
for tractors, and Regulation (EU) 168/2013 for two- and three-wheel vehicles and quadricycles. 

306 

 
 
 
the vehicle register.  

In terms of external coherence, all policy options are therefore considered consistent with relevant 
EU strategies and legal instruments and contribute to EU policy priorities. In relative terms, PO3 and 
PO2 are expected to be the most coherent with the policy objectives in related EU legislation and 
strategies, followed by PO1b and PO1a being slightly less coherent. PO2 is considered somewhat 
more  coherent  than  PO3  in  relation  to  existing  national  policies  and  structural  differences  on  the 
ground (further explained under subsidiarity below). 

Subsidiarity and proportionality 

As described in sections 3.2 and 3.3, EU action is justified on the basis that Member States alone 
would  not  be  able  to  reach  the  objectives  of  the  initiative,  i.e.,  updating  the  harmonised  rules  on 
roadworthiness testing, including coordinated exchange of vehicle-related data. What differentiates 
the policy options beyond the common measures necessary to achieve the objectives at a minimum 
level is their focus (between PO1a and PO1b) and the extent to which they can fulfil the objectives 
(PO2 and PO3 going beyond the other two). 

In  terms  of  the  relevant  measures  for  the  recognition  of  PTI  certificate  in  other  Member  States, 
measures  PM8  (included  in  PO1b  and  PO2)  and  especially  PM7  (in  PO3)  may  be  considered  by 
Member States as going beyond what is necessary to address the problem, while PM9 (in PO1a) – 
based on bilateral agreements (essentially voluntary recognition) – leaves greater scope for Member 
States to decide which PTIs to accept depending on differences between national solutions. However, 
this is expected to significantly limit the benefits to a limited number of citizens and businesses, thus 
also delivering less in terms of the achievement of the objectives. As regards the measures on the PTI 
and RSI tests and procedures, similar measures are already in place in the Member States, based on 
the current Directives. Requiring that certain standards are applied concerning the tests methods and 
procedures is intended to ensure a harmonised approach across the EU and should not, in principle, 
raise any subsidiarity issues.     

In relation to the measures concerning the extension of the scope of PTI and/or RSI to motorcycles, 
PM1 (in PO1a and PO2) aims to ensure harmonisation while giving the option for Member States to 
choose whether to use PTI or RSI for motorcycles. PM2 (in PO1b) and PM3 (in PO3) requiring all 
Member States to apply PTI to motorcycles would effectively harmonise the roadworthiness testing 
of these vehicles, with the change affecting only seven or eight Member States. Furthermore, the fact 
that motorcycles are responsible for a significant share of road crashes and environmental pollution 
(air and noise), and may also take part in international traffic, appears to justify their regular testing 
while leaving the specification of the frequency and contents of the inspections to Member States. 

In terms of proportionality, as the level of intervention and associated costs increase from PO1a to 
PO3,  the  level  of  positive  impacts  also  increases,  although  not  proportionally  (as  shown  by  the 
efficiency ratios). In general, the scope of the options is limited to what can best be achieved at the 
EU level (in terms of harmonisation of methods and scope of testing, as well as in finding common 
solutions to ensure efficient sharing and access to the necessary vehicle data). For example, vehicles 
that are mostly used locally, such as mopeds and tractors are not targeted by the retained measures. 
At the same time, there are differences in the focus and extent to which the options aim to harmonise 
the scope of vehicles and the content of testing.  

307 

 
 
As  for  the  choice  of  the  instrument  for  Union  action,  amending  the  existing  RWP  Directives  is 
considered to be the most appropriate solution. This allows achieving the objectives through taking 
the next logical step in the process of gradual harmonisation in this area, while leaving sufficient 
room for manoeuvre for Member States to implement the changes in their specific national context, 
by continuing to apply well-established national arrangements in roadworthiness testing. This choice, 
using  minimum  requirements  instead  of  a  one-size-fits-all  approach  will  also  allow  industry  to 
develop the most efficient technical solutions that this continuously evolving field requires. 

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ANNEX 15: MONITORING 

The following elements related to RSI are important for the monitoring: 

•  The biennial RSI reports drawn up by Member States cover major and dangerous deficiencies 
detected  during  roadside  inspections  of  heavy-duty  vehicles  (lorries,  buses/coaches,  and 
tractors). As permitted by the RSI Directive, some Member States apply  targeted inspections 
based on the risk rating of transport undertakings, which can significantly increase the share of 
vehicles found defective at the roadside. Although this increases the effectiveness of the measure, 
it also means that the results reported by those Member States are not representative of the actual 
share of defective vehicles that may be circulating. In addition, those reports are not comparable 
to reports from other Member States that do not apply targeted checks. Their usefulness is thus 
limited. 

• 

Instead, reporting the results of PTIs, which are collected by all Member States and cover almost 
the  entire  vehicle  fleet  will  be  a  much  more  useful  source  of  information,  allowing  better 
comparability of the implementation and results achieved according to the effectiveness criteria, 
e.g., in terms of the numbers of defective and tampered vehicles detected (even if not perfect due 
to varying stringency of PTIs among Member States). For vehicles that are subject to PTI, this 
should be the primary reference, with  RSI results a possible addition.  On the other hand, for 
vehicles that remain outside of the scope of PTI, RSI results can be a valuable source to assess 
the implementation of roadworthiness testing in the EU. The frequency of reporting (biennial) is 
considered adequate. 

•  To gain a clearer view and to monitor the evolution the share of high-emitting vehicles, remote 
sensing data should be available from all Member States. Such data would provide an overview 
of the state of the vehicle fleet and help identify recurrent issues with specific technologies and 
brands or models that should be subject to further investigation e.g., through market surveillance 
actions and may be subject to recalls and software updates469. 

• 

In addition, as demonstrated by the evaluation and this impact assessment, data about the number 
of PTI centres, PTI lanes and inspectors are scarce, which hinder the accurate assessment of the 
effects of the policies implemented so far as well as the that of the impacts of measures still to 
be adopted. It is therefore necessary that Member States regularly inform the Commission about 
these  basic  data,  which  should  be  part  of  the  biennial  reports  starting  from  the  date  of 
implementation of the revised RWP. 

To measure the progress and the actual effects of the initiative, the following operational objectives 
and indicators have been identified: 

Operational objective 

Indicators 

469  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 

309 

 
 
 
 
 
Operational objective 

Indicators 

Apply  newly  available  safety  and  emission  testing 
methods at PTI and RSI 

Number of MSs applying test methods specific to EVs 

Number of MSs applying ePTI methods 

Number of MSs applying PN measurement 

Number of MSs applying NOx measurement 

Number of MSs applying remote sensing  

-  To screen pollutant emission 
-  To measure noise 

Number of MSs applying plume chasing 

Numbers of vehicles screened by remote sensing / plume 
chasing 

Interconnect  Member  States’  vehicle  registers  and 
odometer databases through a common hub 

Number of MSs having an odometer database 

Number of MSs connected to the MOVE-HUB 

Number of messages sent per month 

Digitalise vehicle documents 

Number of MSs issuing digital PTI certificates 

Reduce the number of defective and tampered vehicles 
on EU roads 

Number of MSs issuing digital registration certificates 

Number of defective vehicles detected at PTI/RSI 

-  With safety-related defects 
-  With emissions-related defects 

Number  of  vehicles  stopped  at  RSI  following  remote 
emission screening 

Number  of  vehicles  invited  to  PTI  following  remote 
emission screening 

The data for assessing these operational objectives will draw on regular reporting by Member States 
as well as ad hoc data collection actions, including by data exchange systems, such as the MOVE-
HUB. 

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ANNEX 16: SYNERGIES WITH OTHER POLICY INSTRUMENTS 

Roadworthiness testing relies on the technical specifications of the vehicles470 that are harmonised at 
EU level and beyond (UNECE471). Vehicle registration remains a national competence, although it 
relies on the Certificate of Conformity also defined in type-approval legislation472. The most recent 
and  relevant  safety-  and  emissions-related  type-approval  regulations  are  the  General  Safety 
Regulation (GSR)473 and the Euro 7 Regulation (EU) 2024/1257474. The GSR requires that, from 
July 2022, new types of motor vehicles are equipped with advanced driver assistant systems aimed 
at  reducing  the  number  of  fatalities  and  serious  injuries;  these  will  also  be  used  in  automated 
vehicles475. The Euro 7 standards will gradually replace existing emission rules for cars and vans 
(Euro 6) and lorries and buses (Euro VI), ensuring that new cars, vans, lorries and buses are cleaner 
in  real  driving  conditions  and  that  they  remain  clean  for  longer  than  required  by  the  existing 
(durability)  rules.  However,  for  passenger  cars  and  vans,  the  current  Euro  6  test  conditions  and 
exhaust emissions limits were maintained, as well as the current Euro VI testing conditions for buses 
and lorries.  

The focus of the RWP is different from the market surveillance legislation mentioned above. Whereas 
market  surveillance  provisions  aim  to  ensure  that  vehicles  continue  to  meet  their  type-approval 
requirements when placed on the market and for a limited period thereafter, and so are effectively 
focusing on the responsibilities of the manufacturer, the RWP focuses on ensuring that minimum 
standards  are  maintained  by  owners  throughout  the  lifetime  of  the  vehicle.  Also,  while  market 
surveillance  requires  testing  a  limited  number  of  vehicles  per  model,  PTI  applies  to  almost  all 
registered vehicles. Thus, the RWP complements the market surveillance legislation in ensuring road 
safety and the environmental performance of vehicles during their lifetime. 

Since 20 May 2023, real-world fuel and/or energy consumption data are collected from light vehicles 
when they undergo PTI, as required by the rules on on-board fuel consumption monitoring476. This 
is made possible since from that date, all PTI centres are required to be equipped with scan tools 
capable of reading out data from the on-board diagnostics of the vehicle. The same kind of data could 
also be collected from heavy-duty vehicles (HDVs) undergoing PTI as soon as the corresponding 

470 Cf. the various type-approval legislation (Regulation (EU) 2018/858, Regulation (EU) 167/2013, Regulation (EU) 
168/2013). 
471 World Forum for Harmonization of Vehicle Regulations of the United Nations Economic Commission for Europe. 
For example, a proposal has been endorsed in UNECE General Safety Provisions Working Party to introduce odometer 
accuracy and anti-tampering provisions in UN Regulation No. 39, 02 series of amendment. 
472 https://eur-lex.europa.eu/eli/reg/2018/858/oj  
473 https://eur-lex.europa.eu/eli/reg/2019/2144/oj  
474 Regulation - 2024/1257 - EN - EUR-Lex  
475 For all new vehicle types from 6 July 2022 onwards and for all new vehicles from 7 July 2024, the following safety 
features  are  mandatory:  for  all  road  vehicles (cars,  vans,  trucks  and  buses)  -  intelligent  speed  assistance,  reversing 
detection with camera or sensors, attention warning in case of driver drowsiness or distraction, event data recorders as 
well as an emergency stop signal; for cars and vans - additional features such as lane keeping systems and automated 
braking; for buses and trucks - technologies for better recognising possible blind spots, warnings to prevent collisions 
with pedestrians or cyclists and tyre pressure monitoring systems. 
476  Commission  Implementing  Regulation  (EU)  2021/392  on  the  monitoring  and  reporting  of  data  relating  to  CO 2 
emissions from passenger cars and light commercial vehicles, https://eur-lex.europa.eu/eli/reg_impl/2021/392/oj  

311 

 
 
 
 
legislation so requires. 

The Commission is also currently working on an initiative on fair and non-discriminatory access to 
in-vehicle data477, which is crucial for technical inspection centres to be able to carry out their daily 
tasks.  That  initiative  will  complement  the  Commission’s  proposal  for  the  Data  Act478  by  more 
specific provisions on access to functions and resources, essential for the provision of data-dependent 
services in the automotive sector. It will standardise the relevant datasets and ensure effective non-
discriminatory and secure access for aftermarket and mobility services. A range of automotive service 
providers,  including  vehicle  repair  and  inspection  companies  and  authorities  have  called  for  an 
ambitious Commission proposal, to ensure a level-playing field and unhindered access to the relevant 
in-vehicle data479. The revision of the PTI Directive (and of its implementing act on the technical 
information necessary for roadworthiness testing480) could complement the access to in-vehicle data 
proposal,  through  specific  provisions  facilitating  access  to  the  data  necessary  for  technical 
inspections. 

Further  EU  legislation  relevant  for  vehicle  registration  and  roadworthiness  are  the  Single  Digital 
Gateway Regulation (SDG)481 and the Directive on the treatment of end-of-life vehicles (ELV)482. 
The SDG Regulation provides for registering a motor vehicle originating from or already registered 
in  a  Member  State  among  the  procedures  to  be  carried  fully  online,  where  possible.  The 
Commission’s  proposal  to  replace  the  ELV  Directive  with  a  Regulation483  aims  at  linking  export 
requirements  to  roadworthiness  and  relies  on  more  effective  and  efficient  exchange  of  vehicle 
registration data among national authorities, including customs authorities, to address the problem of 
missing  vehicles.  For  that  purpose,  it  calls  for  a  proposal  to  revise  the  Vehicle  Registration 
Documents Directive. It specifically suggests that the revision of the VRD Directive should require 
electronic recording of data related to the reasons for the cancellation of a registration of a vehicle, 
especially if a vehicle has been treated as an end-of-life vehicle in an authorised treatment facility, 
re-registered in another Member State, exported outside the Union, or stolen.  

In March 2023, the Commission made three other road safety-related proposals, out of which two are 
relevant for the revision of the RWP, namely the revision of the Directives on driving licences and 
on facilitating cross-border exchange of information on road-safety-related traffic offences484. 
Coherence  will  need  to  be  ensured  between  the  rules  on  vehicle  registration  documents  and  the 
possible  future  digitalisation  of  documents,  as  well  as  regards  the  exchange  of  vehicle-related 
information among Member States for enforcement purposes. 

EU legislation on road tolling485 also relies on the harmonised Union codes defined in the VRD 
Directive,  which  were  last  (slightly)  amended  as  part  of  the  revision  of  rules  on  road  pricing 

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13180-Access-to-vehicle-data-functions-

477 
and-resources_en  
478 https://ec.europa.eu/commission/presscorner/detail/en/ip_22_1113  
479 See e.g. open letter from CITA: https://citainsp.org/wp-content/uploads/2023/03/L2023-006-Data-Act.pdf  
480 https://eur-lex.europa.eu/eli/reg_impl/2019/621/oj  
481 https://eur-lex.europa.eu/eli/reg/2018/1724/oj  
482 https://eur-lex.europa.eu/eli/dir/2000/53/oj  
483 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52023PC0451  
484 COM(2023) 127 and COM(2023) 126 final, https://transport.ec.europa.eu/news-events/news/european-commission-
proposes-updated-requirements-driving-licences-and-better-cross-border-2023-03-01_en  
485 Directive (EU) 2019/520 on the interoperability of electronic road toll systems and facilitating cross-border exchange 
of information on the failure to pay road fees in the Union, https://eur-lex.europa.eu/eli/dir/2019/520/oj  

312 

 
 
 
(Eurovignette Directive)486.  

Finally,  the  EU  Decision  on  the  Digital  Decade  Policy  Programme  2030487  foresees  that  the 
European Parliament, the Council, the Commission and the Member States shall cooperate with a 
view to  achieving digital targets in  the  Union by 2030. Among those, the  digitalisation of public 
services, where there is 100% online accessible provision of key public services and, where relevant, 
it is possible for citizens and businesses in the Union to interact online with public administrations.  

486 Directive (EU) 2022/362 amending Directives 1999/62/EC, 1999/37/EC and (EU) 2019/520, as regards the charging 
of vehicles for the use of certain infrastructures, https://eur-lex.europa.eu/eli/dir/2022/362/oj  
487 Publications Office (europa.eu) 

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ANNEX 17: EVALUATION REPORT (SEPARATE DOCUMENT) 

Separate document: Evaluation SWD and specific annexes. 

314