Impact assessment support study on the Directives of the Roadworthiness package. Annex 9, Stakeholders consultation report.
Date: 2025-09-11
Institutions: Directorate-General for Mobility and Transport
Subjects: common transport policy, directive (EU), impact study, motor vehicle, pollution control measures, public consultation, road safety, road transport, roadworthiness tests, technical specification, vehicle registration

IMPACT ASSESSMENT SUPPORT STUDY ON THE 
DIRECTIVES OF THE ROADWORTHINESS PACKAGE  

Annex 9 - Stakeholder Consultation Report 

Contract no. MOVE/C2/SER/2022-583/SI2.895928, under FWC 
no. MOVE/2022/OP/0001 

Written by: Ian Skinner (TEPR) 
September 2023 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 
Directorate-General for Mobility and Transport 
Directorate C — Land 
Unit C.2 — Road safety 

Contact: Peter SZATMARI  

E-mail: Peter.SZATMARI@ec.europa.eu 

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
IMPACT ASSESSMENT SUPPORT STUDY ON THE 
DIRECTIVES OF THE ROADWORTHINESS PACKAGE  

Annex 9 – Stakeholder Consultation Report 

Contract no. MOVE/C2/SER/2022-583/SI2.895928, under FWC 
no. MOVE/2022/OP/0001 

Directorate-General for Mobility and Transport  
IA Support Study for the revision of the RWP   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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TABLE OF CONTENTS 

1. 

INTRODUCTION .................................................................................................... 6 

a. 

Summary of consultation activities performed .................................................. 6 

2. 

CONSULTATION STRATEGY – APPROACH TAKEN AND STAKEHOLDERS TARGETED ........ 7 

a. 
b. 
c. 

Overall approach .......................................................................................... 7 
Stakeholder consultation tools used ................................................................ 7 
Stakeholder groups ...................................................................................... 7 

3. 

CONSULTATION ACTIVITIES – THE METHODOLOGY AND TOOLS USED ........................ 8 

a. 
b. 
c. 
d. 

Online survey .............................................................................................. 8 
Interviews ................................................................................................... 9 
IIA ............................................................................................................ 11 
OPC ........................................................................................................... 12 

4. 

CONSULTATION ANALYSIS METHODOLOGY ............................................................. 12 

5. 

6. 

7. 

a. 
b. 
c. 

Survey and interview analysis ....................................................................... 12 
IIA analysis ................................................................................................ 13 
OPC analysis ............................................................................................... 13 

IDENTIFIED CAMPAIGNS ....................................................................................... 13 

CONTRIBUTION  OF  CONSULTATION  ACTIVITIES  TO  THE  IMPACT  ASSESSMENT 
SUPPORT STUDY .................................................................................................. 13 

ANALYSIS AND INTERPRETATION OF THE CONSULTATION RESULTS .......................... 13 

a. 
b. 
c. 
d. 
e. 
f. 
g. 
h. 
i. 
j. 
k. 
l. 

Baseline ..................................................................................................... 14 
Problems, problem drivers and objectives ....................................................... 14 
Policy measures: Scope of PTI Directive ......................................................... 15 
Policy measures: Frequency of PTI tests ......................................................... 16 
Policy measures: Mutual recognition of PTI certificates ..................................... 17 
Policy measures: Electronic roadworthiness certificates .................................... 17 
Policy measures: Content of PTI tests ............................................................ 17 
Policy measures: Scope of RSI Directive ......................................................... 19 
Policy measures: Content of RSIs .................................................................. 19 
Policy measures: Testing software in PTIs and RSIs ......................................... 20 
Policy measures: Access and exchange of information/data .............................. 20 
Policy measures: Measures relating to vehicle registration ................................ 21 

8. 

ANNEXES ............................................................................................................ 22 

a. 
b. 
c. 
d. 
e. 
f. 

Annex 1 – Survey Questionnaire ................................................................... 22 
Annex 2 – Graphs relating to the survey ........................................................ 22 
Annex 3 – Interview checklist ....................................................................... 22 
Annex 4 – Analytical summary of the input to the IIA ...................................... 22 
Annex 5 – Open Public Consultation quantitative charts ................................... 22 
Annex 6 – Open Public Consultation written summary ...................................... 22 

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ANNEX 9 – STAKEHOLDER CONSULTATION REPORT  

1  INTRODUCTION 

This report provides an overview of the stakeholder consultation activities that were carried 
out  as  part  of  the  Impact  Assessment  Support  Study  on  the  Directives  of  the 
Roadworthiness  Package  (RWP).  The  main  body  of  this  report  outlines  the  consultation 
strategy,  activities  and  methodology,  along  with  the  methodologies  used  for  the  various 
analyses  and  includes  a  high-level  analysis  of  the  responses  to  the  various  consultation 
activities. The Annexes of the report include the consultation tools, e.g. survey and interview 
questions, relevant graphs (e.g. those relating to the closed questions in both the survey 
and the Open Public Consultation (OPC)) and an analysis of the Commission’s consultation 
activities, e.g. the Inception Impact Assessment (IIA) and the OPC.  

Summary of consultation activities performed 

The stakeholder consultation included the following activities:  

-  Exploratory interviews. The aim of the exploratory interviews was to have an early 
engagement  with  key  stakeholders  (including  authorities,  industry  and  user 
representatives). However, it was agreed with the Commission that, given the state 
of the development of the policy measures, it was not necessary to undertake the 
intended full exploratory interviews. Instead, 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 project, including the distribution of 
the survey and the identification of potential interviewees. In addition, user groups, 
such as FEMA, FIA and IRU, were emailed to inform them about the project and to 
provide them with the opportunity of a call, if they were interested in having one. 

-  Targeted online survey. As agreed with the Commission, 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  2023  and  14  August,  which  was  a  two-week  extension 
compared to the original deadline. 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.  Seventy-five 
responses to the survey were received.    

-  Targeted  stakeholder interviews.  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. 

- 

IIA. This was concluded before the study began. It was open for comment on the 
Commission’s ‘Have Your Say’ website between 4 October and 1 November 2021. 
Responses were received from 210 unique respondents, although a large number 
of  these  were  linked  to  a  campaign,  which  left  36  responses  that  were  analysed 
individually (see Section 1.4).  

-  OPC. This also concluded before the study began. It was live between 6 July and 
28 September 2022 on the Commission’s ‘Have Your Say’ website. Overall, there 
were  907  responses,  although  the  vast  majority  were  part  of  a  campaign  from 
predominantly French citizens, which left 162 indvidual responses.   

The aim of this report is to: 

• 

Inform policymakers on the outcome of all the consultation activities. 

6 

 
 
• 

Inform stakeholders on how their input has been taken into account. 

1.1  Consultation strategy – approach taken and stakeholders targeted 

1.1.1  Overall approach 

The stakeholder consultation for this impact assessment support study aimed to gather the 
views of relevant stakeholders. As agreed with the Commission at the Kick-Off meeting, the 
focus of the survey and interviews was on the details of the policy measures that might be 
adopted as part of the revision of the Roadworthiness Package, particularly the costs and 
potential  impacts  of  these.  This  was  due  to  the  fact  that  the  Commission  had  already 
discussed  the  problem  drivers  and  objectives  of  the  proposed  revision  of  the  RWP 
extensively with stakeholders, e.g. in the Roadworthiness Expert Group. 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. 

1.1.2  Stakeholder consultation tools used 

Table  1-1  provides  an  overview  of the stakeholder  consultation  tools  used  in this  impact 
assessment support study, including which stakeholders were targeted and the intended 
role of this engagement within the impact assessment. 

Table 1-1: Overview of stakeholder consultation tools used 

Activity 

Stakeholders involved 

Role within the support study 

1. Exploratory 
interviews / 
introductory 
calls 

2. Targeted 
survey 

3. Targeted 
interviews 

4. Consultation 
activities carried 
out by the 
Commission 

CITA, EReg, CORTE and EGEA 

National and regional authorities.  

Industry associations and 
companies. 

User groups, NGOs and academics. 

the  engagement  of 

To  discuss 
these 
organisations  and  their  members  in  the  project, 
including  the  distribution  of  the  survey  and  the 
identification of potential interviewees. 

To explore stakeholders’ views on the details of 
the measures, their potential costs (and savings) 
and potential impacts.  

To  explore  in  depth  relevant  topics  with  key 
representatives  from  each  stakeholder  group, 
also  to  ensure  that  input  was  received  from 
stakeholders not covered in the survey. 

Analysis of activities led by the 
Commission (OPC and IIA) 

To enable stakeholders to provide their views to 
the Commission on the potential changes to the 
RWP.  

1.1.3  Stakeholder groups 

The  stakeholder  groups  targeted  in  the  stakeholder  consultation  activities  for  the  impact 
assessment support study are outlined in Table 1-2 below, including an indication of the 
activities / tools used for engaging with each group. 

Table 1-2: Key stakeholder groups and mapping against activities 

High-level 
stakeholder 
group 
Public authorities 

Description 

Authorities  involved  in  different  activities  relating  to  the 
RWP, 
inspection, 
enforcement and policy. Initial engagement was undertaken 

registration, 

including 

vehicle 

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IA Support Study for the revision of the RWP   

Stakeholder 
engagement activity 

Exploratory interviews 
Targeted surveys 
Targeted interviews 

 
High-level 
stakeholder 
group 

Description 

via their various representative associations, such as CITA, 
EReg and CORTE. 

Industry 
associations  and 
companies 

those 

Associations and companies involved in different aspects of 
RWP,  particularly 
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. 

involved 

in 

Stakeholder 
engagement activity 

Exploratory interviews 
Targeted surveys 
Targeted interviews 

User groups 

Groups  representing  the  drivers  of  the  various  vehicles 
covered  by  the  RWP  were  engaged  with  to  identify  their 
views on the potential measures. 

Targeted interviews 

Road  safety  and 
environmental 
NGOs 

The views of specialist NGOs were also sought to ensure 
that the safety and environmental aspects of the measures 
were sufficiently considered.  

Targeted interviews 

Research 
academia 

/ 

Interviews  were  undertaken  with  selected  road  safety 
academic experts. 

Targeted interviews 

1.2  consultation activities: methodology and tools used 

This section contains more details on each of the consultation methods used in the study, 
including the methodology that was taken and an overview of the respondents to each.    

1.2.1  Online survey 

The survey and interview questions were developed in consultation with the Commission 
and  focused  on  the  details,  costs  and  potential  impacts,  of  the  measures  under 
consideration.  The  survey  and  interview  questions  were  developed  using  a  common 
structure to facilitate their development and analysis.  

The survey was structured by groups of measures, e.g. all those measures that related to 
the scope of the PTI Directive were grouped together, to enable stakeholders to identify and 
respond only to those measures of relevance to them. Respondents were also able to skip 
questions relating to individual measures in the survey, if they wished to. As a result of this 
approach, and the need to ask similar questions of all stakeholder groups, separate surveys 
for authorities and industry respondents were not developed. 

The  survey  contained  closed,  semi-quantitative  questions  supported,  as  appropriate,  by 
open text boxes. The focus of the survey was to seek the views of stakeholders on: 

•  The measures that might be implemented to improve the functioning of the RWP. 

•  The possible costs and potential savings to different stakeholders resulting from the 

implementation of these potential measures.  

• 

Information on the potential impacts of the different measures. 

A set of survey questions is found in Annex 1. 

The survey was available online via the survey platform Alchemer between 26 June 2023 
and 14 August. The original plan was to close the survey at the end of July. However, due 
to the relatively low number of responses that had been received by mid-July, which was 
not surprising as this period clashed with many people’s summer holidays, the deadline was 
extended. Surveys were distributed to, and via, the organisations that had been engaged 
with in the course of the introductory calls (see below), as well to other stakeholders that 

8 

 
 
 
 
 
 
 
 
 
had  been  identified,  and  to  the  members  of  the  Commission’s  Roadworthiness  Expert 
Group.  

A total of 75 survey responses were received. Table 1-3 provides an overview of the survey 
responses received by stakeholder type.  

Table 1-3: Survey responses received by stakeholder type 

Stakeholder group 

Number of completed survey responses 

Member State National authorities   

Other national authorities 

Regional authorities 

Representative associations of authorities 

Total public authorities 

Inspection bodies and their representatives 

Testing equipment manufacturers and their representatives 

Vehicle / vehicle equipment manufacturers; their representatives 

Other industry 

Total industry 

Users 

Research 

Others 

Total users, research, others 

TOTAL 

26 

4 

2 

2 

34 

19 

8 

4 

3 

34 

3 

1 

3 

7 

75 

The graphs presenting the overview of the views of the respondents to the survey for the 
survey’s closed questions can be found in Annex 2. The detailed feedback was taken into 
account in the development, analysis and cost assessment of the respective measures. A 
higher-level  analysis  of  the  responses  to  the  survey  is  included  in  the  analysis  of  the 
consultation results (see Section 1.6 of this report).  

1.2.2  Interviews 

As  noted  above,  the  exploratory  interviews  undertaken  for  this  project  were  more  like 
introductory calls; the recipients of these calls are detailed in Table 1-4. In addition, initial 
contact was made via email with relevant user groups, i.e. the FIA (car drivers), IRU (lorry 
drivers) and FEMA (motorcyclists).  

Table 1-4: Exploratory interviews 

Stakeholder 

Stakeholder group 

Date 

CITA 

EReg 

CORTE 

EGEA 

Representative 
of 
inspection authorities and companies 

association 

Representative 
authorities 
registration  

association 
in 

of 
vehicle 

involved 

24 May 2023 

1 June 2023 

Representative 
organisations 
transport enforcement  

involved 

association 

of 
road 

15 June 2023 

in 

Representative  association  of  garage 
equipment suppliers 

22 June 2023 

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The interview questions were tailored to target three different target audiences:   

•  For authorities and individual companies that completed a survey response, the 
interview questions focused on clarifying their responses to the survey, particularly 
in relation to costs, with the hope of obtaining further information on the latter. 

•  For trade associations that completed the survey, the interview questions put more 
emphasis  on  clarifying  their  high-level  responses  to  the  survey,  as  trade 
associations  were  unlikely  to  have  access  to  more  detailed  cost  information, 
although relevant questions were still asked. 

•  For  those  stakeholders  who  are  not  going  to  be  surveyed  (e.g.  NGOs, 
academics and user groups), the interview aimed to identify their high-level views 
on the measures that were being considered. While questions on costs were asked, 
it  was  not  expected  that  relevant  information  would  be  obtained  from  these 
stakeholders. 

This initially led to the development of two separate sets of interview questions: one focusing 
on  those  interviewees  who  were  not  surveyed;  the  other  focusing  on  “post-survey” 
questions  for  those  who  had  completed  the  survey,  which  covered  public  authorities, 
individual companies and trade associations. However, the latter was ultimately not used, 
as  each  interviewer  reviewed  their  interviewee’s  responses  and  included  follow-up 
questions in the same spreadsheet. The interview questions for those who did not respond 
to the survey are presented in Annex 3.  

Member  State  authorities  were  identified  and  contacted  via  relevant  representative 
associations,  such  as  EReg,  CITA  and  CORTE,  as  well  as  via  the  members  of  the 
Commission’s Roadworthiness Expert Group. Industry interviewees were similarly identified 
via relevant representative groups, e.g. CITA and EGEA. In addition, some stakeholders, 
such  as  user  representatives,  NGOs  and  academics,  had  been  identified  as  being 
appropriate  interview  candidates,  so  these  were  contacted  directly.  Responses  to  the 
survey  were  also  reviewed  to  identify  other  stakeholders  that  it  might  be  interesting  to 
interview, while some requests for an interview were received, which were taken up where 
it was considered that these would bring added value. 

Interviews were undertaken between 26 June 2023 and the end of August 2023. As with 
the surveys, the time period was extended as a result of a low response rate over the first 
part of the holiday period. Overall, 37 interviews were undertaken (see Table 1-5). 

Table 1-5: Number of interviews by stakeholder group 

Stakeholder group 

Member State authorities and their representatives 

Third country authorities 

Public authorities  

Inspection bodies and their representatives 

Testing equipment manufacturers and their representatives 

Vehicle and vehicle equipment manufacturers and their representatives 

Other industry 

Industry 

Users / drivers 

NGOs 

Research 

Number 
undertaken 

of 

interviews 

11 

2 

13 

6 

5 

3 

1 

15 

5 

1 

3 

10 

 
 
Stakeholder group 

Total users, research, others 

TOTAL 

Number 
undertaken 

of 

interviews 

9 

37 

The  detailed  feedback  from  the  interviews  was  taken  into  account  in  the  development, 
analysis and cost assessment of the respective measures. A higher-level analysis of the 
responses to the survey is included in the analysis of the consultation results (see Section 
1.6 of this report).  

1.2.3  IIA  

The IIA was open for comment on the Commission’s ‘Have Your Say’ website between 4 
October and 1 November 2021. A total of 210 unique responses were received in response 
to the Commission’s IIA, although a large number of these were linked to a campaign  (see 
Section 1.4), which left 36 responses that were analysed individually. A breakdown of the 
responses to the IIA, both with and without the campaign, is presented in Table 1-6. 

Table 1-6: Classification and number of stakeholders responding to the IIA 

Category 

Total number of responses 

Non-campaign responses 

Number of 
respondents 

Percentage of 
total number of 
respondents 

Number of 
respondents 

Percentage of total 
number of 
respondents 

Academic 
institution  

/ 

research 

Business association 

Company/business 
organisation 

Consumer organisation 

1 

9 

6 

3 

EU citizen 

171 

Non-EU citizen 

NGO 
organisation) 

(Non-governmental 

Public authority 

Other 

Total 

3 

6 

2 

9 

0% 

4% 

3% 

1% 

81% 

1% 

3% 

1% 

4% 

1 

8 

6 

2 

3 

2 

6 

2 

6 

3% 

22% 

17% 

6% 

8% 

6% 

17% 

6% 

17% 

210 

100% 

36 

100% 

The analysis of these responses to the IIA is presented in Annex 4. It is important to note 
that  the  respondents  were  commenting  on  the  objectives,  problem  drivers  and  policy 
measures that were set out and described in the IIA, not necessarily those that have evolved 
in the course of the study (as presented in the main report).  

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1.2.4  OPC  

The OPC was live between 6 July and 28 September 2022 on the Commission’s ‘Have Your 
Say’ website. Overall, there were 907 responses, although the vast majority were part of a 
campaign from predominantly French citizens (see Section 1.4), which left 162 individual 
responses. A breakdown of the responses to the OPC, both with and without the campaign, 
is presented in Error! Reference source not found.. 

Table 1-7: Classification and number of stakeholders responding to the OPC 

Category 

Total number of responses 

Non-campaign responses 

Number of 
respondents 

Percentage of 
total number of 
respondents 

Number of 
respondents 

Percentage of total 
number of 
respondents 

Academic / research 
institution 

Business association 

Company/business 
organisation 

Consumer organisation 

2 

35 

47 

3 

0.2% 

3.9% 

5.2% 

0.3% 

EU citizen 

758 

83.6% 

Environmental organisation 

Non-EU citizen 

NGO (Non-governmental 
organisation) 

Public authority 

Trade union 

Other 

Total 

1 

10 

18 

10 

5 

18 

0.1% 

1.1% 

2.0% 

1.1% 

0.6% 

2.0% 

2 

35 

43 

3 

29 

1 

0 

18 

10 

5 

18 

1.2% 

21.3% 

26.2% 

1.8% 

17.7% 

0.6% 

0.0% 

11.0% 

6.1% 

3.0% 

11.0% 

100% 

907 

100% 

162 

The  analysis  of  the  responses  to  the  OPC  is  presented  in  Annex  6.  As  with  the  IIA,  the 
respondents were commenting on problems and potential measures that were set out in the 
OPC, so not necessarily those that have evolved in the course of the study (as presented 
in the main report).  

1.3  Consultation Analysis methodology 

1.3.1  Survey and interview analysis 

In  order  to  support  the  use  of  the  results  of  the  survey,  graphs  were  prepared  of  the 
responses to the survey’s closed questions; these graphs are included in Annex 2 of this 
report. The responses to the open survey questions were collated in an Excel spreadsheet, 
along with the responses to the interviews. This was shared with team members responsible 
for analysing the measures, and for the purpose of the higher-level analysis included in this 
report (see Section 1.6).  

12 

 
 
 
1.3.2  IIA analysis 

The responses to the IIA were collated and analysed, which is included in Annex 4 of this 
report. The analysis of the responses to the IIA were also considered in the analysis of the 
consultation results (see Section 1.6 of this report).   

1.3.3  OPC analysis 

Similarly, the responses to the OPC were collated and analysed, the results of which are 
included in Annex 6 of this report. In order to support the analysis of the OPC responses, 
graphs were developed to represent the split of responses to the closed questions, with an 
appropriate  consideration  given  to  the  responses  that  were  part  of  the  campaign  (see 
Section 1.4). The results were presented for all respondents, and by the main categories of 
stakeholders, i.e. industry respondents, public authorities, citizens and ‘other’ stakeholders 
(which includes user groups, NGOs, academics, etc). In addition, for key questions, graphs 
representing  the  responses  from  companies  broken  down  by  company  size  (specifically 
SMEs compared to larger enterprises) were prepared, as were, for industry respondents, 
graphs  based  on  their  specific  interests,  e.g.  inspection  body,  testing  equipment 
manufacturer, etc. These graphs can be found in Annex 5 of this report.     

The  analysis  of  the  responses  to  the  OPC  were  also  considered  in  the  analysis  of  the 
consultation results (see Section 1.6 of this report).  

1.4 

Identified campaigns 

There  was  a  clear  campaign  in  the  responses  to  both  the  IIA  and  the  OPC  from 
motorcyclists  (who  were  either  French  or  responded  in  French),  who  were  against  the 
extension of the PTI Directive to motorcycles. As a result, 731 of the 907 responses to the 
OPC  were  removed  from  the  data  that  was  used  to  produce  the  graphs  to  support  the 
analysis of the closed questions of the OPC. Of the 210 unique responses to the IIA, 174 
were  linked  to  the  campaign.  In  the  analysis  of  the  open  questions  of  the  OPC  and  the 
analysis  of  the  responses  to  the  IIA,  the  views  of  the  campaign  were  mentioned  where 
relevant, with reference to the fact that there was a campaign. 

1.5  Contribution of consultation activities to the impact assessment support 

study  

As  noted  above,  the  detailed  feedback  from  the  survey  and  interviews  was  taken  into 
account in the development, analysis and cost assessment of the respective measures, as 
presented in the main report. The responses to the IIA and OPC fed into the development 
of the measures that were further developed in the course of the study. 

1.6  Analysis and interpretation of the consultation results 

This  section  provides  a  high-level  summary  of  the  key  findings  from  the  targeted 
consultation  (survey  and  interviews),  the  IIA  and  the  OPC,  split  by  baseline,  problem 
definition and then the respective measures.  

As noted above, the survey and interviews followed the same structure, so the results of 
the  stakeholder  engagement  using  these  two  tools  are  addressed  together;  these  tools 
focused  on  the  policy  measures  that  were  being  considered.  The  analysis  of  the  policy 
measures is grouped in the same way as the measures were grouped for the purpose of 
the  survey  and  interviews,  i.e.  according  to their focus,  such  as  those  that  extended  the 
scope  of  the  PTI  Directive.  The  OPC  also  asked  respondents  for  their  views  on  certain 
measures that could be taken to amend the respective Directive, while the responses to the 
IIA  tended  to  be  more  general,  e.g.  calling  for  a  specific  aspect  of  a  vehicle,  e.g.  their 

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emissions, to be better addressed. In this section, the responses to the OPC and IIA are 
used to complement the analysis of the survey and interview responses, where appropriate.  

1.6.1  Baseline 

The analysis in this section is based on the responses to the survey and interviews, as there 
was little relevant comment on the baseline in either the IIA or the OPC.  

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 most positive response – 75% (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 
impact1 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 impact2 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  theme  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 problems of detecting tampering 
in the course of a PTI, particularly tampered odometers. 

1.6.2  Problems, problem drivers and objectives  

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

1 Those rating this ‘5’, ‘6’ or ‘7’ out of ‘7’. 

2 Those rating this ‘1’, ‘2’ or ‘3’ out of ‘7’. 

14 

 
 
 
Table 1-8: Problems and problem drivers presented in the survey  

In the survey, respondents were asked for their views on more detailed problem areas, and 
their associated drivers (see Table 1-8), 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  agreement3  –  around  two  thirds  or  more4  –  for  each  set  of 
problems  and  problem  drivers,  and  overwhelming  support  (at  least  89%)  for  each  of  the 
specific objectives5. 

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

1.6.3  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. On the other hand, those responses that were 
part of the campaign, as well as EU level and national motorcyclists’ groups, called for PTI 

3 Those answering ‘agree’ or ‘strongly agree’ 

4 Respectively, for Problem A and associated drivers (83%; 54, ten ‘no responses’/‘Don’t knows’), Problem B 
(84%; 56, eight ‘no responses’/‘Don’t knows’) and Problem C (65%; 39, 15 ‘no responses’/‘Don’t knows’)  

5  Respectively,  for  SO1  (96%;  64,  eight  ‘no  responses’/‘Don’t  knows’),  SO2  (91%;  60,  nine  ‘no 

responses’/‘Don’t knows’), SO3 (89%; 54, 14 ‘no responses’/‘Don’t knows’) 

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not  to  be  extended  to  motorcycles.  In  the  OPC,  there  was  only  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. 

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 level6 
to delivering SO2, i.e. extending the scope to motorcycles (80%; 41, 24 ‘no responses’ or 
‘Don’t  knows’);  agricultural  and  forestry  tractors  (78%;  31,  35  ‘no  responses’  or  ‘Don’t 
knows’); and light trailers (66%; 27, 34 ‘no responses’ or ‘Don’t knows’). In the survey and 
interviews, it was noted that many Member States already required a PTI for motorcycles, 
tractors  and/or  trailers.  Some  potential  challenges  of  this  measure  were  mentioned, 
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 
that these trailers are not registered in some countries, such as the Netherlands and France.  

In the responses to the OPC, SMEs were much more likely not to support extending the 
scope  of  the  PTI  Directive  to  motorcycles  than  large  enterprises,  with  38%  (eight)  not 
supporting  it,  compared  to  no  large  enterprises.  In  the  response  to  the  survey  and 
interviews,  it  was  suggested  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. 

1.6.4  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, at least two thirds 
of  respondents  believed  that  four  of  the  measures  would  contribute  to  a  high  level  to 
delivering  SO2,  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  contribution7  to 
delivering SO2.  

A  common  argument  in  favour  of  more  frequent  testing  for  N1  vehicles,  which  were 
mentioned in different consultation exercises, wase that such vehicles were used frequently, 
and often had a number of 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 able to test a vehicle in an RSI in the same way 
as it was in a PTI, while the potential cost of setting up a system to record and exchange 
this information was noted, as was the time that would be needed to amend each PTI to the 
take account of the recent RSI history of the vehicle. In relation to requiring a mandatory 

6 Those rating this ‘5’, ‘6’ or ‘7’ out of ‘7’. 

7 Those rating this ‘1’, ‘2’ or ‘3’ out of ‘7’. 

16 

 
 
 
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. 

1.6.5  Policy measures: Mutual recognition of PTI certificates 

The third set of measures included two alternative approaches – one more comprehensive 
than the other – 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 that 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 SO3. 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 SO3, 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.    

1.6.6  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  responses  (94%;  49,  23  ‘no  responses’  or  ‘Don’t 
knows’) believed that this measure would have a high contribution to addressing SO3, 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 theme of the responses. 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.  

1.6.7  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’) were in favour of measures to specifically tackle noise-related tampering 
/ noncompliance problems in vehicles inspected at the roadside. SMEs were much more 

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likely not to support this measure, with 29% (six) not supporting it, compared to no large 
enterprises.  

In the survey, around two thirds or more of respondents believed that the measures would 
contribute to delivering the respective SOs 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  SO1  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 SO2 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 have a contribution to addressing SO2, although a majority (79%; 
37, 28 ‘no responses’ or ‘Don’t knows’) thought that this measure would address SO1 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  SOs,  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 SO1 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  SO1  and  SO2  to  a  high 
level. In the open responses to the survey and the interviews, there was some concern 
regarding  the  feasibility  of  applying  NOx  testing  according  to  the  JRC  methodology  in 
northern Member States, particularly the requirement that testing be undertaken when the 
vehicle  has  a  warm  engine.  Again,  there  were  some  concerns  about  the  impact  of  any 
additional  costs  from  these  measures  on  SMEs  that  undertake  inspections,  particularly 
where the PTI system was decentralised.    

18 

 
 
1.6.8  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, SMEs were much more likely 
not  to  support  this  measure,  with  38%  (eight)  not  supporting  it,  compared  to  no  large 
enterprises. 

In  the  survey,  between  two-thirds  and  three-quarters  of  respondents  believed  that  the 
respective  measures  would  address  the  associated  SOs  at  a  high  level,  although  in  all 
cases at least half of the respondents to the survey did not express a view. At one end of 
this range, 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  SO1  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 SO2 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.   

1.6.9  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 were much more likely not to support either of these measures (29% (six) 
and 40% (eight), respectively), compared to no larger enterprises in both cases.  

In the responses to the survey, a majority of respondents thought that each of the proposed 
measures would contribute to addressing both SO1 and SO2 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 SO2 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 SO2 at a high level was plume chasing for commercial 
vehicles (61%; 14, 52 ‘no responses’ or ‘Don’t knows’). The responses relating to SO1 were 
similar  for  each  measure.  In  the  responses  to  the  open  questions  in  the  survey  and 
interviews, various respondents from national authorities were not convinced of the added 
value of requiring PN counting during an RSI, if this was also measured in the course of a 
PTI. It was also suggested that remote sensing would only be able to identify vehicles that 
exceed the  respective  emission  standards significantly,  rather than  being  able to  identify 
slight exceedances. 

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1.6.10 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 SO1 (86%; 
42,  26  ‘no  responses’  or  ‘Don’t  knows’)  and  SO2  (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.      

1.6.11 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 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  were  less  supportive  of  this 
provision than others, 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 
were less supportive of this measure (38%; five, two ‘no responses’ or ‘Don’t knows’) than 
others. 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 than others (31%; four, two ‘no responses’ or ‘Don’t knows’). 

In  the  survey,  a  majority  of  respondents  believed  that  further  defining  data  governance 
procedures and the means of access to vehicle technical information by testing centres free 
of charge and in standardised format would address both SO1 (87%; 45, 23 ‘no responses’ 
or ‘Don’t knows’) and SO3 (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 SO1 (81%; 34, 33 
‘no responses’ or ‘Don’t knows’) and SO2 (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  SO3  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 four RSIs, and so underlined that this measure should also be considered in the 
context of PTIs; indeed, 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 

20 

 
 
RSI report. A couple of respondents suggested that SMEs would benefit from having easier 
access to information.  

1.6.12 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 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 SOs. 
Over 90% of respondents believed that providing electronic access to relevant data to the 
registration authorities of other EU Member States through the use of a common IT system 
(95%; 38, 35 ‘no responses’ or ‘Don’t knows’) and adding a minimum set of new data to the 
vehicle register (93%; 42, 30 ‘no responses’ or ‘Don’t knows’) would address SO3 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 SO3 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 SO3 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.  The  latter  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 up-to-date as soon as 
relevant changes happen. It was suggested that there could be costs 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 being 
able to have more access to relevant standardised information. 

Directorate-General for Mobility and Transport 
IA Support Study for the revision of the RWP  

2  ANNEXES

Annex 1 – Survey Questionnaire 

Annex 2 – Graphs relating to the survey 

Annex 3 – Interview checklist 

Annex 4 – Analytical summary of the input to the IIA 

Annex 5 – Open Public Consultation quantitative charts 

The files present the graphs for, respectively: the overall responses and a breakdown by 
stakeholder  type;  industry  responses  by  company  size  (SMEs  compared  to  large 
enterprises); and the specific interests of industry respondents.  

Annex 6 – Open Public Consultation written summary 

22 

Annex 1 - Ricardo Roadworthiness Package (RWP) Impact 
Assessment (IA) Survey - June 2023

A. Introduction

Page description:
Objectives

Ricardo Energy & Environment (in a consortium with TRT, E3M Modelling, TEPR and the
Spark) has been appointed by the European Commission (DG MOVE) to support the
Commission in the preparation of an Impact assessment (IA) support study on the
Directives of the Roadworthiness package (RWP). The Directives involved are:

Directive 2014/45/EU on periodic roadworthiness tests, known as the Periodic
Technical Inspection (PTI) Directive.
Directive 2014/47/EU on technical roadside inspections (the Technical Roadside
Inspection (RSI) Directive).  
Directive 2014/46 (the Vehicle Registration Documents Directive).

The study will support DG MOVE in a potential revision of these Directives.

This survey has been developed as part of the stakeholder engagement aspect of the
project. It aims to explore the views of stakeholders on:

1. Their views on the measures that might be implemented to improve the functioning of

the RWP.

2. The possible costs and potential savings to different stakeholders resulting from the

implementation of these potential measures.

3. Obtain data on the potential impacts of the different measures.

The letter of support from the Commission can be found here.

Use of your input
The study team will keep the responses to the survey and will make use of your contribution
(information/data provided) only for the needs of this study. Individual responses to the
survey may be shared with DG MOVE of the European Commission. The survey responses
will not be published. However, we may refer to information provided in the surveys within the
final report, except where specific confidentiality considerations have been identified. Ricardo
and partners are happy to discuss and agree confidentiality requirements where this would
be necessary. Please see our privacy statement here.

1. Please indicate how you would like us to refer to any information provided in
your survey response: *

Your contribution will be referenced to the organisation represented.

Your contribution will be anonymised (i.e. without the name/name of the
organisation but with affiliation to industry sector, e.g. national authority,
transport operator representative, environmental NGO etc.).

Instructions for completing the survey
Please enter your responses using the online survey form. If you wish to return to the survey
to complete your response at a later time/date, please use the 'Save & Continue' function in
the toolbar (at the top of your screen). You will be asked to enter your email address to
receive a link to return to your survey later. When you use the 'Save & Continue' feature, all
survey progress up to that point is saved.

When returning to your saved survey, please remember to submit when complete.

Please note: Although we will only accept responses submitted through the online survey
form, you may download a a PDF version (here) or Word version (here) of the survey to
consider your responses before submitting them. Also note that the downloaded version will
contain all questions while the online version contains logic that will only display relevant
questions based on your answers.

While we have attempted to tailor the questions as much as possible it is possible that not all
questions will be relevant for your organisation or you may not be in a position to respond to
them. In these instances, you can simply select “Do not know” or “Not applicable”.

The survey is expected to remain open for four weeks. The deadline for the submission of
your answers is 25 July 2023.

B. Profile of respondent

2. What is the name of the organisation you represent? *

3. What type of organisation do you represent? *

National authority

Other authority (please specify)

Vehicle / vehicle equipment manufacturer or representative association

Testing equipment manufacturers or representative association

Inspection centre or representative association

Insurance company or representative

Research / academia

User / consumer organisation

NGO

Research / academia

Trade union

Other (please specify)

4. Please indicate which of the following areas your authority is responsible for
(multiple options possible): *

Road safety policy

Environmental policy

Vehicle registrations

Vehicle inspections

Enforcement of vehicle standards policy

Other (please specify)

5. Please indicate whether your organisation is (one option only): *

EU level/international association

National association

Individual company

6. What is the geographical scope of your activities (select all that are
appropriate)? *

EU wide

International

Austria

Belgium

Bulgaria

Republic of Cyprus

Czech Republic

Germany

Denmark

Greece

Spain

Finland

France

Croatia

Hungary

Ireland

Italy

Lithuania

Luxembourg

Latvia

Malta

Netherlands

Poland

Portugal

Romania

Sweden

Slovenia

Slovakia

Other

7. What is the size of your organisation? *

Micro (1 to 9 employees)

Small (100 to 49 employees)

Medium (50 to 249 employees)

Large (250 or more employees)

Don’t know

8. What is your name and surname? *

9. What is your role within the organisation? *

10. What is your email address? *

C. Current situation and evolution without any further EU intervention

Page description:
The first set of questions relate to the current situation and evolution without any further
EU intervention. These seek your views on the impacts of different developments since the
adoption of the roadworthiness package in 2014 until now, and also on what the impacts of
these developments might be in the period from now until 2030, in the absence of any further
EU policy interventions. The developments being considered are:

Technological and market developments, including the introduction of new safety
technologies in vehicles.
The enforcement of the roadworthiness legislation.  
Other measures taken at the Member State level.

We are interested in your views on the impact of these developments on:

The number of unsafe vehicles (i.e. vehicles with safety defects) on the EU’s roads.
The number of vehicles with defective or tampered emission control systems on the
EU’s roads.
The number of vehicles with defective or tampered noise control systems on the EU’s
roads.
The number of vehicles with tampered odometers on the EU’s roads
The process of re-registration of vehicles across the EU.

11. On the basis of your experience, what has been, to this point, the
contribution to reducing the number of the unsafe vehicles (i.e. vehicles
with safety defects) on the EU’s roads in the period since the adoption of the
current roadworthiness package in 2014 of the following:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Technological and market
developments (i.e. introduction
of new safety technologies in
vehicles)

Enforcement of roadworthiness
legislation (including PTI and
RSI)

Other measures taken at the
Member State level

12. In your view, in the absence of any further EU policy interventions,
what do you expect to be in the coming period up to 2030 the additional
contribution to reducing the number of the unsafe vehicles (i.e. vehicles
with safety defects) on the EU’s roads of the following: 

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Technological and market
developments (i.e. introduction
of new safety technologies in
vehicles)

Enforcement of roadworthiness
legislation (including PTI and
RSI)

Other measures taken at the
Member State level

13. Please explain your responses in relation to the contributions to reducing
the number of the unsafe vehicles (i.e. vehicles with safety defects) on the
EU’s roads.

14. On the basis of your experience, what has been, to this point, the
contribution to reducing the number of vehicles with defective or
tampered emission control systems on the EU’s roads in the period since
the adoption of the current roadworthiness package in 2014 of the
following aspects:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Technological and market
developments (i.e. introduction
of new emission control
technologies/sensors in
vehicles, access to OBD)

Enforcement of roadworthiness
legislation (including PTI and
RSI)

Other measures taken at the
Member State level

15. In your view, in the absence of any further EU policy interventions,
what do you expect to be in the coming period up to 2030 the additional
contribution to reducing the number of vehicles with defective or
tampered emission control systems on the EU’s roads of the following: 

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Technological and market
developments (i.e. introduction
of new emission control
technologies/sensors in
vehicles, access to OBD)

Enforcement of roadworthiness
legislation (including PTI and
RSI)

Other measures taken at the
Member State level

16. Please explain your responses in relation to the contributions to reducing
the number of vehicles with defective or tampered emission control
systems on the EU’s roads.

17. On the basis of your experience, what has been, to this point, the
contribution to reducing the number of vehicles with defective or
tampered noise control systems on the EU’s roads in the period since the
adoption of the current roadworthiness package in 2014 of the following
aspects:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Technological and market
developments (i.e. access to
OBD)

Enforcement of roadworthiness
legislation (including PTI and
RSI)

Other measures taken at the
Member State level

18. In your view, in the absence of any further EU policy interventions,
what do you expect to be in the coming period up to 2030 the additional
contribution to reducing the number of vehicles with defective or
tampered noise control systems on the EU’s roads of the following

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Technological and market
developments (i.e. access to
OBD)

Enforcement of roadworthiness
legislation (including PTI and
RSI)

Other measures taken at the
Member State level

19. Please explain your responses in relation to the contributions to reducing
the number of vehicles with defective or tampered noise control systems
on the EU’s roads.

20. On the basis of your experience, what has been, to this point, the
contribution to reducing the number of vehicles with tampered
odometers on the EU’s roads since the adoption of the current
roadworthiness package in 2014 of the following aspects:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Technological and market
developments (i.e. introduction
of new relevant technologies in
vehicles and Information and
Communication Technologies
(ICT) solutions, data exchange)

Enforcement of roadworthiness
legislation (including PTI and
RSI)

Other measures taken at the
Member State level

21. In your view, in the absence of any further EU policy interventions,
what do you expect to be in the coming period up to 2030 the additional
contribution to reducing the number of vehicles with tampered odometers
on the EU’s roads of the following:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Technological and market
developments (i.e. introduction
of new relevant technologies in
vehicles and ICT solutions, data
exchange)

Enforcement of roadworthiness
legislation (including PTI and
RSI)

Other measures taken at the
Member State level

22. Please explain your responses in relation to the contributions to reducing
the number of vehicles with tampered odometers on the EU’s roads.

23. Based on your experience, what has been, to this point, the contribution to
improving the process of re-registration of vehicles across the EU since
the adoption of the current roadworthiness package in 2014 of the
following aspects:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Technological and market
developments (i.e. the broader
use of interfaces, such as
Eucaris and MoveHub, for data
exchange)

Enforcement of roadworthiness
legislation (including the
Directive on vehicle registration
documents)

Other measures taken at the
Member State level

24. In your view, in the absence of any further EU policy interventions,
what do you expect to be in the coming period up to 2030 the additional
contribution to improving the process of re-registration of vehicles across
the EU of of the following:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Technological and market
developments (i.e. the broader
use of interfaces, such as
Eucaris and MoveHub, for data
exchange)

Enforcement of roadworthiness
legislation ((including the
Directive on vehicle registration
documents)

Other measures taken at the
Member State level

25. Please explain your responses in relation to the contributions to
improving the process of re-registration of vehicles across the EU.

26. Based on your experience, what has been, to this point, the contribution
of (electronic) data exchange to :

1
(None
at all)

2

3

4

5

6

7
(Very
high)

Don’t
know

Improving the process of re-
registration of vehicles across the EU
since the adoption of the current
Roadworthiness Package in 2014?

27. Please specify how data exchange for the purposes of re-registration of
vehicles across the EU currently works in your country, in relation to the
following:

The re-registration of vehicles in another country, what data and
registration documents are exchanged among countries?

28. Please specify how data exchange for the purposes of re-registration of
vehicles across the EU currently works in your country, in relation to the
following:

Yes No

The re-registration of vehicles in another country, are data and
registration documents exchanged in an electronic format ?

29. If 'Yes', please elaborate
below.

30. Please specify how data exchange for the purposes of re-registration of
vehicles across the EU currently works in your country, in relation to the
following:

Eucaris MoveHub Other

Not
applicable

The re-registration of vehicles in another
country, please specify how data and
registration documents are exchanged : 

31. If 'Other', please elaborate below.

32. In your view, in the absence of any further EU policy interventions,
what do you expect to be - in the coming period up to 2030 - the additional
contribution of (electronic) data exchange to:

1
(None
at all)

2

3

4

5

6

7
(Very
high)

Don’t
know

Improving the process of re-
registration of vehicles across the
EU?

33. Please explain your responses in relation to the evolution of data
exchange processes for the purposes of re-registration of vehicles
across the EU, in the absence of any further EU policy interventions.

34. Do you have any quantitative evidence to support your views on any
aspect of the baseline? If ‘Yes’, please elaborate below, including providing
any relevant links.

D. Problem drivers and policy objectives

Page description:
The analysis of the challenges with the current Roadworthiness package are already well
advanced. The following preliminary problems areas and their underlying problem drivers
(PDs) have been identified:

35. Please indicate your level of agreement with the preliminary problems and
problem drivers identified?

Strongly
disagree Disagree

Neither
agree
nor

disagree Agree

Strongly
agree

Don’t
know

Problem area A and the
associated problem
drivers

Problem area B and the
associated problem
drivers

Problem area C and the
associated problem
drivers

 
36. Please explain your responses, including any changes that would help the
preliminary problem drivers or problem areas better reflect the challenges that
exist. In addition, please elaborate if, in your view, any problems, or problem
drivers, are missing.

In order to address the preliminary problem drivers and problem areas that have been
identified, the following specific objectives (SO) of the proposed intervention have been
identified.

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.

37. Please indicate your level of agreement with the appropriateness of the
preliminary specific objectives for this initiative?

Strongly
disagree Disagree

Neither
agree
nor

disagree Agree

Strongly
agree

Don’t
know

Specific objective 1
(Adapt testing to today’s
and tomorrow’s vehicles
(improve consistency,
objectivity and quality))

Specific objective 2
(Significantly reduce
fraud and tampering (of
safety and emission
control systems) and
improve the detection of
defective vehicles)

Specific objective 3
(Improve electronic
storage and exchange of
relevant vehicle
identification and status
data)

38. Please explain your response, including any proposals for rewording the
objectives to improve their clarity and/or appropriateness.

39. In your view, are there any other specific objectives that should be
considered as part of this initiative? Please explain.

E. Potential measures to address the preliminary problems identified

Page description:
A set of preliminary policy measures that might address the preliminary problems identified
has been developed. These have been developed to address the limitations and challenges
of the current roadworthiness package (RWP) and so deliver the proposed objectives, as set
out above. The measures under consideration cover all three Directives of the RWP and
have been grouped together depending on the particular aspects and Directive that they
address.

In total, there are 36 measures under consideration, which have been brought together in 11
different groups. The groups bring together measures that affect a particular aspect of at
least one of the Directives. The measures under consideration will be listed when each group
of measures are presented. The measures have been brought together in the following
groups:

1.  Scope of vehicles covered by the Periodic Technical Inspection (PTI) Directive (Section

E.1)

2.  Frequency of PTI testing (E.2)
3.  Recognition of PTI in another country (E.3)
4.  Roadworthiness certificate (E.4)
5.  Improve current PTI test requirements and procedures (E.5)
6.  Introduce new PTI test requirements and procedures (E.6)
7.  Extend scope of roadside inspections (RSI) (E.7)
8.  Introduce new RSI test methods and procedures (E.8)
9.  Introduce new PTI and RSI test methods and procedures (E.9)

10.  Access and exchange of information/data (E.10)
11.  Vehicle registration measures (E.11)

For those measures in which you are interested, we will ask you to provide input relating to
some or all of the following:

The expected contribution of the measure to the objective(s).
The expected contribution of the measure to reducing the number of unsafe vehicles on
the road and in reducing the number of vehicles with defective or tampered emission
control systems, noise control systems and odometers.
The definition of the measure and/or its key parameters.
The new or additional costs associated with the measure, if any.
The savings associated with the measure, if any.

In addition, at the end of each group of measures, there are questions on the potential
impacts of the measures in that group, as well as a question asking you whether there are
any additional measures that might be considered in the context of that group of measures.

Instructions for answering questions on relevant measures 

We are happy for you to provide input on all of the measures under consideration.
However, there is also the option to answer the questions that relate only to those measures
in which you have an interest.
For each group of measures you will first be asked to indicate whether you want to answer
questions relating to any measure in that group and, if so, which.
If you select ‘None’, you will be taken to the next group of measures.
Otherwise, you would then only be asked the questions relating to the policy measures that
you select.

When identifying the measures that are of interest to you, please remember that we are
interested in professional opinions, rather than in personal opinions.

E.1 Scope of vehicles covered by the Periodic Technical Inspection (PTI) Directive

Page description:
The measures in this group relate to the scope of the PTI Directive only and aim to address
the preliminary problem driver 5, i.e. that certain vehicles are not (sufficiently) tested for their
roadworthiness. The preliminary measures considered are:

PM 1: Mandatory PTI for all motorcycles over 50 cm3 (L3-L7 category) and remove the
current opt out for vehicles over 125 cm3 (i.e. including from 50cm3, so for all L3e, L4e,
plus tricycles (L5e) and heavy quadricycles (L7e))
PM 2: Extend scope of mandatory PTI to mopeds (i.e. L1e-B and L2e categories)
PM 3: Mandatory PTI for agricultural and forestry tractors (T category), i.e. remove opt
out
PM 4: Mandatory PTI for light trailers (O1-O2 category)

Below you will be asked whether you want to answer questions relating to any preliminary
measure in this group and, if so, which. If you select ‘None’, you will be taken to the next
group of preliminary measures and skip this group. Otherwise, you will be asked to
indicate the preliminary measures in the respective group on which you would like to answer
questions. You will then only be asked the questions relating to the preliminary policy
measures that you select.

40. Please indicate below which of the above preliminary measures, if any,
you would like to answer the questions about (note, if you answer ‘None’, the
survey will skip these preliminary measures and take you on to the next set of
questions): *

None

PM 1: Mandatory PTI for all motorcycles over 50 cm3 (L3-L7 category)
and remove the current opt out for vehicles over 125 cm3 (i.e. including
from 50cm3, so for all L3e, L4e, plus tricycles (L5e) and heavy
quadricycles (L7e))

PM 2: Extend scope of mandatory PTI to mopeds (i.e. L1e-B and L2e
categories)

PM 3: Mandatory PTI for agricultural and forestry tractors (T category),
i.e. remove opt out

PM 4: Mandatory PTI for light trailers (O1-O2 category)

PM 1: Introduce mandatory PTI for all motorcycles over 50 cm3 (L3-L7 category) and
remove the current opt-out for vehicles over 125 cm3 (i.e. including from 50cm3, so for all
L3e, L4e, plus tricycles (L5e) and heavy quadricycles (L7e))

Page description:
This would remove the current opt-out for motorcycles, so making PTI mandatory for
motorcycles, as well as extending the need for a mandatory PTI to all categories of
motorcycle. As a result the measure would require a mandatory PTI for the following
categories: two-wheel motorcycle (L3e), two-wheel motorcycle with side car (L4e), tricycles
(L5e) and heavy quadricycles (L7e). The aim is to address problem driver 5, i.e. that certain
vehicles are not (sufficiently) tested for their roadworthiness, and so contribute to the
achievement of specific objective 2, i.e. to significantly reduce fraud and tampering (of safety
and emission control systems) and improve the detection of defective vehicles.

41. In your view, what would the contribution of this measure be to addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

42. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Reducing the number of unsafe
vehicles on the EU’s roads?

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

Reducing the number of
vehicles with tampered
odometers?

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

Two-wheel motorcycle (L3e)

Two-wheel motorcycle with side car (L4e)

Tricycles (L5e)

Heavy quadricycles (L7e)

None of these

44. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

45. If this measure was implemented, do you anticipate any new or additional
costs to your organisation / members, such as the following (multiple
responses possible):

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

46. Please elaborate on the other costs mentioned
above.

47. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 2: Extend the scope of mandatory PTI to mopeds (i.e. L1e-B and L2e categories)

Page description:
This would make a PTI mandatory for mopeds (i.e. categories L1e-B, two-wheel mopeds, and
L2e, three-wheel mopeds). The aim is to address problem driver 5, i.e. that certain vehicles
are not (sufficiently) tested for their roadworthiness, and so contribute to the achievement of
specific objective 2, i.e. to significantly reduce fraud and tampering (of safety and emission
control systems) and improve the detection of defective vehicles.

48. In your view, what would the contribution of this measure be to addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

49. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Reducing the number of unsafe
vehicles on the EU’s roads?

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

Reducing the number of
vehicles with tampered
odometers?

50. In your view, to which categories of moped should mandatory PTI be
extended (multiple responses possible):

L1-e-B (two-wheel mopeds)

L2e (three-wheel mopeds)

Neither of these

51. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

52. If this measure was implemented, do you anticipate any new or additional
costs to your organisation / members, such as the following (multiple
responses possible):

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

53. Please elaborate on the other costs mentioned
above.

54. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 3: Introduce mandatory PTI for all agricultural and forestry tractors (T category), i.e.
remove opt-out

Page description:
This would remove the current opt-out for agricultural and forestry tractors (T category), so
making a PTI mandatory for these vehicles. The aim is to address problem driver 5, i.e. that
certain vehicles are not (sufficiently) tested for their roadworthiness, and so contribute to the
achievement of specific objective 2, i.e. to significantly reduce fraud and tampering (of safety
and emission control systems) and improve the detection of defective vehicles.

55. In your view, what would the contribution of this measure be to addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

56. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Reducing the number of unsafe
vehicles on the EU’s roads?

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

Reducing the number of
vehicles with tampered
odometers?

57. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

58. If this measure was implemented, do you anticipate any new or additional
costs to your organisation / members, such as the following (multiple
responses possible):

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

59. Please elaborate on the other costs mentioned
above.

60. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 4: Introduce mandatory PTI for light trailers (O1 and O2)

Page description:
This will introduce a mandatory PTI for light trailers (categories O1 and O2). The aim is to
address problem driver 5, i.e. that certain vehicles are not (sufficiently) tested for their
roadworthiness, and so contribute to the achievement of specific objective 2, i.e. to
significantly reduce fraud and tampering (of safety and emission control systems) and
improve the detection of defective vehicles.

61. In your view, what would the contribution of this measure be to addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

62. In your view, in the context of improving road transport safety, what would
the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Reducing the number of unsafe
vehicles on the EU’s roads?

63. In your view, to which categories of trailer should mandatory PTI be
extended (multiple responses possible):

O1 (trailers with a maximum mass not exceeding 750kg)

O2 (trailers with a maximum mass exceeding 750kg but not exceeding
3,500kg)

Neither of these

64. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs. 
Changes in recurrent costs may include cost savings as well as additional new costs.  
Where possible, please indicate the likely costs involved.

65. If this measure was implemented, do you anticipate any new or additional
costs to your organisation / members, such as the following (multiple
responses possible):

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

66. Please elaborate on the other costs mentioned
above.

67. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

The remaining questions are for the preliminary measures in the section as a whole, that is
those that relate to the scope of vehicles covered by the PTI Directive.

68. In your view, what, if any, impact would this group of measures (if
implemented) have on the following aspects/parameters?

Very
negative

Somewhat
negative

No
impact

Somewhat
positive

Very
positive

Don’t
know

Operation of the EU
Internal market (i.e. in
terms of ensuring fair
competition, avoiding
fraud, eliminating
cross-border trade
obstacles)

Cost and price
competitiveness of
the sectors and
businesses affected
(i.e. related to impacts
on costs of operation,

on costs of operation,
cost of capital, profit
margins)

Innovative capacity of
the sectors and
businesses affected
(i.e. impact on the
capacity of
businesses and
incentives to bring to
the market new
goods/services)

International
competitiveness of
the sectors and
businesses affected
(i.e. specific
costs/benefits for EU
businesses that are
not applicable to their
non-EU competitors)

SME competitiveness
(i.e. lead to costs or
benefits that affect
micro, small and
medium sized
business at a
disproportionate level)

State of the
environment (such as
air quality,
biodiversity,
ecosystem health,
etc)

Level of noise from
road transport

Public health

Employment / jobs in
the affected sectors
and businesses

Fundamental rights
(including in relation
privacy and protection
of data)

69. Please add any comments that you may have on these, or other impacts,
below.

70. In your view, are there likely to be any particular challenges for SMEs, if
any of these preliminary measures were implemented?

Yes

No

Don’t know

71. If ‘Yes’, please explain what these would
be.

72. Are there any measures, in addition to those presented in this section,
which could be considered in relation to the scope of vehicles covered by
the PTI Directive? Please elaborate.

73. If you have any other comments on preliminary measures relating to the
scope of vehicles covered by the PTI Directive, please add them below.

E.2 Frequency of Periodic Technical Inspection (PTI) testing

Page description:

The preliminary measures in this group relate to the frequency of mandatory PTI testing for

vehicles, so only relate to the PTI Directive. The preliminary measures considered are:

PM 5: Require more frequent emission testing (yearly test from the date of registration)
for light duty commercial vehicles (N1 category)
PM 6: Require mandatory yearly testing for vehicles that are 10-year-old and older
PM 7: Introduce option for a simplified PTI (i.e. no emission/noise testing) if vehicle
passed recent roadside inspection (including remote sensing)
PM 8: PTIs mandatory for crashed vehicles with significant damage (affecting the main
safety components)
PM 9: PTIs mandatory following significant modifications (e.g. change of class,
propulsion system)

Below you will be asked whether you want to answer questions relating to any preliminary
measure in this group and, if so, which. If you select ‘None’, you will be taken to the next
group of preliminary measures and skip this group. Otherwise, you will be asked to
indicate the preliminary measures in the respective group on which you would like to answer
questions. You will then only be asked the questions relating to the preliminary policy
measures that you select.

74. Please indicate below which of the above preliminary measures, if any,
you would like to answer the questions about (note, if you answer ‘None’, the
survey will skip these preliminary measures and take you on to the next set of
questions): *

None

PM 5: Require more frequent emission testing (yearly test from the date
of registration) for light duty commercial vehicles (N1 category)

PM 6: Require mandatory yearly testing for vehicles that are 10-year-old
and older

PM 7: Introduce option for a simplified PTI (i.e. no emission/noise testing)
if vehicle passed recent roadside inspection (including remote sensing)

PM 8: PTIs mandatory for crashed vehicles with significant damage
(affecting the main safety components)

PM 9: PTIs mandatory following significant modifications (e.g. change of
class, propulsion system)

PM 5: Require more frequent emission testing (yearly test from the date of registration) for
light duty commercial vehicles (N1 category)

Page description:
This measure would increase the frequency of PTIs for light commercial vehicles (N1
vehicles) to bring this in line with the frequency of testing that applies to larger commercial
vehicles (i.e. N2 and N3 vehicles) and to taxis and ambulances, but for emission testing only.
The aim is to address problem drivers 3, i.e. that there are limited technical possibilities to
detect vehicles with defects or tampered components, and 5 (that certain vehicles are not
(sufficiently) tested for their roadworthiness. In doing so, it will contribute to the achievement
of specific objective 2, i.e. to significantly reduce fraud and tampering (of safety and emission
control systems) and improve the detection of defective vehicles.

75. In your view, what would the contribution of this measure be to addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles:

76. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Reducing the number of
vehicles with defective or
tampered pollutant emission
control systems?

77. In your view, how old should an N1 vehicle (light commercial vehicle) be
when it becomes subject to compulsory annual PTI?

78. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective, or if you consider that the measure could be extended to safety
systems.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

79. If this measure was implemented, do you anticipate any new or additional
costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

80. Please elaborate on the other costs mentioned
above.

81. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 6: Require mandatory yearly testing for vehicles that are 10-year-old and older

Page description:
This measure would make an annual PTI mandatory for vehicles once they are 10 years old,
and for each subsequent year that they are on the road. The aim is to address problem
drivers 3, i.e. that there are limited technical possibilities to detect vehicles with defects or
tampered components, and 5 (that certain vehicles are not (sufficiently) tested for their
roadworthiness. In doing so, it will contribute to the achievement of specific objective 2, i.e.
to significantly reduce fraud and tampering (of safety and emission control systems) and
improve the detection of defective vehicles.

82. In your view, what would the contribution of this measure be to addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles:

83. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Reducing the number of unsafe
vehicles on the EU’s roads?

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

Reducing the number of
vehicles with tampered
odometers?

 
 
84. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

85. If this measure was implemented, do you anticipate any new or additional
costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

86. Please elaborate on the other costs mentioned
above.

87. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

88. Do you anticipate any cost savings to your organisation / members, if this
measure was implemented?

Yes

No

Don’t know

89. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

PM 7: Introduce option for a simplified PTI (i.e. no emission/noise testing) if vehicle passed
recent roadside inspection (including remote sensing)

Page description:
This measure would introduce a simplified PTI, i.e. require no emissions or noise testing, if
the vehicle has successfully passed a recent roadside inspection (including ones undertaken
by remote sensing) without any defects. The aim is to address problem driver 3, i.e. that there
are limited technical possibilities to detect vehicles with defects or tampered components. In
doing so, it will contribute to the achievement of specific objective 2, i.e. to significantly
reduce fraud and tampering (of safety and emission control systems) and improve the
detection of defective vehicles.

90. In your view, what would the contribution of this measure be to addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles:

 
91. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

92. In your view, which aspects of a full PTI should not be undertaken in the
event that the vehicle has recently successfully passed a roadside inspection,
including by remote sensing?

Noise testing

Emissions testing

Neither of these

Other (please specify in response to next question)

93. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

94. If this measure was implemented, do you anticipate any new or additional
costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

95. Please elaborate on the other costs mentioned
above.

96. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

97. Do you anticipate any cost savings to your organisation / members, if this
measure was implemented?

Yes

No

Don’t know

98. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

PM 8: PTIs mandatory for crashed vehicles with significant damage (affecting the main
safety components)

Page description:
This measure would introduce a requirement for a mandatory PTI for vehicles that have been
damaged significantly as a result of their involvement in a crash, which affected their main
safety components. The aim is to address problem drivers 3, i.e. that there are limited
technical possibilities to detect vehicles with defects or tampered components, and 5 (that
certain vehicles are not (sufficiently) tested for their roadworthiness. In doing so, it will
contribute to the achievement of specific objective 2, i.e. to significantly reduce fraud and
tampering (of safety and emission control systems) and improve the detection of defective
vehicles.

99. In your view, what would the contribution of this measure be to addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles:

 
100. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Reducing the number of unsafe
vehicles on the EU’s roads?

101. In your view, what in practice should be considered to be “significant
damage” and how might this be interpreted and/or defined in the legislation?
In addition, what should be considered a “main safety component”?

102. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

103. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

104. Please elaborate on the other costs mentioned
above.

105. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 9: PTIs mandatory following significant modifications (e.g. change of class, propulsion
system)

Page description:
This measure would introduce a requirement for a mandatory PTI for vehicles that have been
subject to significant modifications, such as a change of class or propulsion system. The aim
is to address problem drivers 3, i.e. that there are limited technical possibilities to detect
vehicles with defects or tampered components, and 5 (that certain vehicles are not
(sufficiently) tested for their roadworthiness. In doing so, it will contribute to the achievement
of specific objective 2, i.e. to significantly reduce fraud and tampering (of safety and emission
control systems) and improve the detection of defective vehicles.

106. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles:

107. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don’t
know

Reducing the number of unsafe
vehicles on the EU’s roads?

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

Reducing the number of
vehicles with tampered
odometers?

 
 
108. In your view, what in practice should be considered to be a “significant
modification” and how might this be interpreted and/or defined in the
legislation?

109. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

110. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

111. Please elaborate on the other costs mentioned
above.

112. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

The remaining questions are for the preliminary measures in the section as a whole, that is
those relating to the frequency of PTI testing.

113. In your view, what, if any, impact would this group of measures (if
implemented) have on the following aspects/parameters?

Very
negative

Somewhat
negative

No
impact

Somewhat
positive

Very
positive

Don’t
know

Operation of the EU
Internal market (i.e. in
terms of ensuring fair
competition, avoiding
fraud, eliminating
cross-border trade
obstacles)

Cost and price
competitiveness of
the sectors and
businesses affected
(i.e. related to impacts
on costs of operation,

on costs of operation,
cost of capital, profit
margins)

Innovative capacity of
the sectors and
businesses affected
(i.e. impact on the
capacity of
businesses and
incentives to bring to
the market new
goods/services)

International
competitiveness of
the sectors and
businesses affected
(i.e. specific
costs/benefits for EU
businesses that are
not applicable to their
non-EU competitors)

SME competitiveness
(i.e. lead to costs or
benefits that affect
micro, small and
medium sized
business at a
disproportionate level)

State of the
environment (such as
air quality,
biodiversity,
ecosystem health,
etc)

Level of noise from
road transport

Public health

Employment / jobs in
the affected sectors
and businesses

Fundamental rights
(including in relation
privacy and protection
of data)

114. Please add any comments that you may have on these, or other impacts,
below.

115. Are there any measures, in addition to those presented in this section,
which could be considered in relation to the frequency of PTI testing?
Please elaborate.

116. If you have any other comments on preliminary measures relating to the
frequency of PTI testing, please add them below.

E.3 Recognition of Periodic Technical Inspection (PTI) in another country

Page description:
The preliminary measures in this group relate to the recognition of PTI in another country,
so only relate to the PTI Directive. They aim to address the preliminary problem driver 4, i.e.
that vehicle identification & status data not sufficiently available to, and recognised among,
enforcing authorities. The preliminary measures considered are:

PM 10: Require that a PTI certificate issued in any other EU Member State is
recognised by Member State of registration (under certain conditions)
PM 11: Require that PTI certificate issued in another EU Member State is recognised
by Member State of registration, on the basis of a bilateral agreement among the
Member States

Below you will be asked whether you want to answer questions relating to any preliminary
measure in this group and, if so, which. If you select ‘None’, you will be taken to the next
group of preliminary measures and skip this group. Otherwise, you will be asked to
indicate the preliminary measures in the respective group on which you would like to answer
questions. You will then only be asked the questions relating to the preliminary policy
measures that you select.

117. Please indicate below which of the above preliminary measures, if any,
you would like to answer the questions about (note, if you answer ‘None’, the
survey will skip these preliminary measures and take you on to the next set of
questions): *

None

PM 10: Require that a PTI certificate issued in any other EU Member
State is recognised by Member State of registration (under certain
conditions)

PM 11: Require that PTI certificate issued in another EU Member State is
recognised by Member State of registration, on the basis of a bilateral
agreement among the Member States

PM 10: Require that a PTI certificate issued in any other EU Member State is recognised by
Member State of registration (under certain conditions)

Page description:
The aim of this measure is to increase the mutual recognition of PTI certificates. It would
require such recognition under certain conditions, i.e. provided that the testing Member State
applies at least the same (or equivalent) method for the relevant test items as the Member
State of registration. In addition, Member States would be required to publish the test
methods that they apply to the various vehicle categories. The aim is to address problem
driver 4, i.e. that vehicle identification & status data not sufficiently available to, and
recognised among, enforcing authorities, and so contribute to the achievement of specific
objective 3, i.e. to improve electronic storage and exchange of relevant vehicle identification
and status data.

118. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 3: Improve
electronic storage and exchange
of relevant vehicle identification
and status data

119. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

 
The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

120. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

121. Please elaborate on the other costs mentioned
above.

122. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

123. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

124. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

PM 11: Require that PTI certificate issued in another EU Member State is recognised by
Member State of registration, on the basis of a bilateral agreement among the Member
States

Page description:
The aim of this measure is to increase the mutual recognition of PTI certificates. It would
require such a recognition, where there was a bilateral agreement between both Member
States concerned. This is more limited than the previous measure (see above). The aim is to
address problem driver 4, i.e. that vehicle identification & status data not sufficiently available
to, and recognised among, enforcing authorities, and so contribute to the achievement of
specific objective 3, i.e. to improve electronic storage and exchange of relevant vehicle
identification and status data.

125. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 3: Improve
electronic storage and exchange
of relevant vehicle identification
and status data

 
126. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

127. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

128. Please elaborate on the other costs mentioned
above.

129. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

130. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

131. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

The remaining questions are for the preliminary measures in the section as a whole, that is
those relating to the recognition of PTI in another country.

132. In your view, what, if any, impact would this group of measures (if
implemented) have on the following aspects/parameters?

Very
negative

Somewhat
negative

No
impact

Somewhat
positive

Very
positive

Don’t
know

Operation of the EU
Internal market (i.e. in
terms of ensuring fair
competition, avoiding
fraud, eliminating
cross-border trade
obstacles)

Cost and price
competitiveness of
the sectors and
businesses affected
(i.e. related to impacts
on costs of operation,
cost of capital, profit
margins)

Innovative capacity of
the sectors and
businesses affected
(i.e. impact on the
capacity of
businesses and
incentives to bring to
the market new
goods/services)

goods/services)

International
competitiveness of
the sectors and
businesses affected
(i.e. specific
costs/benefits for EU
businesses that are
not applicable to their
non-EU competitors)

SME competitiveness
(i.e. lead to costs or
benefits that affect
micro, small and
medium sized
business at a
disproportionate level)

State of the
environment (such as
air quality,
biodiversity,
ecosystem health,
etc)

Level of noise from
road transport

Public health

Employment / jobs in
the affected sectors
and businesses

Fundamental rights
(including in relation
privacy and protection
of data)

133. Please add any comments that you may have on these, or other impacts,
below.

134. In your view, are there likely to be any particular challenges for SMEs, if
any of these preliminary measures were implemented?

Yes

No

Don’t know

135. If ‘Yes’, please explain what these would
be.

136. Are there any measures, in addition to those presented in this section,
which could be considered in relation to the recognition of PTI in another
country? Please elaborate.

137. If you have any other comments on preliminary measures relating to
the recognition of PTI in another country, please add them below.

E.4 Roadworthiness certificate

Page description:
The preliminary measure in this group relates to the roadworthiness certificate, so only
relate to the PTI Directive. It aims to address the preliminary problem driver 4, i.e. that
vehicle identification & status data not sufficiently available to, and recognised among,
enforcing authorities. The preliminary measures considered are:

PM 12: Require roadworthiness certificate to be issued in electronic format

Below you will be asked whether you want to answer questions relating to this preliminary
measure. If you select ‘No’, you will be taken to the next group of preliminary
measures and skip this group. Otherwise, you will be asked the questions relating to this
preliminary measure. 

138. Do you want to answer the questions relating to this preliminary
measure? *

Yes

No

PM 12: Require roadworthiness certificate to be issued in electronic format

Page description:
This measure would require roadworthiness certificates to be stored in the vehicle register
and be made available in an electronic format. The aim is to address problem driver 4, i.e.
that vehicle identification & status data not sufficiently available to, and recognised among,
enforcing authorities, and so contribute to the achievement of specific objective 3, i.e. to
improve electronic storage and exchange of relevant vehicle identification and status data.

139. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 3: Improve
electronic storage and exchange
of relevant vehicle identification
and status data

140. In your view, if the roadworthiness certificate was made available
electronically, should the paper version still be made available?

Yes, by default

Yes, but only on request

No

141. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective, or you have views on who should have access to the stored
certificates.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

142. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

143. Please elaborate on the other costs mentioned
above.

144. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

145. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

146. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

147. In your view, what, if any, impact would this measure (if implemented)
have on the following aspects/parameters?

Very
negative

Somewhat
negative

No
impact

Somewhat
positive

Very
positive

Don’t
know

Operation of the EU
Internal market (i.e. in
terms of ensuring fair
competition, avoiding
fraud, eliminating
cross-border trade
obstacles)

Cost and price
competitiveness of
the sectors and
businesses affected
(i.e. related to impacts
on costs of operation,
cost of capital, profit
margins)

Innovative capacity of
the sectors and
businesses affected
(i.e. impact on the
capacity of
businesses and
incentives to bring to
the market new
goods/services)

International
competitiveness of

competitiveness of
the sectors and
businesses affected
(i.e. specific
costs/benefits for EU
businesses that are
not applicable to their
non-EU competitors)

SME competitiveness
(i.e. lead to costs or
benefits that affect
micro, small and
medium sized
business at a
disproportionate level)

State of the
environment (such as
air quality,
biodiversity,
ecosystem health,
etc)

Level of noise from
road transport

Public health

Employment / jobs in
the affected sectors
and businesses

Fundamental rights
(including in relation
privacy and protection
of data)

148. Please add any comments that you may have on these, or other impacts,
below.

149. In your view, are there likely to be any particular challenges for SMEs, if
any of this measure was implemented?

Yes

No

Don’t know

150. If ‘Yes’, please explain what these would
be.

151. Are there any measures, in addition to the one presented in this section,
which could be considered in relation to the roadworthiness certificate?
Please elaborate.

152. If you have any other comments on preliminary measures relating to
the roadworthiness certificate, please add them below.

E.5 Improve current Periodic Technical Inspection (PTI) test requirements and procedures

Page description:
The preliminary measures in this group relate to improving the current PTI test
requirements and procedures, so only relate to the PTI Directive. They aim to address the
preliminary problem driver 3, i.e. that there are limited technical possibilities to detect
vehicles with defective or tampered components. The preliminary measures considered are:

PM 13: Require that PTI includes more advanced testing of noise for motorcycles
PM 14: Require that PTI includes advanced testing of lighting to cover advanced
headlamps
PM 15: Require more advanced testing of braking for HDVs (extrapolation methods)
PM 16: Require training of inspectors for PTI in relation to electric vehicles

Below you will be asked whether you want to answer questions relating to any preliminary
measure in this group and, if so, which. If you select ‘None’, you will be taken to the next
group of preliminary measures and skip this group. Otherwise, you will be asked to
indicate the preliminary measures in the respective group on which you would like to answer
questions. You will then only be asked the questions relating to the preliminary policy
measures that you select.

153. Please indicate below which of the above preliminary measures, if any,
you would like to answer the questions about (note, if you answer ‘None’, the
survey will skip these preliminary measures and take you on to the next set of
questions): *

None

PM 13: Require that PTI includes more advanced testing of noise for
motorcycles

PM 14: Require that PTI includes advanced testing of lighting to cover
advanced headlamps

PM 15: Require more advanced testing of braking for HDVs
(extrapolation methods)

PM 16: Require training of inspectors for PTI in relation to electric
vehicles

PM 13: Require that PTI includes more advanced testing of noise for motorcycles

Page description:
This measure would introduce the more advanced testing of noise for motorcycles into PTIs.
The aim is to address problem driver 3, i.e. that there are limited technical possibilities to
detect vehicles with defects or tampered components, and so contribute to the achievement
of specific objective 2, i.e. to significantly reduce fraud and tampering (of safety and emission
control systems) and improve the detection of defective vehicles.

154. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

155. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of
vehicles with defective or
tampered noise control
systems?

156. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective. In addition, please elaborate on any potential standard that might be
applied in testing.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

157. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

158. Please elaborate on the other costs mentioned
above.

159. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 14: Require that PTI includes advanced testing of lighting to cover advanced
headlamps

Page description:
This measure would introduce the more advanced testing of lighting in PTIs, in order to take
account of the more advanced lighting that is now being added to vehicles. The aim is to
address problem driver 3, i.e. that there are limited technical possibilities to detect vehicles
with defects or tampered components, and so contribute to the achievement of specific
objectives 1 (adapt testing to today’s and tomorrow’s vehicles (improve consistency,
objectivity and quality), and 2, i.e. to significantly reduce fraud and tampering (of safety and
emission control systems) and improve the detection of defective vehicles.

160. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1 Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

161. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

162. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective. In addition, please elaborate on any potential standard that might be
applied in testing.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

163. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

164. Please elaborate on the other costs mentioned
above.

165. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 15: Require more advanced testing of braking for HDVs (extrapolation methods)

Page description:
This measure would introduce the more advanced testing of braking for HDVs, in relation to
the application of extrapolation methods. The aim is to address problem driver 3, i.e. that
there are limited technical possibilities to detect vehicles with defects or tampered
components, and so contribute to the achievement of specific objective 2, i.e. to significantly
reduce fraud and tampering (of safety and emission control systems) and improve the
detection of defective vehicles.

166. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

167. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

168. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective. In addition, please elaborate on any potential standard that might be
applied in testing. 

 
The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

169. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

170. Please elaborate on the other costs mentioned
above.

171. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 16: Require training of inspectors for PTI in relation to electric vehicles

Page description:
This measure would introduce the additional training of inspectors for PTI to ensure that they
are able to undertake the appropriate inspections of electric vehicles. The aim is to address
problem driver 3, i.e. that there are limited technical possibilities to detect vehicles with
defects or tampered components, and so contribute to the achievement of specific objective
1, i.e. to adapt testing to today’s and tomorrow’s vehicles (improve consistency, objectivity
and quality).

172. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1: Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

173. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

174. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective. In addition, please elaborate on any potential standard that might be
applied to such training.

 
The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

175. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

176. Please elaborate on the other costs mentioned
above.

177. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

The remaining questions are for the preliminary measures in the section as a whole, that is
those relating to improving the current PTI test requirements and procedures.

178. In your view, what, if any, impact would this group of measures (if
implemented) have on the following aspects/parameters?

Very
negative

Somewhat
negative

No
impact

Somewhat
positive

Very
positive

Don’t
know

Operation of the EU
Internal market (i.e. in
terms of ensuring fair
competition, avoiding
fraud, eliminating
cross-border trade
obstacles)

Cost and price
competitiveness of
the sectors and
businesses affected
(i.e. related to impacts
on costs of operation,

on costs of operation,
cost of capital, profit
margins)

Innovative capacity of
the sectors and
businesses affected
(i.e. impact on the
capacity of
businesses and
incentives to bring to
the market new
goods/services)

International
competitiveness of
the sectors and
businesses affected
(i.e. specific
costs/benefits for EU
businesses that are
not applicable to their
non-EU competitors)

SME competitiveness
(i.e. lead to costs or
benefits that affect
micro, small and
medium sized
business at a
disproportionate level)

State of the
environment (such as
air quality,
biodiversity,
ecosystem health,
etc)

Level of noise from
road transport

Public health

Employment / jobs in
the affected sectors
and businesses

Fundamental rights
(including in relation
privacy and protection
of data)

179. Please add any comments that you may have on these, or other impacts,
below.

180. In your view, are there likely to be any particular challenges for SMEs, if
any of these preliminary measures were implemented?

Yes

No

Don’t know

181. If ‘Yes’, please explain what these would
be.

182. Are there any measures, in addition to those presented in this section,
which could be considered in relation to improving the current PTI test
requirements and procedures? Please elaborate.

183. If you have any other comments on preliminary measures relating to
improving the current PTI test requirements and procedures, please add
them below.

E.6 Introduce new Periodic Technical Inspection (PTI) test requirements and procedures

Page description:
The preliminary measure in this group relates to introducing new PTI test methods and
procedures, so only relate to the PTI Directive. It aims to address the preliminary problem
driver 4, i.e. that vehicle identification & status data not sufficiently available to, and
recognised among, enforcing authorities. The preliminary measures considered are:

PM 17: Adapt PTI to cover the particularities of electric and hybrid vehicles (e.g. high-
voltage systems)
PM 18: Update PTI with new test items to cover safety systems introduced as part of
the General Safety Regulation using electronic Periodic Technical Inspection (ePTI) (on
the basis of standard ISO 20730:2021)
PM 19: Require mandatory testing of particle numbers at PTI for LDVs and HDVs
based on Commission Recommendation (EU) 2023/688 containing guidelines for
particle number concentration testing during PTI
PM 21: Require NOx testing of LDVs and HDVs at PTI on the basis of testing methods
developed by the JRC

Below you will be asked whether you want to answer questions relating to any preliminary
measure in this group and, if so, which. If you select ‘None’, you will be taken to the next
group of preliminary measures and skip this group. Otherwise, you will be asked to
indicate the preliminary measures in the respective group on which you would like to answer
questions. You will then only be asked the questions relating to the preliminary policy
measures that you select.

184. Please indicate below which of the above preliminary measures, if any,
you would like to answer the questions about (note, if you answer ‘None’, the
survey will skip these preliminary measures and take you on to the next set of
questions): *

None

PM 17: Adapt PTI to cover the particularities of electric and hybrid
vehicles (e.g. high-voltage systems)

PM 18: Update PTI with new test items to cover safety systems
introduced as part of the General Safety Regulation using ePTI (on the
basis of standard ISO 20730:2021)

PM 19: Require mandatory testing of particle numbers at PTI for LDVs
and HDVs based on Commission Recommendation (EU) 2023/688
containing guidelines for particle number concentration testing during PTI

PM 21: Require NOx testing of LDVs and HDVs at PTI on the basis of
testing methods being developed by the JRC

PM 17: Adapt PTI to cover the particularities of electric and hybrid vehicles (e.g. high-
voltage systems)

Page description:
This measure would introduce provisions to amend the PTI to ensure that the safety and
environmental performance of electric and hybrid vehicles is assured, including with respect
to their high voltage systems. The aim is to address problem driver 1 (PTI-methods not
available to test electric vehicles, electronic safety & driver assistance systems), and so
contribute to the achievement of specific objective 1, i.e. to adapt testing to today’s and
tomorrow’s vehicles (improve consistency, objectivity and quality).

185. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1: Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

186. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

187. In your view, what should this update to the PTI include in relation to
inspections for electric and hybrid vehicles?

188. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

189. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

190. Please elaborate on the other costs mentioned
above.

191. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

192. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

193. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

PM 18: Update PTI with new test items to cover safety systems introduced as part of the
General Safety Regulation using electronic Periodic Technical Inspection (ePTI) (on the
basis of standard ISO 20730:2021)

Page description:
This measure introduces provisions to amend the PTI to ensure that this covers the safety
systems that were introduced as part of the General Safety Regulation using ePTI (on the
basis of standard ISO 20730:2021). The aim is to address problem driver 1, i.e. PTI methods
to test electric vehicles, electronic safety & driver assistance systems in vehicles not
available, and so contribute to the achievement of specific objective 1, i.e. to adapt testing to
today’s and tomorrow’s vehicles (improve consistency, objectivity and quality).

194. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1: Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

195. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

196. In your view, what should this update to the PTI include in order to cover
the new test items introduced as part of the General Safety Regulation?

197. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective, or you have views on alternative standards that might be used.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

198. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

199. Please elaborate on the other costs mentioned
above.

200. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

201. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

202. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

PM 19: Require mandatory testing of particle numbers (PN) at PTI for LDVs and HDVs
based on Commission Recommendation (EU) 2023/688 containing guidelines for particle
number concentration testing during PTI

Page description:
This measure would require mandatory PN testing in PTIs for both LDVs and HDVs. The aim
is to address problem driver 2, i.e. that current PTI & RSI methods not suited to test certain
functions of modern vehicles (including emissions performance), and so contribute to the
achievement of specific objectives 1 (to adapt testing to today’s and tomorrow’s vehicles
(improve consistency, objectivity and quality), and 2, i.e. to significantly reduce fraud and
tampering (of safety and emission control systems) and improve the detection of defective
vehicles.

203. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1: Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

204. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of
vehicles with defective or
tampered emission control
systems?

205. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

206. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

207. Please elaborate on the other costs mentioned
above.

208. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 21: Require NOx testing of LDVs and HDVs at PTI on the basis of testing methods
developed by the JRC

Page description:
This measure would require NOx testing in PTIs for both LDVs and HDVs. The aim is to
address problem driver 2, i.e. that current PTI & RSI methods not suited to test certain
functions of modern vehicles (including emissions performance), and so contribute to the
achievement of specific objectives 1 (to adapt testing to today’s and tomorrow’s vehicles
(improve consistency, objectivity and quality), and 2, i.e. Prevent fraud and tampering (of
safety and emission control systems.

209. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1: Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

210. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of
vehicles with defective or
tampered emission control
systems?

211. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

212. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

213. Please elaborate on the other costs mentioned
above.

214. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

The remaining questions are for the preliminary measures in the section as a whole, that is
those relating to introducing new PTI test requirements and procedures.

215. In your view, what, if any, impact would this group of measures (if
implemented) have on the following aspects/parameters?

Very
negative

Somewhat
negative

No
impact

Somewhat
positive

Very
positive

Don’t
know

Operation of the EU
Internal market (i.e. in
terms of ensuring fair
competition, avoiding
fraud, eliminating
cross-border trade
obstacles)

Cost and price
competitiveness of
the sectors and
businesses affected
(i.e. related to impacts
on costs of operation,

on costs of operation,
cost of capital, profit
margins)

Innovative capacity of
the sectors and
businesses affected
(i.e. impact on the
capacity of
businesses and
incentives to bring to
the market new
goods/services)

International
competitiveness of
the sectors and
businesses affected
(i.e. specific
costs/benefits for EU
businesses that are
not applicable to their
non-EU competitors)

SME competitiveness
(i.e. lead to costs or
benefits that affect
micro, small and
medium sized
business at a
disproportionate level)

State of the
environment (such as
air quality,
biodiversity,
ecosystem health,
etc)

Level of noise from
road transport

Public health

Employment / jobs in
the affected sectors
and businesses

Fundamental rights
(including in relation
privacy and protection
of data)

216. Please add any comments that you may have on these, or other impacts,
below.

217. In your view, are there likely to be any particular challenges for SMEs, if
any of these preliminary measures were implemented?

Yes

No

Don’t know

218. If ‘Yes’, please explain what these would
be.

219. Are there any measures, in addition to those presented in this section,
which could be considered in relation to introducing new PTI test methods
and procedures? Please elaborate.

220. If you have any other comments on preliminary measures relating to
introducing new PTI test methods and procedures, please add them
below.

E.7 Extend scope of roadside inspections (RSI)

Page description:
The preliminary measures in this group relate to extending the scope of roadside
inspections, so the preliminary measures now only relate to the RSI Directive. The
preliminary measures considered are:

PM 25: Introduce mandatory standards in relation to cargo securing inspections
PM 26: Extend the scope of application of roadside inspections to N1 vehicles (light
commercial vehicles)
PM 27: Extend the scope of application of roadside inspections to powered 2- and 3-
wheeled (L-category) vehicles

Below you will be asked whether you want to answer questions relating to any preliminary
measure in this group and, if so, which. If you select ‘None’, you will be taken to the next
group of preliminary measures and skip this group. Otherwise, you will be asked to
indicate the preliminary measures in the respective group on which you would like to answer
questions. You will then only be asked the questions relating to the preliminary policy
measures that you select.

221. Please indicate below which of the above preliminary measures, if any,
you would like to answer the questions about (note, if you answer ‘None’, the
survey will skip these preliminary measures and take you on to the next set of
questions): *

None

PM 25: Introduce mandatory standards in relation to cargo securing
inspections

PM 26: Extend the scope of application of roadside inspections to N1
vehicles (light commercial vehicles)

PM 27: Extend the scope of application of roadside inspections to
powered 2- and 3-wheeled (L-category) vehicles

PM 25: Introduce mandatory standards in relation to cargo securing inspections

Page description:
This measure would make the use of existing standards for roadside cargo securing
inspections mandatory (it is currently optional). The aim is to address problem driver 5 (that
certain vehicles are not (sufficiently) tested for their roadworthiness, in order to contribute to
the achievement of specific objective 1, i.e. to adapt testing to today’s and tomorrow’s
vehicles (improve consistency, objectivity and quality).

222. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1: Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

223. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

224. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

225. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

226. Please elaborate on the other costs mentioned
above.

227. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 26: Extend the scope of application of roadside inspections to N1 vehicles (light
commercial vehicles)

Page description:
This measure would extend the scope of roadside inspections to cover N1 vehicles. The aim
is to address problem driver 2, i.e. that certain vehicles are not (sufficiently) tested for their
roadworthiness, in order to contribute to the achievement of specific objective 2, i.e. to
significantly reduce fraud and tampering (of safety and emission control systems) and
improve the detection of defective vehicles.

228. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

229. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

Reducing the number of
vehicles with tampered
odometers?

230. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

231. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

232. Please elaborate on the other costs mentioned
above.

233. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 27: Extend the scope of application of roadside inspections to powered 2- and 3-
wheeled (L-category) vehicles

Page description:
This measure would extend the scope of roadside inspections to cover L-category vehicles.
The aim is to address problem driver 5 (that certain vehicles are not (sufficiently) tested for
their roadworthiness, in order to contribute to the achievement of specific objectives 1, i.e. to
adapt testing to today’s and tomorrow’s vehicles (improve consistency, objectivity and
quality), and 2, i.e. to prevent fraud and tampering (of safety and emission control systems,
and improve the detection of defective vehicles.

234. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1: Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

235. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

Reducing the number of
vehicles with tampered
odometers?

236. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

237. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

238. Please elaborate on the other costs mentioned
above.

239. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

The remaining questions are for the preliminary measures in the section as a whole, that is
those relating to extending the scope for roadside inspections (RSIs).  

240. In your view, what, if any, impact would this group of measures (if
implemented) have on the following aspects/parameters?

Very
negative

Somewhat
negative

No
impact

Somewhat
positive

Very
positive

Don’t
know

Operation of the EU
Internal market (i.e. in
terms of ensuring fair
competition, avoiding
fraud, eliminating
cross-border trade
obstacles)

Cost and price
competitiveness of
the sectors and
businesses affected
(i.e. related to impacts
on costs of operation,

on costs of operation,
cost of capital, profit
margins)

Innovative capacity of
the sectors and
businesses affected
(i.e. impact on the
capacity of
businesses and
incentives to bring to
the market new
goods/services)

International
competitiveness of
the sectors and
businesses affected
(i.e. specific
costs/benefits for EU
businesses that are
not applicable to their
non-EU competitors)

SME competitiveness
(i.e. lead to costs or
benefits that affect
micro, small and
medium sized
business at a
disproportionate level)

State of the
environment (such as
air quality,
biodiversity,
ecosystem health,
etc)

Level of noise from
road transport

Public health

Employment / jobs in
the affected sectors
and businesses

Fundamental rights
(including in relation
privacy and protection
of data)

241. Please add any comments that you may have on these, or other impacts,
below.

242. In your view, are there likely to be any particular challenges for SMEs, if
any of these preliminary measures were implemented?

Yes

No

Don’t know

243. If ‘Yes’, please explain what these would
be.

244. Are there any measures, in addition to those presented in this
section (e.g. such as other categories of vehicle to which the scope of RSI
might be extended), which could be considered in relation to extending the
scope of roadside inspections (RSI)? Please elaborate.

245. If you have any other comments on preliminary measures relating to
extending the scope of roadside inspections (RSI), please add them
below.

E.8 Introduce new roadside inspections (RSI) test methods and procedures

Page description:
The preliminary measures in this group relate to introducing new RSI test methods and
procedures, so only relate to the RSI Directive. They aim to address the preliminary
problem driver 2, i.e. that current PTI & RSI methods not suited to test certain functions of
modern vehicles (including emissions performance). The preliminary measures considered
are:

PM 20: Require mandatory PN measurement for N1 vehicles and HDVs, as from Euro
5/V-diesel, in the technical roadside inspections of commercial vehicles
PM 22: Extend the scope of the RSI Directive to require the conduct of NOx and noise
measurements by remote sensing for all vehicles (including also M1, N1 and L-
category)
PM 23: Introduce the potential use of plume chasing in technical roadside inspections
of commercial vehicles (optional)

Below you will be asked whether you want to answer questions relating to any preliminary
measure in this group and, if so, which. If you select ‘None’, you will be taken to the next
group of preliminary measures and skip this group. Otherwise, you will be asked to
indicate the preliminary measures in the respective group on which you would like to answer
questions. You will then only be asked the questions relating to the preliminary policy
measures that you select.

246. Please indicate below which of the above preliminary measures, if any,
you would like to answer the questions about (note, if you answer ‘None’, the
survey will skip these preliminary measures and take you on to the next set of
questions): *

None

PM 20: Require mandatory PN measurement for N1 vehicles and HDVs,
as from Euro 5/V-diesel, in the technical roadside inspections of
commercial vehicles

PM 22: Extend the scope of the RSI Directive to require the conduct of
NOx and noise measurements by remote sensing for all vehicles
(including also M1, N1 and L-category)

PM 23: Introduce the potential use of plume chasing in technical roadside
inspections of commercial vehicles (optional)

PM 20: Require mandatory PN measurement for N1 vehicles and HDVs, as from Euro 5/V-
diesel, in the technical roadside inspections of commercial vehicles

Page description:
This measure would require the mandatory PN measurement for diesel N1 vehicles and
HDVs, from Euro 5/V onwards, in roadside inspections. The aim is to address problem driver
2, i.e. that current PTI & RSI methods not suited to test certain functions of modern vehicles
(including emissions performance), and so contribute to the achievement of specific
objectives 1 (to adapt testing to today’s and tomorrow’s vehicles (improve consistency,
objectivity and quality), and 2, i.e. to significantly reduce fraud and tampering (of safety and
emission control systems) and improve the detection of defective vehicles.

247. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1: Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

248. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of
vehicles with defective or
tampered emission control
systems?

 
249. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

250. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

251. Please elaborate on the other costs mentioned
above.

252. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 22: Extend the scope of the RSI Directive to require the conduct of NOx and noise
measurements by remote sensing for all vehicles (including also M1, N1 and L-category)

Page description:
This measure would extend the scope of the RSI Directive to require the conducting of NOx
and noise measurements by remote sensing of M1, N1 and L category vehicles. The aim is
to address problem driver 2, i.e. that current PTI & RSI methods not suited to test certain
functions of modern vehicles (including emissions performance), and so contribute to the
achievement of specific objectives 1 (to adapt testing to today’s and tomorrow’s vehicles
(improve consistency, objectivity and quality), and 2, i.e. to significantly reduce fraud and
tampering (of safety and emission control systems) and improve the detection of defective
vehicles.

253. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1: Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

254. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

255. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

256. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

257. Please elaborate on the other costs mentioned
above.

258. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 23: Introduce the potential use of plume chasing in technical roadside inspections of
commercial vehicles (optional)

Page description:
This measure would introduce the option of using plume chasing (i.e. use of a chase car
driving behind a heavy-duty vehicle to measure and calculate the content of NOx in the
exhaust gas) in the technical roadside testing of commercial vehicles. The aim is to address
problem driver 2, i.e. that current PTI & RSI methods not suited to test certain functions of
modern vehicles (including emissions performance), and so contribute to the achievement of
specific objectives 1 (to adapt testing to today’s and tomorrow’s vehicles (improve
consistency, objectivity and quality), and 2, i.e. to significantly reduce fraud and tampering (of
safety and emission control systems) and improve the detection of defective vehicles.

259. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1: Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

260. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of
vehicles with defective or
tampered emission control
systems?

261. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

262. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

263. Please elaborate on the other costs mentioned
above.

264. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

265. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

266. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

The remaining questions are for the preliminary measures in the section as a whole, that is
those relating to introducing new RSI test methods and procedures.  

267. In your view, what, if any, impact would this group of measures (if
implemented) have on the following aspects/parameters?

Very
negative

Somewhat
negative

No
impact

Somewhat
positive

Very
positive

Don’t
know

Operation of the EU
Internal market (i.e. in
terms of ensuring fair
competition, avoiding
fraud, eliminating
cross-border trade
obstacles)

Cost and price
competitiveness of
the sectors and
businesses affected
(i.e. related to impacts
on costs of operation,
cost of capital, profit
margins)

Innovative capacity of
the sectors and
businesses affected
(i.e. impact on the
capacity of
businesses and
incentives to bring to
the market new
goods/services)

goods/services)

International
competitiveness of
the sectors and
businesses affected
(i.e. specific
costs/benefits for EU
businesses that are
not applicable to their
non-EU competitors)

SME competitiveness
(i.e. lead to costs or
benefits that affect
micro, small and
medium sized
business at a
disproportionate level)

State of the
environment (such as
air quality,
biodiversity,
ecosystem health,
etc)

Level of noise from
road transport

Public health

Employment / jobs in
the affected sectors
and businesses

Fundamental rights
(including in relation
privacy and protection
of data)

268. Please add any comments that you may have on these, or other impacts,
below.

269. In your view, are there likely to be any particular challenges for SMEs, if
any of these preliminary measures were implemented?

Yes

No

Don’t know

270. If ‘Yes’, please explain what these would
be.

271. Are there any measures, in addition to those presented in this section,
which could be considered in relation to introducing new RSI test methods
and procedures? Please elaborate.

272. If you have any other comments on preliminary measures relating to
introducing new RSI test methods and procedures, please add them
below.

E.9 Introduce new Periodic Technical Inspection (PTI) and roadside inspections (RSI) test
requirements and procedures

Page description:
The preliminary measures in this group relate to the introducing new PTI and RSI test
requirements and procedures; this group focuses on preliminary measures that relate to
BOTH the PTI and RSI Directives. The aim is to address problem drivers 1, i.e. PTI methods
not available to test electric vehicles, electronic safety & driver assistance systems, and 2
(that current PTI & RSI methods not suited to test certain functions of modern vehicles
(including emissions performance). The measure here is:

PM 24: 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

Below you will be asked whether you want to answer questions relating to this preliminary
measure. If you select ‘No’, you will be taken to the next group of preliminary
measures and skip this group. Otherwise, you will be asked the questions relating to this
preliminary measure. 

273. Do you want to answer the questions relating to this preliminary
measure? *

Yes

No

PM 24: 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

Page description:
This measure would require the testing of the software status and integrity of safety and
emission relevant systems in both the PTI (for all vehicles) and the RSI (for commercial
vehicles). The aim is to address problem drivers 1, i.e. PTI methods not available to test
electric vehicles, electronic safety & driver assistance systems, and 2 (that current PTI & RSI
methods not suited to test certain functions of modern vehicles (including emissions
performance)), and so contribute to the achievement of specific objectives 1 (to adapt testing
to today’s and tomorrow’s vehicles (improve consistency, objectivity and quality), and 2, i.e.
to significantly reduce fraud and tampering (of safety and emission control systems) and
improve the detection of defective vehicles.

274. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1: Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

275. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

276. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

277. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

278. Please elaborate on the other costs mentioned
above.

279. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

280. In your view, what, if any, impact would this group of measures (if
implemented) have on the following aspects/parameters?

Very
negative

Somewhat
negative

No
impact

Somewhat
positive

Very
positive

Don’t
know

Operation of the EU
Internal market (i.e. in
terms of ensuring fair
competition, avoiding
fraud, eliminating
cross-border trade
obstacles)

Cost and price
competitiveness of
the sectors and
businesses affected
(i.e. related to impacts
on costs of operation,
cost of capital, profit
margins)

Innovative capacity of
the sectors and
businesses affected
(i.e. impact on the
capacity of
businesses and
incentives to bring to
the market new
goods/services)

International
competitiveness of
the sectors and
businesses affected
(i.e. specific
costs/benefits for EU
businesses that are
not applicable to their
non-EU competitors)

SME competitiveness
(i.e. lead to costs or
benefits that affect
micro, small and
medium sized
business at a
disproportionate level)

State of the
environment (such as
air quality,
biodiversity,
ecosystem health,
etc)

Level of noise from
road transport

Public health

Employment / jobs in
the affected sectors
and businesses

Fundamental rights
(including in relation
privacy and protection
of data)

281. Please add any comments that you may have on these, or other impacts,
below.

282. In your view, are there likely to be any particular challenges for SMEs, if
any of this measure was implemented?

Yes

No

Don’t know

283. If ‘Yes’, please explain what these would
be.

284. Are there any measures, in addition to those presented in this section,
which could be considered in relation to introducing new PTI and RSI test
requirements and procedures? Please elaborate.

285. If you have any other comments on preliminary measures relating to
introducing new PTI and RSI test requirements and procedures, please
add them below.

E.10 Access and exchange of information/data

Page description:
The preliminary measures in this group relate to access and exchange of information; this
group focuses on preliminary measures that relate to BOTH the PTI and RSI Directives.
They aim to address the preliminary problem driver 4, i.e. that vehicle identification & status
data not sufficiently available to, and recognised among, enforcing authorities. The
preliminary measures considered are:

PM 28: Provide for the enabling and use of independent remote access to in-vehicle
data in the technical roadside inspections of commercial vehicles
PM 29: Data governance: further define the procedures and the means of access to
vehicle technical information by testing centres free of charge and in standardised
format (cf. Commission Implementing Regulation (EU) 2019/621)
PM 30: Require the electronic storage of roadside inspection 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 (peer-to-peer or via a central
hub)

Below you will be asked whether you want to answer questions relating to any preliminary
measure in this group and, if so, which. If you select ‘None’, you will be taken to the next
group of preliminary measures and skip this group. Otherwise, you will be asked to
indicate the preliminary measures in the respective group on which you would like to answer
questions. You will then only be asked the questions relating to the preliminary policy
measures that you select.

286. Please indicate below which of the above preliminary measures, if any,
you would like to answer the questions about (note, if you answer ‘None’, the
survey will skip these preliminary measures and take you on to the next set of
questions): *

None

PM 28: Provide for the enabling and use of independent remote access
to in-vehicle data in the technical roadside inspections of commercial
vehicles

PM 29: Data governance: further define the procedures and the means of
access to vehicle technical information by testing centres free of charge
and in standardised format (cf. Commission Implementing Regulation
(EU) 2019/621)

PM 30: Require the electronic storage of roadside inspection 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 (peer-to-peer or via a central hub)

PM 28: Provide for the enabling and use of independent remote access to in-vehicle data
in the technical roadside inspections of commercial vehicles

Page description:
This measure would enable and allow the use of independent remote access to in-vehicle
data in the technical roadside inspections of commercial vehicles, so as to enable the
checking of vehicles ‘over-the-air’. The aim is to address problem driver 4, i.e. that vehicle
identification & status data not sufficiently available to, and recognised among, enforcing
authorities. In doing this, it will contribute to the achievement of specific objectives 1, i.e. to
adapt testing to today’s and tomorrow’s vehicles (improve consistency, objectivity and
quality), and 2, i.e. to significantly reduce fraud and tampering (of safety and emission control
systems) and improve the detection of defective vehicles.

287. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1: Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

288. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

Reducing the number of
vehicles with tampered
odometers?

289. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

290. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

291. Please elaborate on the other costs mentioned
above.

292. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

293. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

294. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

PM 29: Data governance: further define the procedures and the means of access to vehicle
technical information by testing centres free of charge and in standardised format (cf.
Commission Implementing Regulation (EU) 2019/621)

Page description:
This measure would facilitate access to technical information for testing centres by requiring
that it is made available free of charge, without undue administrative burden and in a
standardised format. The aim is to address problem driver 4, i.e. that vehicle identification &
status data not sufficiently available to, and recognised among, enforcing authorities. In
doing so, it will contribute to the achievement of specific objectives 1, i.e. to adapt testing to
today’s and tomorrow’s vehicles (improve consistency, objectivity and quality, and 3, i.e. to
improve electronic storage and exchange of relevant vehicle identification and status data.

295. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 1: Adapt
testing to today’s and
tomorrow’s vehicles (improve
consistency, objectivity and
quality)

Specific objective 3: Improve
electronic storage and exchange
of relevant vehicle identification
and status data

 
296. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

Reducing the number of
vehicles with tampered
odometers?

297. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

298. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

299. Please elaborate on the other costs mentioned
above.

300. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

301. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

302. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

PM 30: Require the electronic storage of roadside inspection 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 (peer-to-peer or via a central hub)

Page description:
This measure would require that roadside inspection reports are stored electronically in
national databases. In addition, it would require the access and exchange of data relevant to
roadside inspections to RSI authorities in other EU Member States through a common (yet to
be decided) system. The aim is to address problem driver 4, i.e. that vehicle identification &
status data not sufficiently available to, and recognised among, enforcing authorities, and so
contribute to the achievement of specific objective 3, i.e. to improve electronic storage and
exchange of relevant vehicle identification and status data.

303. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 3: Improve
electronic storage and exchange
of relevant vehicle identification
and status data

304. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

Reducing the number of
vehicles with tampered
odometers?

305. In your view, which would be the most appropriate way to provide
electronic access to relevant data to registration authorities in other EU
Member States?

Peer-to-peer exchange

Via a central hub

Either

Don’t know

Other (please specify)

306. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

307. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

308. Please elaborate on the other costs mentioned
above.

309. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

310. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

311. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

The remaining questions are for the preliminary measures in the section as a whole, that is
those relating to access and exchange of information.  

312. In your view, what, if any, impact would this group of measures (if
implemented) have on the following aspects/parameters?

Very
negative

Somewhat
negative

No
impact

Somewhat
positive

Very
positive

Don’t
know

Operation of the EU
Internal market (i.e. in
terms of ensuring fair
competition, avoiding
fraud, eliminating
cross-border trade
obstacles)

Cost and price
competitiveness of
the sectors and
businesses affected
(i.e. related to impacts
on costs of operation,
cost of capital, profit
margins)

Innovative capacity of
the sectors and
businesses affected
(i.e. impact on the
capacity of
businesses and
incentives to bring to
the market new
goods/services)

goods/services)

International
competitiveness of
the sectors and
businesses affected
(i.e. specific
costs/benefits for EU
businesses that are
not applicable to their
non-EU competitors)

SME competitiveness
(i.e. lead to costs or
benefits that affect
micro, small and
medium sized
business at a
disproportionate level)

State of the
environment (such as
air quality,
biodiversity,
ecosystem health,
etc)

Level of noise from
road transport

Public health

Employment / jobs in
the affected sectors
and businesses

Fundamental rights
(including in relation
privacy and protection
of data)

313. Please add any comments that you may have on these, or other impacts,
below.

314. In your view, are there likely to be any particular challenges for SMEs, if
any of these preliminary measures were implemented?

Yes

No

Don’t know

315. If ‘Yes’, please explain what these would
be.

316. Are there any measures, in addition to those presented in this section,
which could be considered in relation to the access and exchange of
information? Please elaborate.

317. If you have any other comments on preliminary measures relating to
the access and exchange of information, please add them below.

E.11 Vehicle registration measures

Page description:
The preliminary measures in this group relate to vehicle registration, so only relate to the
Vehicle Registration Documents Directive. They aim to address the preliminary problem
driver 4, i.e. that vehicle identification & status data not sufficiently available to, and
recognised among, enforcing authorities. The preliminary measures considered are:

PM 31: Provide electronic access to relevant data to the registration authorities of other
EU Member States through the use of a common IT system (peer-to-peer or via a
central hub)
PM 32: Add a minimum set of new data to the vehicle register, that may include:
country of 1st registration; registration status; PTI status
PM 33: Increase the harmonisation of the technical data in the vehicle registration
documents on the basis of a common standard
PM 34: Introduce the requirement that any vehicle transformation, including any
important vehicle refurbishment or conversion (e.g. emission values), has to be
approved and registered
PM 35: Require issuing of the registration certificates (Annex I) in digital format
PM 36: Require that Member States update vehicle registration data on a regular basis
(period to be defined)

Below you will be asked whether you want to answer questions relating to any preliminary
measure in this group and, if so, which. If you select ‘None’, you will be taken to the next
group of preliminary measures and skip this group. Otherwise, you will be asked to
indicate the preliminary measures in the respective group on which you would like to answer
questions. You will then only be asked the questions relating to the preliminary policy
measures that you select.

318. Please indicate below which of the above preliminary measures, if any,
you would like to answer the questions about (note, if you answer ‘None’, the
survey will skip these preliminary measures and take you on to the next set of
questions): *

None

PM 31: Provide electronic access to relevant data to the registration
authorities of other EU Member States through the use of a common IT
system (peer-to-peer or via a central hub)

PM 32: Add a minimum set of new data to the vehicle register, that may
include: country of 1st registration; registration status; PTI status

PM 33: Increase the harmonisation of the technical data in the vehicle
registration documents on the basis of a common standard

PM 34: Introduce the requirement that any vehicle transformation,
including any important vehicle refurbishment or conversion (e.g.
emission values), has to be approved and registered

PM 35: Require issuing of the registration certificates (Annex I) in digital
format

PM 36: Require that Member States update vehicle registration data on a
regular basis (period to be defined)

PM 31: Provide electronic access to relevant data to the registration authorities of other
EU Member States through the use of a common IT system (peer-to-peer or via a central
hub)

Page description:
This measure would provide electronic access to relevant data to registration authorities of
other Member States through the use of a common (yet to be defined) interface. The aim is
to address problem driver 4, i.e. that vehicle identification & status data not sufficiently
available to, and recognised among, enforcing authorities, and so contribute to the
achievement of specific objective 3, i.e. to improve electronic storage and exchange of
relevant vehicle identification and status data.

319. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 3: Improve
electronic storage and exchange
of relevant vehicle identification
and status data

320. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

321. In your view, which would be the most appropriate way to provide
electronic access to relevant data to registration authorities of other EU
Member States?

Peer-to-peer exchange

Via a central hub

Either

Don’t know

Other (please specify)

322. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

323. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

324. Please elaborate on the other costs mentioned
above.

325. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

326. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

327. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

PM 32: Add a minimum set of new data to the vehicle register, including: country of 1st
registration; registration status (de-registered, suspended, end-of-life); PTI status (validity,
minor/major defects)

Page description:
This measure would define a minimum set of new data that should be included in the vehicle
register, which would include the vehicle’s country of 1st registration, as well as its
registration and PTI status. The aim is to address problem driver 4, i.e. that vehicle
identification & status data not sufficiently available to, and recognised among, enforcing
authorities, and so contribute to the achievement of specific objective 3, i.e. to improve
electronic storage and exchange of relevant vehicle identification and status data.

328. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 3: Improve
electronic storage and exchange
of relevant vehicle identification
and status data

 
329. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

330. In addition to the new data mentioned above (i.e. country of 1st
registration, registration status and PTI status), which of the following data
would you also support being amongst the minimum set of new data to be
included in the vehicle register? (multiple responses possible):

Odometer readings, e.g. those recorded at PTI/RSI

Changes in documentation or transformation of vehicle

Major accidents/incidents

Other (please specify)

331. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective, or you have views on which odometer readings should be recorded
or consider that other data should be included in the vehicle register.

 
The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

332. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

333. Please elaborate on the other costs mentioned
above.

334. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

335. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

336. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

PM 33: Increase the harmonisation of the technical data in the vehicle registration
documents on the basis of a common standard

Page description:
This measure aims to increase the harmonisation of the technical data in the vehicle
registration documents (either paper or digital), specifically the content that is currently
optional as specified in Annexes I and II of the Directive, on the basis of a common standard.
This would include increasing the items for which harmonisation would be mandatory, as well
as potentially adding more items to the Annexes. The aim is to address problem driver 4, i.e.
that vehicle identification & status data not sufficiently available to, and recognised among,
enforcing authorities, and so contribute to the achievement of specific objective 3, i.e. to
improve electronic storage and exchange of relevant vehicle identification and status data.

337. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 3: Improve
electronic storage and exchange
of relevant vehicle identification
and status data

 
338. In your view, should the dataset in the Annexes be considered as the
minimum dataset?

Yes, other data should be allowed if available  

No, no other data should be allowed

Don’t know

339. In your view, should there be one organisation appointed in the
legislation for maintaining the dataset after the revision?

Yes  

No

Don’t know

340. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective, or you have views on which organisation should be responsible for
maintaining the dataset.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

341. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

342. Please elaborate on the other costs mentioned
above.

343. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

344. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

345. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

PM 34: Introduce the requirement that any vehicle transformation, including any important
vehicle refurbishment or conversion (e.g. emission values) has to be approved and
registered

Page description:
This measure would require that any transformations to a vehicle, including refurbishments
and conversion (e.g. those that lead to different emissions), would need to be approved and
registered. The aim is to address problem driver 4, i.e. that vehicle identification & status data
not sufficiently available to, and recognised among, enforcing authorities, and so contribute
to the achievement of specific objectives 2 (to significantly reduce fraud and tampering (of
safety and emission control systems) and improve the detection of defective vehicles), and 3,
i.e. to improve electronic storage and exchange of relevant vehicle identification and status
data.

346. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 2: Significantly
reduce fraud and tampering (of
safety and emission control
systems) and improve the
detection of defective vehicles

Specific objective 3: Improve
electronic storage and exchange
of relevant vehicle identification
and status data

347. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

Reducing the number of
vehicles with defective or
tampered emission control
systems?

Reducing the number of
vehicles with defective or
tampered noise control
systems?

Reducing the number of
vehicles with tampered
odometers?

348. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

349. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

350. Please elaborate on the other costs mentioned
above.

351. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

PM 35: Require issuing of the registration certificates (Annex I) in digital format

Page description:
This measure would require the issuing of registration certificates in a digital format. The aim
is to address problem driver 4, i.e. that vehicle identification & status data not sufficiently
available to, and recognised among, enforcing authorities, and so contribute to the
achievement of specific objective 3, i.e. to improve electronic storage and exchange of
relevant vehicle identification and status data.

352. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 3: Improve
electronic storage and exchange
of relevant vehicle identification
and status data

353. In your view, should the issuing of registration certificates (Annex I) in a
digital format be:

Mandatory

Optional

Don't know

354. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective, or you have views on the format of the digital registration certificates.

 
The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

355. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

356. Please elaborate on the other costs mentioned
above.

357. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

358. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

359. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

PM 36: Require that Member States update vehicle registration data on a regular basis
(period to be defined)

Page description:
This measure would require that Member States update vehicle registration data on a regular
basis, which is yet to be defined. The aim is to address problem driver 4, i.e. that vehicle
identification & status data not sufficiently available to, and recognised among, enforcing
authorities, and so contribute to the achievement of specific objective 3, i.e. to improve
electronic storage and exchange of relevant vehicle identification and status data.

360. In your view, what would the contribution of this measure be to
addressing:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Specific objective 3: Improve
electronic storage and exchange
of relevant vehicle identification
and status data

 
361. In your view what would the contribution of this measure be to:

1 (None at
all)

2

3

4

5

6

7 (Very
high)

Don't
know

Reducing the number of unsafe
vehicles on the EU’s roads?

362. With what frequency should Member States be required to update vehicle
registration data? At least every:

Three months

Six months

Each year

Every two years

Every three years

At every registration renewal

Don’t know

Other (please specify)

363. Please elaborate on any of your responses so far regarding this measure,
particularly if you do not support its adoption and/or do not think that it will be
effective.

 
The question below relates to expected changes in adjustment, administrative or
enforcement costs to your organisation, if any, of each of the policy measures relative to
the status quo. Please distinguish between one-off costs and changes in recurrent costs.
Changes in recurrent costs may include cost savings as well as additional new costs. Where
possible, please indicate the likely costs involved.

364. If this measure was implemented, do you anticipate any new or
additional costs to your organisation / members, such as the following:

Yes,
one-off
costs

Yes,
ongoing
costs

No one-off or
ongoing costs
anticipated

Don’t
know

Adjustment costs (i.e. those
investments and expenses that
businesses, citizens, or public
authorities have to bear in order
to adjust their activity to the
requirements contained in the
measure)?

Administrative costs (those
costs borne by businesses,
citizens, civil society
organisations and public
authorities as a result of
administrative activities
performed to comply with
administrative obligations
included in the measure (e.g.
notifications, reporting,
certification))?

Enforcement costs (i.e. those
associated with activities linked
to the implementation of an
initiative such as monitoring,
inspections and
adjudication/litigation)?

Other costs?

365. Please elaborate on the other costs mentioned
above.

366. If ‘Yes’, for any of the questions on costs, please elaborate on the extent
of these costs (either in terms of € or human resources needed).

367. Do you anticipate any cost savings to your organisation / members, if
this measure was implemented?

Yes

No

Don’t know

368. If ‘Yes’, please elaborate on the nature of any savings, e.g. whether they
are one-off or ongoing, and on the extent of these (either in terms of € or
human resources no longer needed).

The remaining questions are for the preliminary measures in the section as a whole, that is
those relating to vehicle registration.  

369. In your view, what, if any, impact would this group of measures (if
implemented) have on the following aspects/parameters?

Very
negative

Somewhat
negative

No
impact

Somewhat
positive

Very
positive

Don’t
know

Operation of the EU
Internal market (i.e. in
terms of ensuring fair
competition, avoiding
fraud, eliminating
cross-border trade
obstacles)

Cost and price
competitiveness of
the sectors and
businesses affected
(i.e. related to impacts
on costs of operation,
cost of capital, profit
margins)

Innovative capacity of
the sectors and
businesses affected
(i.e. impact on the
capacity of
businesses and
incentives to bring to
the market new
goods/services)

goods/services)

International
competitiveness of
the sectors and
businesses affected
(i.e. specific
costs/benefits for EU
businesses that are
not applicable to their
non-EU competitors)

SME competitiveness
(i.e. lead to costs or
benefits that affect
micro, small and
medium sized
business at a
disproportionate level)

State of the
environment (such as
air quality,
biodiversity,
ecosystem health,
etc)

Level of noise from
road transport

Public health

Employment / jobs in
the affected sectors
and businesses

Fundamental rights
(including in relation
privacy and protection
of data)

370. Please add any comments that you may have on these, or other impacts,
below.

371. In your view, are there likely to be any particular challenges for SMEs, if
any of these preliminary measures were implemented?

Yes

No

Don’t know

372. If ‘Yes’, please explain what these would
be.

373. Are there any measures, in addition to those presented in this section,
which could be considered in relation to the vehicle registration? Please
elaborate.

374. If you have any other comments on preliminary measures relating to
the vehicle registration, please add them below.

G. Closing comments

375. If you would be happy to be contacted further by the study team, e.g. for
an interview, please indicate this in the box below and leave appropriate
contact details.  

376. If you have any other closing comments on this survey, please add them
below.

Thank You!

Thank you for your contributions! For any further comments or questions, contact us
at the following email address: RWP_IA@ricardo.com

1.  Annex 2 – Charts for survey responses (closed-response questions)
1.1. 
1.1.1.  On the basis of your experience, what has been, to this point, the contribution to reducing 

Section C - Baseline 

the number of the unsafe vehicles (i.e. vehicles with safety defects) on the EU’s roads in the 
period since the adoption of the current roadworthiness package in 2014 of the following: 

Question option 
Technological and market developments 
Enforcement of roadworthiness legislation 
Other measures taken at the Member State 
level 

Weighted average 
4.47 
4.96 

4.23 

1.1.2. 

In your view, in the absence of any further EU policy interventions, what do you expect to be 
in the coming period up to 2030 the additional contribution to reducing the number of the 
unsafe vehicles (i.e. vehicles with safety defects) on the EU’s roads of the following:  

Question option 
Technological and market developments 
Enforcement of roadworthiness legislation 
Other measures taken at the Member State 
level 

Weighted average 
3.84 
3.58 

3.63 

1.1.3.  On the basis of your experience, what has been, to this point, the contribution to reducing 

the number of vehicles with defective or tampered emission control systems on the EU’s 
roads in the period since the adoption of the current roadworthiness package in 2014 of the 
following aspects 

Question option 
Technological and market developments 
Enforcement of roadworthiness legislation 
Other measures taken at the Member State 
level 

Weighted average 
4.00 
3.95 

3.79 

1.1.4. 

In your view, in the absence of any further EU policy interventions, what do you expect to be 
in the coming period up to 2030 the additional contribution to reducing the number of 
vehicles with defective or tampered emission control systems on the EU’s roads of the 
following: 

Question option 
Technological and market developments 
Enforcement of roadworthiness legislation 
Other measures taken at the Member State 
level 

Weighted average 
3.69 
3.45 

3.64 

1.1.5.  On the basis of your experience, what has been, to this point, the contribution to reducing 

the number of vehicles with defective or tampered noise control systems on the EU’s roads in 
the period since the adoption of the current roadworthiness package in 2014 of the following 
aspects 

Question option 
Technological and market developments 
Enforcement of roadworthiness legislation 
Other measures taken at the Member State 
level 

Weighted average 
3.20 
3.76 

3.73 

1.1.6. 

In your view, in the absence of any further EU policy interventions, what do you expect to be 
in the coming period up to 2030 the additional contribution to reducing the number of 
vehicles with defective or tampered noise control systems on the EU’s roads of the following: 

Question option 
Technological and market developments 
Enforcement of roadworthiness legislation 
Other measures taken at the Member State 
level 

Weighted average 
3.33 
3.44 

3.80 

1.1.7.  On the basis of your experience, what has been, to this point, the contribution to reducing 

the number of vehicles with tampered odometers on the EU’s roads since the adoption of the 
current roadworthiness package in 2014 of the following aspects 

Question option 
Technological and market developments 
Enforcement of roadworthiness legislation 
Other measures taken at the Member State 
level 

Weighted average 
3.31 
3.78 

4.00 

1.1.8. 

In your view, in the absence of any further EU policy interventions, what do you expect to be 
in the coming period up to 2030 the additional contribution to reducing the number of 
vehicles with tampered odometers on the EU’s roads of the following 

Question option 
Technological and market developments 
Enforcement of roadworthiness legislation 
Other measures taken at the Member State 
level 

Weighted average 
3.75 
3.52 

3.94 

1.1.9.  Based on your experience, what has been, to this point, the contribution to improving the 
process of re-registration of vehicles across the EU since the adoption of the current 
roadworthiness package in 2014 of the following aspects: 

Question option 
Technological and market developments 
Enforcement of roadworthiness legislation 
Other measures taken at the Member State 
level 

Weighted average 
3.94 
3.83 

4.07 

1.1.10.  In your view, in the absence of any further EU policy interventions, what do you expect to be 

in the coming period up to 2030 the additional contribution to improving the process of re-
registration of vehicles across the EU of the following: 

Question option 
Technological and market developments 
Enforcement of roadworthiness legislation 
Other measures taken at the Member State 
level 

Weighted average 
3.88 
3.23 

4.03 

1.1.11.  Based on your experience, what has been, to this point,  the contribution of (electronic) data 

exchange to: 

Question option 
Improve process of re-registration of vehicles 
across the EU with 2014 adoption of the RWP 

Weighted average 

3.19 

1.1.12.  Following the 2014 adoption of the RW, please specify how data exchange for the purposes 
of re-registration of vehicles across the EU currently works in your country, in relation to the 
following: 

1.1.13.  Following the 2014 adoption of the RW, please specify how data exchange for the purposes 
of re-registration of vehicles across the EU currently works in your country, in relation to the 
following:  

Section D - Policy drivers and policy objectives 

1.2. 
1.2.1.  Please indicate your level of agreement with the preliminary problems and problem 

drivers identified? 

 
 
 
 
 
 
 
1.2.2.  Please indicate your level of agreement with the appropriateness of the preliminary 

specific objectives for this initiative? 

1.3. 

Section E1 - Scope of vehicles covered by the Periodic Technical Inspection 
(PTI) Directive 

1.3.1.  PM1 - Introduce mandatory PTI for all motorcycles over 50 cm3 (L3-L7 category) and 

remove the current opt-out for vehicles over 125 cm3 

1.3.1.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

  4.77 

1.3.1.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 
Reduce defective/tampered emission control 
Reduce defective/tampered noise control 
Reduce vehicles with tampered odometers 

Weighted average 
5.1 
4.34 
4.24 
3.89 

1.3.1.3. 

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

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

s
t
n
e
d
n
o
p
s
e
r

l

a
t
o
t

f
o

e
r
a
h
S

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

60%

57%

59%

60%

Two-wheel
motorcycle
(L3e)

Two-wheel
motorcycle with
side car (L4e)

Tricycles (L5e)

Heavy
quadricycles
(L7e)

None of these Don't know / No

response

31%

9%

 
 
 
 
 
 
 
 
 
 
1.3.2.  PM3 - Introduce mandatory PTI for all agricultural and forestry tractors (T category), 

i.e. remove opt-out

1.3.2.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

  4.56 

1.3.2.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 
Reduce defective/tampered emission control 
Reduce defective/tampered noise control 
Reduce vehicles with tampered odometers 

Weighted average 
4.57 
3.88 
3.28 
3.1 

1.3.3.  PM4 - Introduce mandatory PTI for light trailers (O1 and O2) 
1.3.3.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

4.26 

1.3.3.2. 

In your view, in the context of improving road transport safety, what would the 
contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 

Weighted average 
4.62 

1.3.3.3. 

In your view, to which categories of trailer should mandatory PTI be extended (multiple 
responses possible): 

1.3.3.3. In your view, to which categories of trailer should mandatory PTI 
be extended (multiple responses possible): 

s
t
n
e
d
n
o
p
s
e
r

l

a
t
o
t

f
o

e
r
a
h
S

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

39%

49%

47%

O1 (trailers with a
maximum mass not
exceeding 750kg)

O2 (trailers with a
maximum mass
exceeding 750kg but
not exceeding 3,500kg)

3%

Neither of these

Don't know / No
response

 
 
 
 
1.3.4.  E1 Measure group 
1.3.4.1. 

In your view, what, if any, impact would this group of measures (if implemented) have on 
the following aspects/parameters? 

Question option 
Operation of the EU Internal market 
Cost and price competitiveness of sectors affected 
Innovative capacity of sectors affected 
International competitiveness of sectors affected 
SME competitiveness 
State of the environment 
Noise from road transport 
Public health 
Employment in affected sectors 
Fundamental rights 

Weighted average 
4.20 
3.51 
3.93 
3.61 
3.32 
4.47 
4.45 
4.39 
4.04 
3.38 

 
 
  
 
1.3.4.2. 

In your view, are there likely to be any particular challenges for SMEs, if any of these 
preliminary measures were implemented? 

Section E2 - Frequency of Periodic Technical Inspection (PTI) testing 

1.4. 
1.4.1.  PM5 - Require more frequent emission testing (yearly test from the date of 

registration) for light duty commercial vehicles (N1 category) 

1.4.1.1. 

In your view, what would the contribution of this measure be to addressing:  

Question option 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

4.27 

1.4.1.2. 

In your view what would the contribution of this measure be to:   

Question option 
Reduce defective/tampered emission control 

Weighted average 
4.30 

1.4.2.  PM6 - Require mandatory yearly testing for vehicles that are 10-year-old and older 
1.4.2.1. 
In your view, what would the contribution of this measure be to addressing:   

 
 
 
 
 
 
 
Question option 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

4.89 

1.4.2.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 
Reduce defective/tampered emission control 
Reduce defective/tampered noise control 
Reduce vehicles with tampered odometers 

Weighted average 
5.03 
4.74 
4.36 
4.47 

1.4.3.  PM7 - Introduce option for a simplified PTI (i.e. no emission/noise testing) if vehicle 

passed recent roadside inspection (including remote sensing) 

1.4.3.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

2.73 

1.4.3.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce defective/tampered emission control 
Reduce defective/tampered noise control 

Weighted average 
3.19 
3.33 

1.4.3.3. 

In your view, which aspects of a full PTI should not be undertaken in the event that the 
vehicle has recently successfully passed a roadside inspection, including by remote 
sensing? 

1.4.4.  PM8 - PTIs mandatory for crashed vehicles with significant damage (affecting the 

main safety components) 

1.4.4.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

4.70 

1.4.4.2. 

In your view what would the contribution of this measure be to 

Question option 
Reduce unsafe vehicles  on the EU’s roads 

Weighted average 
4.72 

1.4.5.  PM9 - PTIs mandatory following significant modifications (e.g. change of class, 

propulsion system) 

1.4.5.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

  4.76 

1.4.5.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 
Reduce defective/tampered emission control 
Reduce defective/tampered noise control 
Reduce vehicles with tampered odometers 

Weighted average 
4.69 
4.8 
4.41 
3.97 

 
 
1.4.6.  E2 Measure Group 
1.4.6.1. 

In your view, what, if any, impact would this group of measures (if implemented) have on 
the following aspects/parameters? 

Question option 
Operation of the EU Internal market 
Cost and price competitiveness of sectors affected 
Innovative capacity of sectors affected 
International competitiveness of sectors affected 
SME competitiveness 
State of the environment 
Noise from road transport 
Public health 
Employment in affected sectors 
Fundamental rights 

Weighted average 
4.06 
3.49 
3.80 
3.51 
3.29 
4.33 
4.20 
4.30 
3.92 
3.44 

 
 
  
 
1.5. 

Section E3 - Recognition of Periodic Technical Inspection (PTI) in another 
country 

1.5.1.  PM10 - Require that a PTI certificate issued in any other EU Member State is 
recognised by Member State of registration (under certain conditions) 

1.5.1.1. 

In your view, what would the contribution of this measure be to addressing:   

Question option 
SO3 - Improve electronic storage & vehicle data 
exchange 

Weighted average 

3.97 

1.5.2.  PM11 - Require that PTI certificate issued in another EU Member State is recognised 

by Member State of registration, on the basis of a bilateral agreement among the 
Member States 

1.5.2.1. 

In your view, what would the contribution of this measure be to addressing:   

Question option 
SO3 - Improve electronic storage & vehicle data 
exchange 

Weighted average 

         4.00  

 
 
 
 
1.5.3.  E3 Measure group 
1.5.3.1. 

In your view, what, if any, impact would this group of measures (if implemented) have on 
the following aspects/parameters? 

Question option 
Operation of the EU Internal market 
Cost and price competitiveness of sectors affected 
Innovative capacity of sectors affected 
International competitiveness of sectors affected 
SME competitiveness 
State of the environment 
Noise from road transport 
Public health 
Employment in affected sectors 
Fundamental rights 

Weighted average 
3.59 
3.12 
3.03 
3.26 
3.16 
2.97 
2.98 
3.03 
2.98 
2.94 

 
 
  
 
1.5.3.2. 

In your view, are there likely to be any particular challenges for SMEs, if any of these 
preliminary measures were implemented? 

Section E4 - Roadworthiness certificate 

1.6. 
1.6.1.  PM12 - Require roadworthiness certificate to be issued in electronic format 
1.6.1.1. 

In your view, what would the contribution of this measure be to addressing:   

Question option 
SO3 - Improve electronic storage & vehicle data 
exchange 

Weighted average 

5.44 

1.6.1.2. 

In your view, if the roadworthiness certificate was made available electronically, should 
the paper version still be made available? 

1.6.2.  E4 Measure group 
1.6.2.1. 

In your view, what, if any, impact would this group of measures (if implemented) have on 
the following aspects/parameters? 

Question option 
Operation of the EU Internal market 
Cost and price competitiveness of sectors affected 
Innovative capacity of sectors affected 
International competitiveness of sectors affected 
SME competitiveness 
State of the environment 
Noise from road transport 
Public health 
Employment in affected sectors 
Fundamental rights 

Weighted average 
4.31 
3.75 
3.95 
3.62 
3.39 
3.82 
3.33 
3.6 
3.28 
3.24 

1.6.2.2. 

In your view, are there likely to be any particular challenges for SMEs, if any of this 
measure was implemented? 

1.7. 

Section E5 - Improve current Periodic Technical Inspection (PTI) test 
requirements and procedures 

1.7.1.  PM13 -  Require that PTI includes more advanced testing of noise for motorcycles 
1.7.1.1. 

In your view, what would the contribution of this measure be to addressing:  

Question option 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

         4.19 

1.7.1.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce defective/tampered noise control 

Weighted average 
         4.38 

 
 
 
 
 
 
 
1.7.2.  PM14 - Require that PTI includes advanced testing of lighting to cover advanced 

headlamps 

1.7.2.1. 

In your view, what would the contribution of this measure be to addressing:  

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

4.95 

3.93 

1.7.2.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 

Weighted average 
4.28  

1.7.3.  PM15 - Require more advanced testing of braking for HDVs (extrapolation methods) 
1.7.3.1. 
In your view, what would the contribution of this measure be to addressing:   

 
 
 
 
 
 
 
 
Question option 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

4.74  

1.7.3.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 

Weighted average 
4.70  

1.7.4.  PM16 - Require training of inspectors for PTI in relation to electric vehicles 
1.7.4.1. 
In your view, what would the contribution of this measure be to addressing:   

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 

Weighted average 

5.34  

1.7.4.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 

Weighted average 
4.69  

 
 
 
 
 
 
 
1.7.5.  E5 Measure group 
1.7.5.1. 

In your view, what, if any, impact would this group of measures (if implemented) have on 
the following aspects/parameters? 

Question option 
Operation of the EU Internal market 
Cost and price competitiveness of sectors affected 
Innovative capacity of sectors affected 
International competitiveness of sectors affected 
SME competitiveness 
State of the environment 
Noise from road transport 
Public health 
Employment in affected sectors 
Fundamental rights 

Weighted average 
4.00 
3.60 
3.90 
3.61 
3.34 
3.98 
3.77 
4.02 
3.91 
3.42 

 
 
  
 
1.7.5.2. 

In your view, are there likely to be any particular challenges for SMEs, if any of these 
preliminary measures were implemented? 

1.8. 

Section E6 - Introduce new Periodic Technical Inspection (PTI) test 
requirements and procedures 

1.8.1.  PM17 - Adapt PTI to cover the particularities of electric and hybrid vehicles (e.g. high-

voltage systems) 

1.8.1.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 

Weighted average 

5.18 

1.8.1.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 

Weighted average 
4.78 

1.8.2.  PM18 - Update PTI with new test items to cover safety systems introduced as part of 

the General Safety Regulation using ePTI (on the basis of standard ISO 20730:2021) 

1.8.2.1. 

In your view, what would the contribution of this measure be to addressing:   

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 

Weighted average 

5.32 

1.8.2.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 

Weighted average 
5.03 

1.8.3.  PM19 - Require mandatory testing of particle numbers (PN) at PTI for LDVs and HDVs 

based on Commission Recommendation (EU) 2023/688 containing guidelines for 
particle number concentration testing during PTI 

1.8.3.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

5.31 

5.07 

1.8.3.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce defective/tampered emission control 

Weighted average 
5.26 

1.8.4.  PM21 - Require NOx testing of LDVs and HDVs at PTI on the basis of testing methods 

developed by the JRC 

1.8.4.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

5.23 

5.05 

1.8.4.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce defective/tampered emission control 

Weighted average 
5.11 

1.8.5.  E6 Measure group 
1.8.5.1. 

In your view, what, if any, impact would this group of measures (if implemented) have on 
the following aspects/parameters? 

Question option 
Operation of the EU Internal market 
Cost and price competitiveness of sectors affected 
Innovative capacity of sectors affected 
International competitiveness of sectors affected 
SME competitiveness 
State of the environment 
Noise from road transport 
Public health 
Employment in affected sectors 
Fundamental rights 

Weighted average 
4.31 
3.75 
4.02 
3.79 
3.33 
4.47 
3.84 
4.49 
3.82 
3.34 

1.8.5.2. 

In your view, are there likely to be any particular challenges for SMEs, if any of these 
preliminary measures were implemented? 

Section E7 - Extend scope of roadside inspections (RSI) 

1.9. 
1.9.1.  PM25 -  Introduce mandatory standards in relation to cargo securing inspections 
1.9.1.1. 

In your view, what would the contribution of this measure be to addressing:   

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 

Weighted average 

4.99 

1.9.1.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 

Weighted average 
5.54 

1.9.2.  PM26 -  Extend the scope of application of roadside inspections to N1 vehicles (light 

commercial vehicles) 

1.9.2.1. 

In your view, what would the contribution of this measure be to addressing:  

Question option 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

5.04  

1.9.2.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 

Weighted average 
4.96  

 
 
  
 
 
 
 
Reduce defective/tampered emission control 
Reduce defective/tampered noise control 
Reduce vehicles with tampered odometers 

4.79 
4.17 
4.26 

1.9.3.  PM27 -  Extend the scope of application of roadside inspections to powered 2- and 3-

wheeled (L-category) vehicles 

1.9.3.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

5.04 

4.91 

1.9.3.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 
Reduce defective/tampered emission control 
Reduce defective/tampered noise control 
Reduce vehicles with tampered odometers 

Weighted average 
5 
4.96 
4.88 
4.44 

1.9.4.  E7 Measure group 
1.9.4.1. 

In your view, what, if any, impact would this group of measures (if implemented) have on 
the following aspects/parameters? 

Question option 
Operation of the EU Internal market 
Cost and price competitiveness of sectors affected 
Innovative capacity of sectors affected 
International competitiveness of sectors affected 
SME competitiveness 
State of the environment 
Noise from road transport 
Public health 
Employment in affected sectors 
Fundamental rights 

Weighted average 
3.93 
3.70 
3.61 
3.7 
3.65 
4.23 
4.44 
4.30 
3.65 
3.50 

1.9.4.2. 

In your view, are there likely to be any particular challenges for SMEs, if any of these 
preliminary measures were implemented? 

1.10.  Section E8 - Introduce new roadside inspections (RSI) test methods and 

procedures 

1.10.1. PM20 - Require mandatory PN measurement for N1 vehicles and HDVs, as from Euro 

5/V-diesel, in the technical roadside inspections of commercial vehicles 

1.10.1.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

4.80 
4.89 

1.10.1.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce defective/tampered emission control 

Weighted average 
4.89 

 
1.10.2. PM22 - Extend the scope of the RSI Directive to require the conduct of NOx and noise 
measurements by remote sensing for all vehicles (including also M1, N1 and L-
category) 

1.10.2.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

4.45 

4.81 

1.10.2.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce defective/tampered emission control 
Reduce defective/tampered noise control 

Weighted average 
4.50 
4.33 

1.10.3. PM23 - Introduce the potential use of plume chasing in technical roadside inspections 

of commercial vehicles (optional) 

1.10.3.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

4.31 

4.14 

1.10.3.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce defective/tampered emission control 

Weighted average 
4.15 

1.10.4. E8 Measure group 
1.10.4.1. 

In your view, what, if any, impact would this group of measures (if implemented) have on 
the following aspects/parameters? 

Question option 
Operation of the EU Internal market 
Cost and price competitiveness of sectors affected 
Innovative capacity of sectors affected 
International competitiveness of sectors affected 
SME competitiveness 
State of the environment 
Noise from road transport 
Public health 
Employment in affected sectors 
Fundamental rights 

Weighted average 
3.93 
3.55 
3.83 
3.71 
3.62 
4.33 
4.17 
4.41 
3.67 
3.56 

1.10.4.2. 

In your view, are there likely to be any particular challenges for SMEs, if any of these 
preliminary measures were implemented? 

1.11.  Section E9 - Introduce new Periodic Technical Inspection (PTI) and roadside 

inspections (RSI) test requirements and procedures 

1.11.1. PM24 - 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 

1.11.1.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

5.29 

4.88 

1.11.1.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 
Reduce defective/tampered emission control 
Reduce defective/tampered noise control 

Weighted average 
5.04 
5.08 
4.09 

1.11.2. E9 Measure group 
1.11.2.1. 

In your view, what, if any, impact would this group of measures (if implemented) have on 
the following aspects/parameters? 

Question option 
Operation of the EU Internal market 
Cost and price competitiveness of sectors affected 
Innovative capacity of sectors affected 
International competitiveness of sectors affected 
SME competitiveness 
State of the environment 
Noise from road transport 
Public health 
Employment in affected sectors 
Fundamental rights 

Weighted average 
4.05 
3.89 
4.05 
3.53 
3.52 
4.38 
3.95 
4.39 
3.85 
3.52 

1.11.2.2. 

In your view, are there likely to be any particular challenges for SMEs, if any of these 
preliminary measures were implemented? 

1.12.  Section E10 - Access and exchange of information/data 
1.12.1. PM28 - Provide for the enabling and use of independent remote access to in-vehicle 

data in the technical roadside inspections of commercial vehicles 

1.12.1.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 

Weighted average 

4.72 

4.42 

1.12.1.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 
Reduce defective/tampered emission control 
Reduce defective/tampered noise control 
Reduce vehicles with tampered odometers 

Weighted average 
4.59 
4.38 
3.91 
4.24 

1.12.2. PM29 - Data governance: further define the procedures and the means of access to 

vehicle technical information by testing centres free of charge and in standardised 
format (cf. Commission Implementing Regulation (EU) 2019/621) 

1.12.2.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO1 - Adapt testing to today's and tomorrow’s 
vehicles 
SO3 – Improve electronic storage and vehicle 
data exchange 

Weighted average 

5.24 

5.11 

1.12.2.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 
Reduce defective/tampered emission control 
Reduce defective/tampered noise control 
Reduce vehicles with tampered odometers 

Weighted average 
4.78 
4.58 
3.8 
4.08 

1.12.3. PM30 - Require the electronic storage of roadside inspection 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 (peer-to-peer or 
via a central hub) 
1.12.3.1. In your view, what would the contribution of this measure be to addressing: 

Question option 
SO3 - Improve electronic storage & vehicle data 
exchange 

Weighted average 

4.86 

1.12.3.2. In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 
Reduce defective/tampered emission control 
Reduce defective/tampered noise control 
Reduce vehicles with tampered odometers 

Weighted average 
4.36 
4.33 
4.11 
4.4 

1.12.4. E10 Measure group 
1.12.4.1. 

In your view, what, if any, impact would this group of measures (if implemented) 
have on the following aspects/parameters? 

Question option 
Operation of the EU Internal market 
Cost and price competitiveness of sectors affected 
Innovative capacity of sectors affected 
International competitiveness of sectors affected 
SME competitiveness 
State of the environment 
Noise from road transport 
Public health 
Employment in affected sectors 
Fundamental rights 

Weighted average 
4.35 
3.98 
3.96 
3.76 
3.68 
4.19 
3.76 
3.98 
3.84 
3.51 

1.13.  Section E11 - Vehicle registration measures 
1.13.1. PM31 - Provide electronic access to relevant data to the registration authorities of 

other EU Member States through the use of a common IT system (peer-to-peer or via 
a central hub) 

1.13.1.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO3 - Improve electronic storage & vehicle data 
exchange 

Weighted average 

  5.23 

1.13.1.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 

Weighted average 
4.45 

1.13.1.3. 

In your view, which would be the most appropriate way to provide electronic access to 
relevant data to registration authorities of other EU Member States? 

1.13.2. PM32 - Add a minimum set of new data to the vehicle register, including: country of 
1st registration, registration status (de-registered, suspended, end-of-life), PTI status 
(validity, minor/major defects) 

1.13.2.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO3 - Improve electronic storage & vehicle data 
exchange 

Weighted average 

5.23 

1.13.2.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 

Weighted average 
4.61 

1.13.2.3. 

In addition to the new data mentioned above (i.e. country of 1st registration, registration 
status and PTI status), which of the following data would you also support being amongst 
the minimum set of new data to be included in the vehicle register? (multiple responses 
possible): 

1.13.2.3. In addition to the new data mentioned above (i.e. country of 1st 
registration, registrationstatus and PTI status), which of the following 
data would you also support being amongstthe minimum set of new data 
to be included in the vehicle register

s
t
n
e
d
n
o
p
s
e
r

l

a
o

t

t

f

o

e
r
a
h
S

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

56%

43%

53%

Changes in
documentation or
transformation of
vehicle

Major
accidents/incidents

Odometer
readings, e.g.
those recorded at
PTI/RSI

40%

11%

Other (please
specify)

Don't know / No
response

1.13.3. PM33 - Increase the harmonisation of the technical data in the vehicle registration 

documents on the basis of a common standard 

1.13.3.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO3 - Improve electronic storage & vehicle data 
exchange 

Weighted average 

5.32 

1.13.3.2. 

In your view, should the dataset in the Annexes be considered as the minimum dataset? 

 
 
 
1.13.4. PM34 - Introduce the requirement that any vehicle transformation, including any 

important vehicle refurbishment or conversion (e.g. emission values) has to be 
approved and registered 

1.13.4.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO2 - Reduce fraud & tampering, detect 
defective vehicles 
SO3 - Improve electronic storage & vehicle data 
exchange 

Weighted average 

5.17 

5.24 

1.13.4.2. 

In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 
Reduce defective/tampered emission control 

Weighted average 
5.04 
4.58 

Reduce defective/tampered noise control 
Reduce vehicles with tampered odometers 

4.56 
4.09 

1.13.5. PM35 - Require issuing of the registration certificates (Annex I) in digital format 
1.13.5.1. 

In your view, what would the contribution of this measure be to addressing:   

Question option 
SO3 - Improve electronic storage & vehicle data 
exchange 

Weighted average 

4.89 

1.13.5.2. 

In your view, should the issuing of registration certificates (Annex I) in a digital format be: 

1.13.6. PM36 - Require that Member States update vehicle registration data on a regular 

basis (period to be defined) 

1.13.6.1. 

In your view, what would the contribution of this measure be to addressing: 

Question option 
SO3 - Improve electronic storage & vehicle data 
exchange 

Weighted average 

5.00 

1.13.6.2. 

 In your view what would the contribution of this measure be to: 

Question option 
Reduce unsafe vehicles  on the EU’s roads 

Weighted average 
4.48 

1.13.7. E11 Measure group 
1.13.7.1. 

In your view, what, if any, impact would this group of measures (if implemented) have on 
the following aspects/parameters? 

Question option 
Operation of the EU Internal market 
Cost and price competitiveness of sectors affected 

Weighted average 
4.30 
3.73 

Innovative capacity of sectors affected 
International competitiveness of sectors affected 
SME competitiveness 
State of the environment 
Noise from road transport 
Public health 
Employment in affected sectors 
Fundamental rights 

3.92 
3.69 
3.42 
3.86 
3.67 
3.76 
3.39 
3.39 

1.13.7.2. 

In your view, are there likely to be any particular challenges for SMEs, if any of these 
preliminary measures were implemented? 

Impact assessment support study on the possible 
revision of the Roadworthiness package 

Annex 3 - Interview Questions 

A. Introduction

Objectives 

Ricardo  Energy  &  Environment  (in  a  consortium  with  TRT,  E3M  Modelling,  TEPR  and  the 
Spark)  has  been  appointed  by  the  European  Commission  (DG  MOVE)  to  support  the 
Commission  in  the  preparation  of  an  Impact  assessment  (IA)  support  study  on  the 
Directives of the Roadworthiness package (RWP). The Directives involved are: 

- Directive 2014/45/EU on periodic roadworthiness tests, known as the Periodic

Technical Inspection (PTI) Directive.

- Directive 2014/47/EU on technical roadside inspections (the Technical Roadside

Inspection (RSI) Directive).

- Directive 2014/46 (the Vehicle Registration Documents Directive).

The study will support DG MOVE in a potential revision of these Directives. 

This set of interview questions has been developed as part of the stakeholder engagement 
aspect of the project. It aims to explore the views of stakeholders on:  

1. Their views on the measures that might be implemented to improve the functioning of

the RWP.

2. The possible costs and potential savings to different stakeholders resulting from the

implementation of these potential measures.

3. Obtain data on the potential impacts of the different measures.

Use of your input 

The  study  team  will  keep  detailed  notes  of  the  discussion  and  will  make  use  of  your 
contribution (information/data provided) only for the needs of this study. The interview notes 
will  be  shared  with  DG  MOVE  of  the  European  Commission.  The  interview  notes  and  any 
subsequent written contribution will not be published. However, we may refer to information 
provided  in  the  interviews  within  the  final  report,  except  where  specific  confidentiality 
considerations  have been  identified.  Ricardo and  partners  are  happy to  discuss and agree 
confidentiality requirements where this would be necessary. Please see our privacy statement. 

Please  indicate  how  you  would  like  us  to  refer  to  any  information  provided  in  your 
interview: 

Your contribution will be referenced to the organisation represented; 

1 

Your contribution will be anonymised (i.e. without the name/name of 
the organisation but with affiliation to industry sector, e.g. national 
authority, transport operator representative, environmental NGO etc.).  

B. Profile of respondent / Contact information

Trade association / NGO / consumer organisation / Academia or 
research institution / Other 

Organisation name: 

Type of organisation: 

Area of interest: 

Geographical scope: 

Contact name: 

Role in the organisation: 

Email address: 

C. Problem analysis – general issues

1.

In your view, what challenges currently exist in relation to the functioning of
RWP?

D. Problem drivers and policy objectives

The analysis of the challenges with the current Roadworthiness package are already well 
advanced. The following preliminary problems areas and their underlying problem drivers 
(PDs have been identified: 

Problems (preliminary) 
A - Presence of unsafe vehicles on 
EU roads 

B – Presence of polluting vehicles 
on EU roads 

Problem Drivers (preliminary) 
PD1 - PTI-methods not available to test electric vehicles, 
electronic safety & driver assistance systems 
PD3 – Limited technical possibilities to detect vehicles 
with defective or tampered components 
PD5 - Certain vehicles are not (sufficiently) tested for their 
roadworthiness 
PD2 - Current PTI & RSI methods not suited to test certain 
functions of modern vehicles (including emissions 
performance) 

2 

C- Roadworthiness Directives are
not effective in enforcing rules in
EU cross-border traffic or trade of
vehicles

PD3 – Limited technical possibilities to detect vehicles 
with defective or tampered components 
PD5 - Certain vehicles are not (sufficiently) tested for their 
roadworthiness 
PD3 – Limited technical possibilities to detect vehicles 
with defective or tampered components 
PD4 - Vehicle identification & status data not sufficiently 
available to, and recognised among, enforcing authorities 

2. Do you agree with the problems and problem drivers identified? Please

elaborate on your views, including on any amendments or additions that you
would like to see.

3. To what extent has the situation evolved since the adoption of the current

roadworthiness package in 2014?

4.

In the absence of further EU action, how do you think the situation will evolve in
the coming period up to 2030?

In  order  to  address  the  preliminary  problem  drivers  and  problem  areas  that  have  been 
identified,  the  following  specific  objectives  of  the  proposed  intervention  have  been 
identified: 

- Specific objective 1 (SO1):  Adapt testing to today’s and tomorrow’s vehicles

(improve consistency, objectivity and quality).

3 

- Specific objective 2 (SO2): Significantly reduce fraud and tampering (of safety and

emission control systems) and improve the detection of defective vehicles.
- Specific objective 3 (SO3): Improve electronic storage and exchange of relevant

vehicle identification and status data.

5.

In your view, are the specific objectives appropriate to address the problems
with the current RWP? Please elaborate on your views, including on any
amendments or additions that you would like to see.

E. Input on potential measures for the revision of the RWP

A  set  of  preliminary  policy  measures  that  might  address  the  preliminary  problems 
identified has been developed. These have been developed to address the limitations and 
challenges  of  the  current  roadworthiness  package  (RWP)  and  so  deliver  the  proposed 
objectives, as set out above. The measures under consideration cover all three Directives 
of  the  RWP  and  have  been  grouped  together  depending  on  the  particular  aspects  and 
Directive that they address. 

In total, there are 36 measures under consideration, which have been brought together in 
11 different groups. The groups bring together measures that affect a particular aspect of 
at least one of the Directives. The measures under consideration will be listed when each 
group  of  measures  are  presented.  The  measures  have  been  brought  together  in  the 
following groups: 

1. Scope of vehicles covered by the Periodic Technical Inspection (PTI) Directive

(Section E.1)

Improve current PTI test requirements and procedures (E.5)
Introduce new PTI test requirements and procedures (E.6)

2. Frequency of PTI testing (E.2)
3. Recognition of PTI in another country (E.3)
4. Roadworthiness certificate (E.4)
5.
6.
7. Extend scope of roadside inspections (RSI) (E.7)
8.
9.
10. Access and exchange of information/data (E.10)
11. Vehicle registration measures (E.11)

Introduce new RSI test methods and procedures (E.8)
Introduce new PTI and RSI test methods and procedures (E.9)

Given that there are a lot of measures, we would like to focus the interview on those that 
are  of most  interest  to  you.  Hence,  we  do  not  expect  you to  respond to the  questions  in 
each group. In the following sections, we cover each group of measures separately. Please 
focus on those measures that are most relevant, or interest, to you. 

4 

 Scope of vehicles covered by the PTI Directive 

The  preliminary  measures  in  this  group  relate  to  the  PTI  Directive  only.  The  measures 
considered are: 

PM 1: Introduce mandatory PTI for all motorcycles over 50 cm3 (L3-L7 category) and 
remove the current opt-out for vehicles over 125 cm3 (i.e. including from 50cm3, so 
for all L3e, L4e, plus tricycles (L5e) and heavy quadricycles (L7e)) 

This  would  remove  the  current  opt-out  for  motorcycles,  so  making  PTI  mandatory  for 
motorcycles,  as  well  as  extending  the  need  for  a  mandatory  PTI  to  all  categories  of 
motorcycle.  As  a  result  the  measure  would  require  a  mandatory  PTI  for  the  following 
categories: two-wheel motorcycle (L3e), two-wheel motorcycle with side car (L4e), tricycles 
(L5e) and heavy quadricycles (L7e). 

PM 2: Extend the scope of mandatory PTI to mopeds (i.e. L1e-B and L2e categories) 

This would make a PTI mandatory for mopeds (i.e. categories L1e-B, two-wheel mopeds, 
and L2e, three-wheel mopeds). 

PM 3: Introduce mandatory PTI for all agricultural and forestry tractors (T category), 
i.e. remove opt-out

This would remove the current opt-out for agricultural and forestry tractors (T category), so 
making a PTI mandatory for these vehicles. 

PM 4: Introduce mandatory PTI for light trailers (O1 and O2) 

This will introduce a mandatory PTI for light trailers (categories O1 and O2). 

The aim of all of these measures is to address problem driver 5, i.e. that certain vehicles 
are not (sufficiently) tested for their roadworthiness, and so contribute to the achievement 
of  specific  objective  2,  i.e.  to  significantly  reduce  fraud  and  tampering  (of  safety  and 
emission control systems) and improve the detection of defective vehicles. 

6. Would you like to discuss this group of measures? Yes/No

7.

In your view, to what extent do the identified measures address the stated
problem driver(s) and specific objective(s)?

8. Please elaborate on your views on these measures, particularly if you do not

support their adoption and/or do not think that they will be effective.

5 

9. Do you have any comments on the details of any of these measures, e.g. on:
a. The L-category vehicles (motorcycles and/or mopeds) that should be

covered (under PM 1 and PM 2)?

b. The categories of trailer that should be covered (under PM 4)?

 Frequency of PTI testing 

The  preliminary  measures  in  this  group  relate  to  the  PTI  Directive  only.  The  measures 
considered are: 

PM  5:  Require  more  frequent  emission  testing  (yearly  test  from  the  date  of 
registration) for light duty commercial vehicles (N1 category) 

This  measure  would  increase  the  frequency  of  PTIs  for  light  commercial  vehicles  (N1 
vehicles) to bring this in line with the frequency of testing that applies to larger commercial 
vehicles (i.e. N2 and N3 vehicles) and to taxis and ambulances, but for emission testing only. 

PM 6: Require mandatory yearly testing for vehicles that are 10-year-old and older 

This measure would make an annual PTI mandatory for vehicles once they are 10 years 
old, and for each subsequent year that they are on the road. 

PM 7: Introduce option for a simplified PTI (i.e. no emission/noise testing) if vehicle 
passed recent roadside inspection (including remote sensing) 

This measure would introduce a simplified PTI, i.e. require no emissions or noise testing, if 
the  vehicle  has  successfully  passed  a  recent  roadside  inspection  (including  ones 
undertaken by remote sensing) without any defects. 

PM  8:  PTIs  mandatory  for  crashed  vehicles  with  significant  damage  (affecting  the 
main safety components) 

This  measure  would  introduce  a  requirement  for  a  mandatory  PTI  for  vehicles  that  have 
been damaged significantly as a result of their involvement in a crash, which affected their 
main safety components. 

6 

PM  9:  PTIs  mandatory  following  significant  modifications  (e.g.  change  of  class, 
propulsion system) 

This  measure  would  introduce  a  requirement  for  a  mandatory  PTI  for  vehicles  that  have 
been subject to significant modifications, such as a change of class or propulsion system. 

The  aim  of  these  measures  is  to  address  problem  drivers  3,  i.e.  that  there  are  limited 
technical possibilities to detect vehicles with defects or tampered components, and 5 (that 
certain vehicles are not (sufficiently) tested for their roadworthiness (with the exception of 
PM 7 for problem driver 5). In doing so, they will contribute to the achievement of specific 
objective 2, i.e. to significantly reduce fraud and tampering (of safety and emission control 
systems) and improve the detection of defective vehicles. 

10. Would you like to discuss this group of measures? Yes/No

11. In your view, to what extent do the identified measures address the stated

problem driver(s) and specific objective(s)?

12. Please elaborate on your views on these measures, particularly if you do not

support their adoption and/or do not think that they will be effective.

13. Do you have any comments on the details of any of these measures, e.g. on:

a. How old should an N1 vehicle (light commercial vehicle) be when it

becomes subject to compulsory annual PTI (under PM 5)?

b. Should PM 5 be extended to also cover safety systems?
c. The aspects of a full PTI that should not be undertaken in the event that
the vehicle has recently successfully passed a RSI, including by remote
sensing (PM 7)?

d. What in practice should be considered to be “significant damage” and
how might this be interpreted and/or defined in the legislation? What
should be considered a “main safety component” (PM 8)?

e. What in practice should be considered to be a “significant modification”
and how might this be interpreted and/or defined in the legislation (PM
9)?

7 

 Recognition of PTI in another country  

The  preliminary  measures  in  this  group  relate  to  the  PTI  Directive  only.  The  measures 
considered are: 

PM  10:  Require  that  a  PTI  certificate  issued  in  any  other  EU  Member  State  is 
recognised by Member State of registration (under certain conditions) 

The aim of this measure is to increase the mutual recognition of PTI certificates. It would 
require  such  recognition  under  certain  conditions,  i.e.  provided  that  the  testing  Member 
State  applies at  least  the same (or  equivalent) method for  the relevant test  items  as  the 
Member State of registration. In addition, Member States would be required to publish the 
test methods that they apply to the various vehicle categories. 

PM 11: Require that PTI certificate issued in another EU Member State is recognised 
by  Member  State  of  registration,  on  the  basis  of  a  bilateral  agreement  among  the 
Member States 

The aim of this measure is to increase the mutual recognition of PTI certificates. It would 
require such a recognition, where there was a bilateral agreement between both Member 
States concerned. This is more limited than the previous measure. 

The  aim  of  both  of  these  measures  is  to  address  problem  driver  4,  i.e.  that  vehicle 
identification & status data not sufficiently available  to, and recognised among, enforcing 
authorities, and so contribute to the achievement of specific objective 3, i.e. to improve 
electronic storage and exchange of relevant vehicle identification and status data. 

14. Would you like to discuss this group of measures? Yes/No

15. In your view, to what extent do the identified measures address the stated

problem driver(s) and specific objective(s)?

16. Please elaborate on your views on these measures, particularly if you do not

support their adoption and/or do not think that they will be effective.

8 

17. Do you have any comments on the details of any of these measures?

 Roadworthiness certificate  

The  preliminary  measure  in  this  group  relates  to  the  PTI  Directive  only.  The  measure 
considered is: 

PM 12: Require roadworthiness certificate to be issued in electronic format 

This measure would require roadworthiness certificates to be stored in the vehicle register 
and be made available in an electronic format. 

The aim  is  to  address  problem  driver  4,  i.e.  that  vehicle  identification &  status data not 
sufficiently available to, and recognised among, enforcing authorities, and so contribute to 
the achievement of specific objective 3, i.e. to improve electronic storage and exchange 
of relevant vehicle identification and status data. 

18. Would you like to discuss this measure? Yes/No

19. In your view, to what extent does the identified measure address the stated

problem driver(s) and specific objective(s)?

20. Please elaborate on your views on this measure, particularly if you do not

support its adoption and/or do not think that it will be effective, or you have
views on who should have access to the stored certificates.

9 

21. Do you have any comments on the detail of this measure, e.g. on:

a. Whether the paper version of the roadworthiness certificate should still
be made available, if the roadworthiness certificate had to be made
available electronically (PM 12)?

b. Who should have access to the stored certificates (PM 12)?

 Improve current PTI test requirements and procedures 

The  preliminary  measures  in  this  group  relate  to  the  PTI  Directive  only.  The  measures 
considered are: 

PM 13: Require that PTI includes more advanced testing of noise for motorcycles 

This measure would introduce the more advanced testing of noise for motorcycles into PTIs. 

PM  14:  Require  that  PTI  includes  advanced  testing  of  lighting  to  cover  advanced 
headlamps 

This measure would introduce the more advanced testing of lighting in PTIs, in order to take 
account of the more advanced lighting that is now being added to vehicles. 

PM 15: Require more advanced testing of braking for HDVs (extrapolation methods) 

This measure would introduce the more advanced testing of braking for HDVs, in relation 
to the application of extrapolation methods. 

PM 16: Require training of inspectors for PTI in relation to electric vehicles 

This  measure would  introduce  the  additional training  of  inspectors for  PTI to ensure  that 
they are able to undertake the appropriate inspections of electric vehicles. 

The aim of all of these measures is to address problem driver 3, i.e. that there are limited 
technical possibilities to detect vehicles with defects or tampered components. 

For PM 14 and PM 16, this will contribute to the achievement of specific objective 1 (adapt 
testing to today’s and tomorrow’s vehicles (improve consistency, objectivity and quality). 

10 

For PM 13, PM 14 and PM 15, this will contribute to the achievement of specific objective 
2, i.e. to significantly reduce fraud and tampering (of safety and emission control systems) 
and improve the detection of defective vehicles. 

22. Would you like to discuss this group of measures? Yes/No

23. In your view, to what extent do the identified measures address the stated

problem driver(s) and specific objective(s)?

24. Please elaborate on your views on these measures, particularly if you do not

support their adoption and/or do not think that they will be effective.

25. Do you have any comments on the details of any of these measures, e.g. on:

a. Alternative standards that might be used in PM 18?

 Introduce new PTI test requirements and procedures  

The  preliminary  measures  in  this  group  relate  to  the  PTI  Directive  only.  The  measures 
considered are: 

PM 17: Adapt PTI to cover the particularities of electric and hybrid vehicles (e.g. 
high-voltage systems) 

This measure would introduce provisions to amend the PTI to ensure that the safety and 
environmental performance of electric and hybrid vehicles is assured, including with respect 
to their high voltage systems. 

11 

PM 18: Update PTI with new test items to cover safety systems introduced as part of 
the General Safety Regulation using ePTI (on the basis of standard ISO 20730:2021) 

This measure introduces provisions to amend the PTI to ensure that this covers the safety 
systems that were introduced as part of the General Safety Regulation using ePTI (on the 
basis of standard ISO 20730:2021). 

For PM 17 and PM 18, the aim is to address problem driver 1 (PTI-methods not available 
to test electric vehicles, electronic safety & driver assistance systems), and so contribute to 
the  achievement  of  specific  objective  1,  i.e.  to  adapt  testing  to  today’s  and  tomorrow’s 
vehicles (improve consistency, objectivity and quality). 

PM 19: Require mandatory testing of particle numbers (PN) at PTI for LDVs and HDVs 
based  on  Commission  Recommendation  (EU)  2023/688  containing  guidelines  for 
particle number concentration testing during PTI 

This measure would require mandatory PN testing in PTIs for both LDVs and HDVs. 

PM 21: Require NOx testing of LDVs and HDVs at PTI on the basis of testing methods 
developed by the JRC 

This measure would require NOx testing in PTIs for both LDVs and HDVs. 

For PM 19 and PM 21, the aim is to address problem driver 2, i.e. that current PTI & RSI 
methods  not  suited  to  test  certain  functions  of  modern  vehicles  (including  emissions 
performance),  and  so  contribute  to  the  achievement  of  specific  objectives  1  (to  adapt 
testing  to  today’s  and  tomorrow’s  vehicles  (improve  consistency,  objectivity  and  quality), 
and  2,  i.e.  to  significantly  reduce  fraud  and  tampering  (of  safety  and  emission  control 
systems) and improve the detection of defective vehicles. 

26. Would you like to discuss this group of measures? Yes/No

27. In your view, to what extent do the identified measures address the stated

problem driver(s) and specific objective(s)?

28. Please elaborate on your views on these measures, particularly if you do not

support their adoption and/or do not think that they will be effective.

12 

29. Do you have any comments on the details of any of these measures, e.g. on:

a. What the update to the PTI in relation to electric and hybrid vehicles

should include (PM 17)?

b. What the update to the PTI to cover the new test items introduced as part

of the General Safety Regulation should include (PM 18)?

 Extend scope of roadside inspections (RSI)  

The  preliminary  measures  in  this  group  relate  to  the  RSI  Directive  only.  The  measures 
considered are: 

PM 25: Introduce mandatory standards in relation to cargo securing inspections 

This  measure  would  make  the  use  of  existing  standards  for  roadside  cargo  securing 
inspections mandatory (it is currently optional). 

The aim is to address problem driver 5 (that certain vehicles are not (sufficiently) tested 
for their roadworthiness, in order to contribute to the achievement of specific objective 1, 
i.e. to adapt testing to today’s and tomorrow’s vehicles (improve consistency, objectivity and
quality).

PM 26: Extend the scope of application of roadside inspections to N1 vehicles (light 
commercial vehicles)  

This measure would extend the scope of roadside inspections to cover N1 vehicles. 

The aim is to address problem driver 2, i.e. that certain vehicles are not (sufficiently) tested 
for their roadworthiness, in order to contribute to the achievement of specific objective 2, 
i.e. to significantly reduce fraud and tampering (of safety and emission control systems) and
improve the detection of defective vehicles.

PM 27: Extend the scope of application of roadside inspections to powered 2- and 3-
wheeled (L-category) vehicles  

This measure would extend the scope of roadside inspections to cover L-category vehicles. 

13 

The aim is to address problem driver 5 (that certain vehicles are not (sufficiently) tested 
for their roadworthiness, in order to contribute to the achievement of specific objectives 1, 
i.e. to adapt testing to today’s and tomorrow’s vehicles (improve consistency, objectivity and
quality), and 2, i.e. to prevent fraud and tampering (of safety and emission control systems,
and improve the detection of defective vehicles.

30. Would you like to discuss this group of measures? Yes/No

31. In your view, to what extent do the identified measures address the stated

problem driver(s) and specific objective(s)?

32. Please elaborate on your views on these measures, particularly if you do not

support their adoption and/or do not think that they will be effective.

33. Do you have any comments on the details of any of these measures (e.g. other

categories of vehicle to which the scope of RSI might be extended)?

 Introduce new RSI test methods and procedures  

The  preliminary  measures  in  this  group  relate  to  the  RSI  Directive  only.  The  measures 
considered are: 

PM 20: Require mandatory PN measurement for N1 vehicles and HDVs, as from Euro 
5/V-diesel, in the technical roadside inspections of commercial vehicles 

This  measure  would  require  the  mandatory  PN  measurement  for  diesel  N1  vehicles  and 
HDVs, from Euro 5/V onwards, in roadside inspections. 

14 

PM 22: Extend the scope of the RSI Directive to require the conduct of NOx and noise 
measurements  by  remote  sensing  for  all  vehicles  (including  also  M1,  N1  and  L-
category) 

This measure would extend the scope of the RSI Directive to require the conducting of NOx 
and noise measurements by remote sensing of M1, N1 and L category vehicles.  

PM  23:  Introduce  the  potential  use  of  plume  chasing  in  technical  roadside 
inspections of commercial vehicles (optional) 

This measure would introduce the option of using plume chasing (i.e. use of a chase car 
driving  behind  a  heavy-duty  vehicle  to  measure  and  calculate  the  content  of  NOx  in  the 
exhaust gas) in the technical roadside testing of commercial vehicles. 

The aim of all of these measures is to address problem driver 2, i.e. that current PTI & RSI 
methods  not  suited  to  test  certain  functions  of  modern  vehicles  (including  emissions 
performance),  and  so  contribute  to  the  achievement  of  specific  objectives  1  (to  adapt 
testing  to  today’s  and  tomorrow’s  vehicles  (improve  consistency,  objectivity  and  quality), 
and  2,  i.e.  to  significantly  reduce  fraud  and  tampering  (of  safety  and  emission  control 
systems) and improve the detection of defective vehicles. 

34. Would you like to discuss this group of measures? Yes/No       

35. In your view, to what extent do the identified measures address the stated 

problem driver(s) and specific objective(s)?       

36. Please elaborate on your views on these measures, particularly if you do not 
support their adoption and/or do not think that they will be effective.       

37. Do you have any comments on the details of any of these measures? 

15 

 
                                                                   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Introduce new PTI and RSI test methods and procedures  

The preliminary measure in this group relates to BOTH the PTI and RSI Directives. The 
measure considered is: 

PM  24:  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 

This measure would require the testing of the software status and integrity of safety and 
emission  relevant  systems  in  both the  PTI  (for  all  vehicles)  and  the  RSI  (for  commercial 
vehicles).  

The  aim  is  to  address  problem  drivers  1,  i.e.  PTI  methods not  available  to  test  electric 
vehicles,  electronic  safety  &  driver  assistance  systems,  and  2  (that  current  PTI  &  RSI 
methods  not  suited  to  test  certain  functions  of  modern  vehicles  (including  emissions 
performance)),  and  so  contribute  to  the  achievement  of  specific  objectives  1  (to  adapt 
testing  to  today’s  and  tomorrow’s  vehicles  (improve  consistency,  objectivity  and  quality), 
and  2,  i.e.  to  significantly  reduce  fraud  and  tampering  (of  safety  and  emission  control 
systems) and improve the detection of defective vehicles. 

38. Would you like to discuss this group of measures? Yes/No       

39. In your view, to what extent do the identified measures address the stated 

problem driver(s) and specific objective(s)?       

40. Please elaborate on your views on these measures, particularly if you do not 
support their adoption and/or do not think that they will be effective.       

16 

 
                                                                   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
41. Do you have any comments on the detail of this measure? 

 Access and exchange of information/data   

The preliminary measures in this group relate to BOTH the PTI and RSI Directives. The 
measures considered are: 

PM 28: Provide for the enabling and use of independent remote access to in-vehicle 
data in the technical roadside inspections of commercial vehicles 

This measure would enable and allow the use of independent remote access to in-vehicle 
data  in  the  technical  roadside  inspections  of  commercial  vehicles,  so  as  to  enable  the 
checking of vehicles ‘over-the-air’.  

PM 29: Data governance: further define the procedures and the means of access to 
vehicle technical information by testing centres free of charge and in standardised 
format (cf. Commission Implementing Regulation (EU) 2019/621) 

This measure would facilitate access to technical information for testing centres by requiring 
that  it  is  made  available  free  of  charge,  without  undue  administrative  burden  and  in  a 
standardised format. 

PM  30:  Require  the  electronic  storage  of  roadside  inspection  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 (peer-to-peer or via a central 
hub) 

This  measure  would  require  that  roadside  inspection  reports  are  stored  electronically  in 
national databases. In addition, it would require the access and exchange of data relevant 
to roadside inspections to RSI authorities in other EU Member States through a common 
(yet to be decided) system. 

The  aim  of  all  of  these  measures  is  to  address  problem  driver  4,  i.e.  that  vehicle 
identification & status data not sufficiently available  to, and recognised among, enforcing 
authorities. 

For PM 28, this will contribute to the achievement of  specific objectives 1, i.e. to adapt 
testing  to  today’s  and  tomorrow’s  vehicles  (improve  consistency,  objectivity  and  quality), 
and  2,  i.e.  to  significantly  reduce  fraud  and  tampering  (of  safety  and  emission  control 
systems) and improve the detection of defective vehicles. 

17 

 
                                                                   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
For PM 29, this will contribute to the achievement of  specific objectives 1, i.e. to adapt 
testing to today’s and tomorrow’s vehicles (improve consistency, objectivity and quality, and 
3,  i.e.  to  improve  electronic  storage  and  exchange  of  relevant  vehicle  identification  and 
status data 

For PM 30, this will contribute to the achievement of specific objective 3, i.e. to improve 
electronic storage and exchange of relevant vehicle identification and status data. 

42. Would you like to discuss this group of measures? Yes/No       

43. In your view, to what extent do the identified measures address the stated 

problem driver(s) and specific objective(s)?       

44. Please elaborate on your views on these measures, particularly if you do not 
support their adoption and/or do not think that they will be effective.       

45. Do you have any comments on the details of this measure, e.g. on: 

a.  The most appropriate way to provide electronic access to relevant data 

to registration authorities in other EU Member States (PM 30)? 

 Vehicle registration measures   

The preliminary measures in this group only relate to the Vehicle Registration Documents 
Directive. The measures considered are: 

18 

 
                                                                   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
PM  31:  Provide  electronic  access to relevant data to the  registration  authorities  of 
other EU Member States through the use of a common IT system (peer-to-peer or via 
a central hub) 

This measure would provide electronic access to relevant data to registration authorities of 
other Member States through the use of a common (yet to be defined) interface. 

PM 32: Add a minimum set of new data to the vehicle register, including: 

country of 1st registration
registration status (de-registered, suspended, end-of-life)

-
-
- PTI status (validity, minor/major defects)

This measure would define a minimum set of new data that should be included in the vehicle 
register,  which  would  include  the  vehicle’s  country  of  1st  registration,  as  well  as  its 
registration and PTI status. 

PM  33: Increase  the  harmonisation  of the technical  data in the  vehicle  registration 
documents on the basis of a common standard 

This  measure  aims  to  increase  the  harmonisation  of  the  technical  data  in  the  vehicle 
registration  documents  (either  paper  or  digital),  specifically  the  content  that  is  currently 
optional as specified in Annexes I and II of the Directive, on the basis of a common standard. 
This would include increasing the items for which harmonisation would be mandatory, as 
well as potentially adding more items to the Annexes. 

PM  34:  Introduce  the  requirement  that  any  vehicle  transformation,  including  any 
important  vehicle  refurbishment  or  conversion  (e.g.  emission  values)  has  to  be 
approved and registered 

This measure would require that any transformations to a vehicle, including refurbishments 
and conversion (e.g. those that lead to different emissions), would need to be approved and 
registered. 

PM 35: Require issuing of the registration certificates (Annex I) in digital format 

This measure would require the issuing of registration certificates in a digital format. 

PM 36: Require that Member States update vehicle registration data on a regular basis 
(period to be defined) 

This  measure  would  require  that  Member  States  update  vehicle  registration  data  on  a 
regular basis, which is yet to be defined. 

The  aim  of  all  of  these  measures  is  to  address  problem  driver  4,  i.e.  that  vehicle 
identification & status data not sufficiently available  to, and recognised among, enforcing 
authorities, and so contribute to the achievement of specific objective 3, i.e. to improve 
electronic storage and exchange of relevant vehicle identification and status data. 

19 

In  addition,  PM  34  also  contributes  to  the  achievement  of  specific  objective  2  (to 
significantly  reduce  fraud  and  tampering  (of  safety  and  emission  control  systems)  and 
improve the detection of defective vehicles). 

46. Would you like to discuss this group of measures? Yes/No

47. In your view, to what extent do the identified measures address the stated

problem driver(s) and specific objective(s)?

48. Please elaborate on your views on these measures, particularly if you do not

support their adoption and/or do not think that they will be effective.

49. Do you have any comments on the details of this measure, e.g. on:

a. The most appropriate way to provide electronic access to relevant data

to registration authorities of other EU Member States (PM 31)?
b. Additional information (such as odometer readings, changes in

documentation or transformation of vehicle, major accidents/incidents)
that could be included amongst the minimum set of new data to be
included in the vehicle register (PM 32)?

c. When odometer readings should be recorded (PM 32)?
d. Whether the dataset in the Annexes should be considered as the

minimum dataset (PM 33)?

e. Whether one organisation should be appointed in the legislation for
maintaining the dataset after the revision (and if so, which) (PM 33)?
f. Whether the issuing of registration certificates (Annex I) in a digital

format should be mandatory, or optional (PM 35)?

g. The format of the digital registration certificates (PM 35)?
h. The frequency with which Member States should be required to update

vehicle registration data (PM 36)?

20 

F. Closing questions and comments

50. In your view, what, if any, impact would the measures presented above (if
implemented) have on the following aspects/parameters (please highlight
specific measures in your response)?
a. Operation  of  the  EU  Internal  market  (i.e.  in  terms  of  ensuring  fair  competition,

avoiding fraud, eliminating cross-border trade obstacles)

b. Cost and price competitiveness of the sectors and businesses affected (i.e. related

c.

d.

to impacts on costs of operation, cost of capital, profit margins)
Innovative  capacity  of  the  sectors  and  businesses  affected  (i.e.  impact  on  the
capacity of businesses and incentives to bring to the market new goods/services)
International competitiveness of the sectors and businesses affected (i.e. specific
costs/benefits  for  EU  businesses  that  are  not  applicable  to  their  non-EU
competitors)

e. SME  competitiveness  (i.e.  lead  to  costs  or  benefits  that  affect  micro,  small  and

medium sized business at a disproportionate level)

f. State of the environment (such as air quality, biodiversity, ecosystem health, etc)
g. Level of noise from road transport
h. Public health
i. Employment / jobs in the affected sectors and businesses
j. Fundamental rights (including in relation privacy and protection of data)

51. Do you have any suggestions as to where we might find information on the

potential costs and/or saving of the measures presented above, if any of these
measures were implemented?

52. In your view, are there likely to be any challenges for SMEs, if any of these

measures were implemented?

21 

53. Do you have any closing remarks on the potential revision of the

Roadworthiness package?

Thank you for your contributions! For any further comments or questions, contact us 
at the following email address: RWP_IA@ricardo.com  

22 

IMPACT ASSESSMENT SUPPORT STUDY ON THE 
DIRECTIVES OF THE ROADWORTHINESS PACKAGE 

Annex 4 of the Stakeholder Consultation Report – Analytical 
summary of the IIA 

Contract no. MOVE/C2/SER/2022-583/SI2.895928, under FWC 
no. MOVE/2022/OP/0001 

Written by: Ian Skinner [TEPR] 
September 2023 

IA support study on the Directives of the RWP 

Analytical summary of the IIA 

EUROPEAN COMMISSION 
Directorate-General for Mobility and Transport 
Directorate C — Land 
Unit C.2 — Road safety 

Contact: Peter SZATMARI 

E-mail: Peter.SZATMARI@ec.europa.eu

European Commission 
B-1049 Brussels

Directorate-General for Mobility and Transport 
IA for revision of the RWP 

 IMPACT ASSESSMENT SUPPORT STUDY ON DIRECTIVES OF THE ROADWORTHINESS 
PACKAGE  

Analytical summary of the input to the IIA 

The Inception Impact Assessment (IIA) on the revision of the EU’s Roadworthiness package 
(RWP)  was  open  for  comment  on  the  Commission’s  ‘Have  Your  Say’  website  between  4 
October and 1 November 2021. This Annex analyses the responses that were received. 

i.

Summary of profiles

Overall,  217  responses  to  the  IIA  were  received,  although  seven  of  these  were  repeat 
responses. Hence, there were 210 unique, individual responses. The vast majority (81%) of 
these  were  from  EU  citizens,  whereas  the  highest  proportion  of  responses  from  other 
stakeholder categories was only 4% (for business associations and ‘Other’ stakeholders; see 
the second and third columns of Table 1). 

However, there was clearly a campaign from citizens, as many of their responses underlined 
their opposition to PTIs for motorcycles. These responses were from France, and/or in French, 
and  included  the  majority  of  responses  from  citizens  (all  but  three  citizen  responses  were 
submitted in French), as well as a small number of responses from respondents that labelled 
themselves  as  either  a  business  association,  a  consumer  organisation  or  ‘Other’.  These 
responses have been removed from the second set of numbers in Table 1 (i.e. the fourth and 
fifth columns of the table). This left only 36 responses that were analysed individually, nearly 
three quarters of which came from either business associations (eight, 22%), companies or 
business organisations, NGOs or ‘Other’ stakeholders (six, 17%, each). In the text that follows, 
the analysis focuses on these 36 responses, with reference to the views of the campaign in 
relation to the single measure on which they expressed a view. 

Table 1: Responses to the IIA by stakeholder category 

Category 

Total number of responses 

Non-campaign responses 

Number of 
respondents 

Percentage of 
total number of 
respondents 

Number of 
respondents 

Percentage of 
total number of 
respondents 

Academic / research 
institution 

Business association 

Company/business 
organisation 

Consumer organisation 

EU citizen 

Non-EU citizen 

NGO (Non-governmental 
organisation) 

Public authority 

Other 

Total 

1 

9 

6 

3 

171 

3 

6 

2 

9 

0% 

4% 

3% 

1% 

81% 

1% 

3% 

1% 

4% 

1 

8 

6 

2 

3 

2 

6 

2 

6 

3% 

22% 

17% 

6% 

8% 

6% 

17% 

6% 

17% 

210 

100% 

36 

100% 

The extent of the campaign from French respondents is clear in Table 2, as 86% of individual 
responses were from France, whereas the proportion of responses from France dropped to 
19% excluding the campaign. Half of the remaining 36 responses came from three Member 
States,  i.e.  Belgium  (eight,  22%),  Germany  (six,  17%)  and  Austria  (four,  11%),  with  the 

Directorate-General for Mobility and Transport 
IA for revision of the RWP 

 IMPACT ASSESSMENT SUPPORT STUDY ON DIRECTIVES OF THE ROADWORTHINESS 
PACKAGE  

remaining  responses  coming  from  another  seven  Member  States  and  two  other  countries 
(China and Iran). 

Table 2: Geographical distribution of the IIA’s respondents 

Category 

Total number of responses 

Non-campaign responses 

Number of 
respondents 

Percentage of 
total number of 
respondents 

Number of 
respondents 

Percentage of 
total number of 
respondents 

France 

Belgium 

Germany 

Austria 

Portugal 

Spain 

Finland 

Ireland 

Poland 

Slovakia 

Sweden 

China 

Iran 

Total 

181 

86% 

8 

6 

4 

2 

2 

1 

1 

1 

1 

1 

1 

1 

4% 

3% 

2% 

1% 

1% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

7 

8 

6 

4 

2 

2 

1 

1 

1 

1 

1 

1 

1 

19% 

22% 

17% 

11% 

6% 

6% 

3% 

3% 

3% 

3% 

3% 

3% 

3% 

210 

100% 

36 

100% 

ii.

Introduction

The IIA covered both the evaluation and the impact assessment of the RWP and was divided 
into four sections. Section A, Context, Evaluation, Problem definition and subsidiarity check, 
introduced the  IIA,  including  providing  the  wider  context,  namely  the  EU’s  Sustainable and 
Smart Mobility Strategy and its contribution to the delivery of the Strategic Action Plan on Road 
Safety.  Two  problems  that  the  revision  of  the  RWP  could  address  were  also  mentioned, 
specifically, the introduction of: 

(a) advanced  vehicle  safety  features  (mandated  by  the  General  Safety  Regulation

from 2022 onwards); and

(b) significantly strengthened emission legislation, led vehicles in the EU to become

technically ever more complex.

Section B (Objectives and Policy options) began by specifying the general objectives (GOs) 
that the initiative aimed to address, followed by the associated specific objectives (SOs), i.e.: 

GO1: to improve road safety; 
GO2: to contribute to more sustainable and smarter mobility; and  
GO3: to facilitate and simplify the free movement of people and goods in the Union. 

SO1:  to  ensure  the  functioning  of  modern  electronic  safety  components,  advanced 
driver assistance systems and automated functions during the vehicles’ lifetime; 
SO2: to perform meaningful emission tests during vehicle inspections; and 

Directorate-General for Mobility and Transport 
IA for revision of the RWP 

 IMPACT ASSESSMENT SUPPORT STUDY ON DIRECTIVES OF THE ROADWORTHINESS 
PACKAGE  

SO3:  to  improve  the  electronic  storage,  read-out  and  exchange  of  roadworthiness-
relevant vehicle identification and status data between EU Member States as well as 
performance data, building amongst others also on the digitalisation of administrative 
documents and certificates.   

Section B of the IIA also set out some measures that were being considered in the context of 
the potential revision of each of the three Directives of the RWP, while Section C set out the 
Commission’s Preliminary Assessment of Expected Impacts. Section D (Evidence base, Data 
collection  and  Better  Regulation  instruments)  informed  respondents  of  the  Commission’s 
planned  evaluation  and  impact  assessment  for  the  revision  of  the  RWP  and  set  out  the 
Commission’s consultation strategy for this.  

The initial plan for the analysis of the responses to the IIA was to use the structure of the IIA 
for this. However, after a high-level review of the responses, it was clear that stakeholders 
typically focused their responses to the IIA on issues, or measures, that they would like to see 
addressed,  or  included,  in  the  revision  of  the  respective  Directives.  Hence,  the  following 
sections are structured in this way. They begin with some general comments, before focusing 
on  stakeholders’  views  on  changes  that  they  consider  were  needed  to  the  respective 
Directives. There were more comments on the PTI Directive than the other two, so the analysis 
of  the  responses  relating  to  this  Directive  has  been  grouped  by  subject  area  and  potential 
measure. 

iii.

General comments

CITA, the international motor vehicle inspection committee, submitted a position paper on the 
revision of the Directive. This included a call for the coordination between type approval and 
the  roadworthiness  package  to  be  considered  and  underlined  the  increased  importance  of 
data in ensuring roadworthiness, given the increased use of sensors and IT technologies in 
vehicles. They also noted the importance of adjusting and developing inspection methods to 
take account of new vehicle technologies and to facilitate the testing of these in the course of 
PTI. CITA also called for the revision of the RWP to increase the harmonisation of the minimum 
requirements  for  PTI,  to  ensure  that  vehicle  inspectors  are  sufficiently  trained  to  inspect 
increasingly complex vehicle systems and for measures to be taken to ensure the impartiality 
of  inspectors  (and  their  organisations)  from  the  vehicle  manufacturing,  trade,  leasing  and 
repair sectors. Dekra, an inspection company, also highlighted the importance of maintaining 
the impartiality of inspection organisations and inspectors from these other sectors. 

In addition to more specific responses mentioned below, a number of respondents underlined 
that they supported CITA’s position paper, which is covered above and below, including the 
Fahrzeugsystemdaten  GmbH  (FSD;  the  German  Central  Agency  for  PTI),  the  GTÜ, 
representing  German  self-employed vehicle inspectors,  and  Dekra.  In  addition,  GTÜ,  while 
welcoming the minimum standards for PTI that are set in the legislation, underlined that these 
should not undermine the independence of inspectors, so the principal of  the separation of 
inspections  and  repairs  should  be  maintained.  GTÜ  also  underlined  the  importance  of 
ensuring that inspectors continue to be trained to a high level, so that they were able to inspect 
new safety technologies, electric drive systems and cybersecurity. Dekra underlined that, in 
its view, the IIA highlighted the important elements of the RWP that needed to be addressed. 

Two  Austrian  business  associations,  the  Association  of  Independent  Automotive  Parts 
Dealers  (Verband  der  freien  Kfz-Teile-Fachhändler;  VFT)  and  the  Federal  Guild  of 
Automotive Technology (Bundesinnung der Fahrzeugtechnik; BdF) both underlined that the 
system works well in Austria, whereby provincial authorities authorise assessment bodies, so 
should be allowed to continue. They also both called for more consideration to be given to the 
links between type approval and the RWP, that testing should continue to be simple, fast and 

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cost-effective and that consideration should be given to shortening the periods between tests 
by  making  use  of  new  electronic  systems.  The  German  Motor  Vehicle  Industry  Central 
Association (Deutsches Kraftfahrzeuggewerbe Zentralverband; DKZ) made similar points in 
relation  to  the  importance  of  being  able  to  maintain  well-functioning  PTI  systems  that  are 
present  in some countries,  while  improving  less  effective  testing  systems.  They also made 
similar  points  to  other  inspection  bodies,  i.e.  that  more  consideration  be  given  to  the  link 
between  type  approval  and  the  RWP  and  that  testing  should  remain  simple,  quick  and 
inexpensive. GOCA Vlaanderen, the Flemish association of PTI enterprises in Belgium, also 
underlined the importance of strengthening the system to ensure the impartiality of inspectors 
and to eliminate potential conflicts of interest.  

Ireland’s  Road Safety Authority (RSA)  called for  actions  to  be  taken  in the  review  of  the 
RWP to improve the consistency of roadworthiness standards and practices across the EU, 
which should involve greater use of electronic testing to complement visual inspections. They 
also  called  for  further  measures  to  ensure  the  independence  of  vehicle  inspections  by 
separating PTI inspections from repair facilities, as well as enhanced oversight and reporting 
systems to the relevant authorities. The Nordic Logistics Association also highlighted the 
importance of having a consistent and coherent approach to PTI across the EU, as this was 
important to ensure that vehicle safety remained high across the EU.   

Consumer group, the Fédération Internationale de l’Automobile (FIA) made some general 
points,  i.e.  that  the  RWP  must  fit  the  needs  of  Member  States  to  maintain  their  testing 
frameworks,  that  better  coordination  between  type  approval  and  the  RWP  should  be 
considered, and that testing should continue to be “relatively simple, quick and inexpensive”, 
while  still  meeting  the  objectives  of  the  Directive.  The  response  of  the  Austrian  driver’s 
organisation Österreichischer Automobil-, Motorrad- und Touring Club (ÖAMTC) made 
similar points.  

A response from an automotive car manufacturer suggested that there was a need to define 
the  notion  of  "Type  of  Vehicle",  perhaps  along  the  lines  of  the  UN-R155  on  Cybersecurity 
definition, i.e.: Vehicle type "means vehicles which do not differ in at least the essential aspects 
of the electric / electronic architecture and external interfaces with respect to ePTI or the test 
for  safety-relevant  electronic  components  of  ADAS".  Another  respondent  from  Austria 
argued that the system in that country worked well and should be maintained, while also noting 
that testing needed to take account of new propulsion systems and ensure that access to data 
should be free of charge and easily accessible to all. 

iv.

Scope of the PTI Directive

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) argued that the absence of the requirement to undertake a PTI for L-category vehicles 
in the four EU countries that did not require such a test could not be justified and referred to 
CITA’s report that recommended that these vehicles be subject to a PTI. 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) 

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also  underlined  the  importance  of  extending  roadworthiness  testing  to  all  road  transport 
vehicles.  

Various motorcycle users’ groups submitted contributions that argued against the mandatory 
extension of the scope of the PTI to motorcycles, in line with the responses from the campaign. 
The  Federation  of  European  Motorcyclists’  Associations  (FEMA)  argued  that  the 
evidence was that the technical state of motorcycles only played a marginal role in accidents 
involving motorcycles. FEMA criticised the study undertaken by CITA et al that concluded that 
there was a beneficial cost-benefit ratio of extending PTI to motorcycles, arguing that it was 
based  on  a  narrow  set of  data  (from  Spain),  as  well  as  not  being  clear about the  research 
methods and assumptions used. Suomen Motoristit ry (SMOTO), representing the interests 
of Finnish motorcyclists, made similar points. SMOTO and their Swedish equivalent, Sveriges 
MotorCyklister,  SMC,  also  presented  data  comparing  Nordic  countries  that  they  argued 
demonstrated that the risk of being killed on a motorcycle in Sweden, where they have PTIs 
for motorcycles, was greater than in other Nordic countries that did not require a PTI. They 
also presented data that suggested that technical failures in motorcycles play much less of a 
role  in  accidents  than  technical  failures  in  other  vehicles.  The  French  motorcyclists’  group, 
Fédération  Française  des  Motards  en  Colère,  also  argued  against  extending  PTI  to 
motorcycles,  as  a  PTI  was  not  necessary  to  ensure  the  safety  of  motorcycles,  as  users 
maintained their bikes well, and accidents were more likely to be the result of human error 
than mechanical failures. This was also a common argument used amongst the citizens who 
responded as part of the campaign. 

v.

Frequency of the PTI Directive

As some cars and light commercial were increasingly being used for shared mobility and public 
transport, CITA called for an increased frequency of PTI for some vehicles. For example, they 
supported annual PTIs for vehicles used for shared mobility and public transport, as a result 
of their high annual mileage, as well as for 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. Similarly, as a result of the increased use of a range of vehicles for the purpose 
of shared mobility, 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.  

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.     

vi.

Access to information in the context of undertaking PTIs

As technical inspections are undertaken for the authorities of the Member States, CITA called 
for all those undertaking inspections to have access to vehicle-specific original data in a non-

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discriminatory, free and independent manner. They also underlined the importance of relevant 
stakeholders being able to verify that the right version of approved software was being used 
by the vehicle.  

Germany’s Central Agency for PTI, the FSD, also underlined the importance of access to 
in-vehicle data and diagnostic information in an independent and reliable way, specifically the 
information  made  available  in  the  context  of  EU  type  approval  legislation,  along  with 
unrestricted access to the vehicle data and software, covering the whole lifetime of the vehicle. 
Similarly,  the  Spanish  AECA-ITV  underlined  the  importance  of  PTI  inspection  providers 
having  access  to  the  original  vehicle  data,  including  up-to-date  software,  in  a  non-
discriminatory, free and independent manner, so that vehicles could be appropriately tested. 
In addition, they proposed that a European electronic vehicle information platform be set up, 
to contain specific and standardised vehicle roadworthiness data, along with the establishment 
of  appropriate  formats,  so  that  all  roadworthiness  documentation  could  be  available 
electronically, including the PTI certificates of all Member States. 

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. They noted that 
the implementation of a free electronic platform that contained relevant vehicle information, 
e.g. on a vehicle’s type approval, its registration and roadworthiness testing, would be useful.

Two Austrian  business associations,  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.   

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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. 

vii.

Ensuring the environmental performance of vehicles in PTIs

In  relation  to  ensuring  the  environmental  performance  of  vehicles,  CITA  called  for  the 
inclusion of PN counting in both PTI and RSI, for the development of appropriate methods to 
include NOx testing as part of the inspection and to detect tampering, and to ensure that the 
RWP  is  coordinated  with  the  development  of  the  relevant  aspects  of  the  proposed  Euro  7 
standards. The two Austrian business associations, VFT and BdF, and the German DKZ also 
called for PN counting to replace opacity testing, as well as for NOx tests to be based on OBD 
data and to use the functionality of OBDs to detect emissions-related defects and tampering.  

GOCA Vlaanderen noted the innovations in relation to PN counting and measuring NOx and 
underlined that the Directive should help to ensure that such innovative methods were able to 
be introduced more widely and more quickly. The Portuguese ANCIA called for the definition 
of  new  test  methods  to  ensure  that  emissions  of  NOx  and  particulates  met  the  necessary 
standards. Inspection company Applus underlined that PTI was the effective way of assessing 
whether the emissions reductions systems for NOx and PN had been properly maintained or 
had been tampered with. A French inspection company also supported the introduction of 
NOx measurements.  

The  EGEA  underlined  the  importance  of  testing  the  emissions  of  vehicles,  and  for  direct 
access  to  in-vehicle  data to  facilitate  this.  Whilst  noting  the  importance  of  the  OBD,  EGEA 
argued that OBDs were not able to detect all defects, so should be used in combination with 
other methods; they also suggested that there was no easy, short-term solution to measuring 
NOx  emissions.  The  EGEA’s  submission  included  more  detailed  recommendations  and 
requirements for the testing of various components, including air conditioning.  

The Association for Emissions Control by Catalyst (AECC) underlined the importance of 
“meaningful” emissions tests to measure NOx and PN emissions to be undertaken in PTIs, in 
particular to identify non-compliance related to poor vehicle maintenance or tampering. They 
noted  that  on-board  monitoring,  remote  sensing  and  vehicle  system  durability  testing  were 
also needed to ensure that a vehicle’s emissions remained low throughout its lifetime. 

The  FIA  also  called for the  replacement  of  the  current  opacity  test  with PN  counting  for  all 
vehicles, and also noted a presentation that had been made to the Roadworthiness Committee 
in September 2020 on testing NOx emissions using the functionality of a vehicle’s OBD. The 
ÖAMTC’s response made similar points, and they also provided a presentation that set out a 
methodology for assessing NOx emissions in a PTI, using data from a vehicle’s OBD.   

viii. Ensuring the safety and functionality of vehicles in PTIs

In its position paper, CITA made a number of points relating to the testing of the safety and 
functionality of vehicles. In the context of the advanced driver assistance systems (ADAS) that 
will be required by the implementation of the General Safety Regulation (GSR), they called for 
the mandatory  inspection of  the  functionality  and  effectiveness  of  ADAS  in PTIs,  based  on 
agreed test procedures, to complement the vehicle’s own self-diagnosis systems. Such testing 
procedures will need to be complemented by necessary changes to type approval legislation 
to facilitate these. They also called for a comprehensive roadworthiness framework that could 

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evaluate  the  safety  performance  of  highly  automated  vehicles,  arguing  that  self-diagnosis 
would  not  be  sufficient  for  these  vehicles,  either.  To  support  this,  they  called  for  vehicles’ 
software to be identified at type approval through a standardised and harmonised procedure. 
Whilst acknowledging that it was outside of the scope of the PTI Directive, CITA underlined 
the importance of data security and data protection being tested by an independent third party. 

Germany’s FSD called for the inspection of a vehicle’s automated driving functions in PTIs, 
including using test drives, and also raised the prospect of shorter intervals between PTIs for 
automated vehicles to ensure their safety. The functionality of such vehicles’ communication 
with other road users and infrastructure should also be tested in PTIs. FSD also underlined 
the  importance  of  software  inspections  in  PTIs,  and  of  ensuring  that  data  protection  and 
security  was  also  verified  to  protect  owners.  The  Spanish  AECA-ITV  underlined  the 
importance  of  establishing  testing  methodologies  to  enable  the  inspection  of  the  safety 
systems  required  by  the  GSR. GOCA  Vlaanderen  also  noted  the  importance of the  better 
testing of ADAS, as did the Portugal’s ANCIA.   

Ireland’s RSA  called  for  the  mandatory  inspection  of  the  functionality  and  effectiveness of 
ADAS in PTIs, including at least those covered in the GSR. They also underlined their view 
that a PTI would still be needed to ensure the safety of connected and automated vehicles, as 
self-diagnosis  would  not  be  sufficient.  The  RSA’s  submission  also  included  more  detailed 
comments on the restructuring of Annex I of the PTI Directive.  

Inspection  company,  Dekra  noted  that  they  agreed  with  the  IIA’s  reference  to  the  need  to 
ensure  that  electronic  components,  ADAS  and  automated  functions  were  covered  in  PTIs, 
supported by non-discriminatory and free access to vehicle data for inspection organisations. 
They noted that the analysis of in-vehicle data would still need to be complemented by visual 
and mechanical inspection. Inspection company Applus also called for the status of ADAS to 
be checked during PTIs, as well as for OBD testing to assess the correct version and status 
of the software and for a physical inspection of the external sensors on which ADAS relies (as 
non-physical inspection would not be sufficient). A French inspection company called for 
more control of ADAS in PTIs, as well as for organised access to data for connected vehicles, 
so that these vehicles could be appropriately tested in PTIs.   

The EGEA underlined the importance of testing ADAS and automated driving systems in PTIs, 
and for direct access to in-vehicle data to facilitate this. Their submission also included more 
detailed recommendations and requirements for the testing of various components, such as 
advanced  headlighting  systems  and  a  vehicle’s  suspension,  as  well  as  proposals  for  the 
implementation of ePTI based on the respective ISO standards.  

In  relation  to  testing  safety  systems,  the  FIA  underlined  the  importance  of  consistency 
between  type  approval  and  roadworthiness  requirements,  noting  again  that  access  to  in-
vehicle data and functions for PTI stations and inspection bodies was important.  

ix.

PTIs for electric and hybrid vehicles

CITA  underlined  that,  in  electric  and  hybrid  vehicles,  the  high  voltage  batteries  and 
components needed to be inspected in more detail in PTIs. Germany’s FSD also called for 
new  inspection  items  for  vehicles  with  a  high  voltage  powertrain,  based  on  electronic 
diagnosis, as well as requirements for the use and handling of a vehicle’s battery management 
system. Spanish AECA-ITV underlined the importance of establishing testing methodologies 
to enable the inspection of electric vehicles in PTIs.  

The two Austrian business associations, VFT and BdF, and the German DKZ, also called for 
the testing of high voltage components of electric and hybrid vehicles and suggested that the 

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OBD could be used to support such tests. The Portuguese ANCIA also called for an OBD 
test to cover the testing of the systems and chargers of electric and hybrid vehicles.  

GOCA Vlaanderen also noted the importance of the better testing of high voltage batteries 
and  components  of  electric  and  hybrid  vehicles,  as  did  a  French  inspection  company. 
Inspection  company,  Applus  called  for  PTIs  for  electric  and  hybrid  vehicles  to  cover  the 
electrical safety of high voltage components, the integrity of the battery and the safety of the 
charging port and noted that OBD testing could be used to assess the condition of the battery. 

The  FIA  and  ÖAMTC  called  for  the  regular  inspection  of  the  high  voltage  components  of 
vehicles with  electric motors,  which  could  include OBD  diagnosis  for many components. In 
addition,  the  FIA  called  for  “safe  access  points”  to  be  added  to  vehicles  to  enable  the 
emergency services to measure the current and voltage in the event of an accident, if the OBD 
was not accessible.   

x.

Other issues relating to the undertaking of PTIs

Germany’s  Central  Agency  for  PTI,  the  FSD,  underlined  that  all  electronic  safety  and 
environmental relevant systems should be tested in PTIs, and so called for the removal of the 
requirement  in  the  current  Directive  that  a  cost-benefit  analysis  be  undertaken  before  new 
items were included in PTIs. They also called for Annexes I and III of the PTI Directive to be 
amended  to  indicate  that  these  contain  recommended  (rather  than  required)  methods  and 
inspection equipment, thus leaving room for Member States to use alternatives, as long as 
these maintained an equivalent high quality of inspection. The FSD noted that it believed that 
the  ISO  standard for  ePTI  was a  game  changer  that  enabled  the  safe, cheap  and efficient 
inspection of electronic systems during PTI, and so this standard should be referenced in the 
PTI Directive, and the necessary functional inspections should be enabled in the type approval 
legislation. They also underlined the importance of “dynamic inspections”, i.e. test drives, to 
enable smart inspection technologies to be used to test safety-relevant systems.   

GOCA Vlaanderen called for greater flexibility in the legislation to make it easier to adopt new 
methods, as vehicle and testing methodologies develop. They also called for the introduction 
of a suspension test and the recording of mileages to prevent odometer fraud, as was done 
in Belgium.   

A German academic argued that, in order to facilitate ePTI, the revision of the PTI Directive 
should  ensure  that  the  external  inspection  equipment  needed  was  technically  and 
commercially independent. He argued that in practice this meant that external equipment had 
an  open  technical  interface  that  allowed  inspection  agencies  to  install  their  own  inspection 
schedules  for  vehicles’  electronic  systems  and that  these  inspections  were  delivered  in  an 
open data format. 

The French CNPA underlined that there was a problem recruiting PTI inspectors in France, 
and so called for the number of years of experience in the vehicle repair and maintenance 
sectors to be taken into account when assessing the level of skills of potential inspectors. They 
also called for more measures to ensure that vehicles were tested on time and for owners of 
well-maintained  older  cars  to  be  allowed  into  low  emission  zones,  if  their  PTI  certificate 
indicated  that  the  emissions  of  their  vehicle  were  sufficiently  low.  A  French  inspection 
company  also  called  for  a  relaxation  of  the  rules  around  who  is  able  to  be  an  inspector, 
arguing  that  they  have  found  that  experienced  engineers,  who  do  not  have  the  necessary 
vehicle inspection diploma, are capable of being a technical controller. 

Spanish AECA-ITV called for the PTI Directive to require insurance companies to check that 
a valid PTI was in place when a vehicle was insured. A German company called for the PTI 

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to check the calibration of a vehicle’s tachograph. The Regional Road Transport Inspection 
in Bydgoszczy called for a number of failures relating to the security of the fitting, legibility 
and consistency of licence plates to be considered as a major deficiency in PTIs.   

xi.

RSI Directive

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.  In  addition,  they  called  for  no,  or  an  expired,  certificate  of  roadworthiness  to  be 
considered  as  an  infringement  for  RSIs.  The  RSA  also  supported  the  establishment  of  the 
proposed  EU-wide  Electronic  Vehicle  Information  Platform.  They  also  suggested  that 
consideration could be given to expanding the scope of the RSI Directive, either making this 
mandatory or including opt-out options, e.g. for L-category and T-category vehicles.   

As  they  proposed  in  relation  to  PTI,  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. In 
addition,  due  to  the  increasing  complexity  of  vehicles,  they  called  for  the  traffic  authorities 
undertaking  RSIs  to  be  supported  by  certified  inspectors,  using  state  of  the  art  inspection 
equipment. 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.     

Transport en Logistiek Vlaanderen, a Belgian business association, highlighted a couple of 
examples  of  penalties  being  levied  in  one  country,  which  it  considered  not  to  be  fair  and 
wanted  clarifying  in  the  revision  of  the  RWP.  First,  fines  were  sometimes  levied  where  a 
vehicle was subject to a brake test on the roadside when it is empty, even though it had passed 
a PTI, in which the brake test had been undertaken on a laden vehicle. Second, vehicles had 
been fined in one country for having lights that have been authorised in another country.    

xii.

Vehicle registration documents Directive

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.  

Directorate-General for Mobility and Transport 
IA for revision of the RWP 

1.  Annex 5a – Charts for quantitative questions
1.1.  General assessment of current EU rules on roadworthiness 
1.1.1.  Please provide your opinion below on how effective are the current EU rules on 

periodic roadworthiness testing and technical roadside inspections in improving road 
safety? (Question 6) 

1.1.2.  Please provide your opinion below on how effective are the current EU rules on 

periodic roadworthiness testing and technical roadside inspections in reducing air 
pollutant emissions? (Question 7) 

 
1.1.3.  Please provide your opinion below on how effective are the current EU rules on the 

registration documents for vehicles in facilitating free movement of goods and people 
within the EU? (Question 8) 

1.2.  Main problems to address 
1.2.1.  In your opinion, how important is that the following problems are addressed, in case 

of the revision of the EU roadworthiness rules? (Question 9) 

 
 
 
 
 
 
1.3.  Policy measures 
1.3.1.  In your opinion, how important is it to include the following provisions in revising the 

EU rules on periodic roadworthiness testing? (Question 11) 

 
 
 
1.3.2.  In your opinion, how important is it to include the following provisions in revising the 

EU rules on technical roadside inspections? (Question 12) 

 
1.3.3.  In your opinion, how important is it to include the following provisions in revising the 

EU rules on the registration documents for vehicles? (Question 13) 

 
 
Impacts 

1.4. 
1.4.1.  How would you assess the likely impact of the following potential measures, if these 

were included in the EU rules? (Question 15) 

 
EU added value 

1.5. 
1.5.1.  To what extent do you agree with following statements? (For the purpose of 

answering some of the questions below, please note that EU “Regulations” are EU 
rules which are directly binding on Member States across the EU, whereas EU 
“Directives” are EU rules implemented through national laws. Currently, the EU rules 
on periodic testing, registration documents, and roadside inspections, are 
implemented through Directives.) (Question 17) 

1.  Annex 5b – Charts for quantitative questions (SME responses)
1.1.  Main problems to address 
1.1.1.  In your opinion, how important is that the following problems are addressed, in case 

of the revision of the EU roadworthiness rules? (Question 9) 

1.2.  Policy measures 
1.2.1.  In your opinion, how important is it to include the following provisions in revising the 

EU rules on periodic roadworthiness testing? (Question 11) 

                    
1.2.2.  In your opinion, how important is it to include the following provisions in revising the 

EU rules on technical roadside inspections? (Question 12) 

1.2.3.  In your opinion, how important is it to include the following provisions in revising the 

EU rules on the registration documents for vehicles? (Question 13) 

 
 
   
1.  Annex 5c – Charts for quantitative questions (Industry responses)
1.1.  Main problems to address 
1.1.1.  In your opinion, how important is that the following problems are addressed, in case 

of the revision of the EU roadworthiness rules? (Question 9) 

1.2.  Policy measures 
1.2.1.  In your opinion, how important is it to include the following provisions in revising the 

EU rules on periodic roadworthiness testing? (Question 11) 

1.2.2.  In your opinion, how important is it to include the following provisions in revising the 

EU rules on technical roadside inspections? (Question 12) 

1.2.3.  In your opinion, how important is it to include the following provisions in revising the 

EU rules on the registration documents for vehicles? (Question 13) 

IMPACT ASSESSMENT SUPPORT STUDY ON THE 
DIRECTIVES OF THE ROADWORTHINESS PACKAGE 

Annex 6 of the Stakeholder Consultation Report – Open Public 
Consultation written summary  

Contract no. MOVE/C2/SER/2022-583/SI2.895928, under FWC 
no. MOVE/2022/OP/0001 

Written by: Ian Skinner (TEPR)  
May – July 2023

IA support study on the Directives of the RWP 

Open Public Consultation written summary 

Directorate-General for Mobility and Transport 
IA for revision of the RWP 

EUROPEAN COMMISSION 
Directorate-General for Mobility and Transport 
Directorate C — Land 
Unit C.2 — Road safety 

Contact: Peter SZATMARI 

E-mail: Peter.SZATMARI@ec.europa.eu

European Commission 
B-1049 Brussels

 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

Analysis of the OPC 

Introduction 

The online public consultation (OPC) on the revision of the EU’s Roadworthiness package 
was live between 6 July and 28 September 2022 on the EU’s Survey website. The OPC 
was divided into six sections, as follows: 

A. Additional information about the respondent.
B. General assessment of current EU rules on roadworthiness.
C. Main problems to address.
D. Policy measures.
Impacts.
E.
F. Final remarks.

This Annex analyses the responses to this consultation. 

The  OPC  covered  both  the  evaluation  of  the  Roadworthiness  package,  which  was  the 
subject  of  a separate  study,  and the  IA  study.  In  the following  analysis,  we focus  on  the 
questions that are relevant for the IA study. Hence, we do not cover the following: 

- Question 2: This was a general question on the effectiveness of the Roadworthiness
package,  which  does  not  provide  any  additional  value  to  the  IA-related  analysis,
given  the  later  more  detailed  questions  on  effectiveness  that  we  do  analyse,  i.e.
questions 6 to 8.

- Questions 3 to 5: These focus on the relevance of the current rules, which is relevant

for the backward-looking evaluation study.

Characteristics of the respondents 

This section contains an analysis of the respondents by their characteristics, whereas the 
remaining  sections  in  this  Annex  present  the  analysis  of  the  responses  to  the  other 
questions according to the respective sections of the OPC, as listed above. The exception 
to this is that the responses to Question 1, which was the only question in Section A of the 
OPC (“Additional information about the respondent”), is analysed in this section, as it asked 
respondents for their ‘specific interest’.   

The analysis in this Annex is differentiated by stakeholder group. We have summarised the 
responses  as  factually  as  possible,  while also  taking  account  of  diverging  views  and  the 
views of SMEs, where these provide additional insights. [Note that the views of SMEs will 
be included later] 

The vast majority of respondents – 84% – were from EU citizens. Looking at the qualitative 
responses  from  EU  citizens  –  when  these  were  provided  –  it  is  clear  that  many  of  the 
responses from citizens in French were part of a campaign. This also includes responses 
in French  from  EU  citizens  based  outside  of  France,  as well  as responses from  non-EU 
citizens, all of which were also in French and from citizens based in France. Together, 96% 
(731) of the responses from EU citizens were in French. In order that the responses from
this  group  of  respondents  did  not  skew  the  analysis,  the  responses  in  French  from  EU
citizens and from non-EU citizens were excluded from the quantitative analysis, although
have been covered in the analysis of the open, qualitative questions. In addition, there were
five near identical responses from a Slovak company, so four of these were also excluded
from the quantitative analysis.

Overall,  there  were  907  responses  to  the  OPC,  of  which  162  have  been  retained  for 
inclusion  in  the  graphs  presented  in  the  following  sections  (see  Table  1).  Overall,  43 

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 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

respondents were a company / business organisation1 and an additional 35 responses were 
from business associations. These two categories were the largest two in the set of retained 
responses, together making up nearly half (48%) of the responses that were analysed. EU 
citizens  contributed  27  responses  of  the  set  of  retained  responses,  while  18  came  from 
NGOs. The 10 responses from public authorities came from seven national authorities and 
three regional or local authorities, representing eight different Member States and Norway. 
Five or fewer responses were received from trade unions (5), consumer organisations (3), 
academic/research institutions (2) and environmental organisations (1). In addition, there 
were 18 responses from organisations that classified themselves as ‘Other’.  

Table 1: Responses by stakeholder category 

Category 

Total number of responses 

Retained responses 

Number of 
respondents 

Percentage of 
total number of 
respondents 

Number of 
respondents 

Percentage of 
total number of 
respondents 

Academic / research 
institution 

Business association 

Company/business 
organisation 

Consumer organisation 

2 

35 

47 

3 

0.2% 

3.9% 

5.2% 

0.3% 

EU citizen 

758 

83.6% 

Environmental 
organisation 

Non-EU citizen 

NGO (Non-governmental 
organisation) 

Public authority 

Trade union 

Other 

Total 

1 

10 

18 

10 

5 

18 

0.1% 

1.1% 

2.0% 

1.1% 

0.6% 

2.0% 

2 

35 

43 

3 

29 

1 

0 

18 

10 

5 

18 

907 

100% 

162 

1.2% 

21.3% 

26.2% 

1.8% 

17.7% 

0.6% 

0.0% 

11.0% 

6.1% 

3.0% 

11.0% 

100% 

1 The majority of respondents that classified themselves as a ‘company / business organisation’ were individual 
companies, although there were some company groupings under this heading. It is not clear why the latter 
chose  to  identify  themselves  as  a  ‘business  organisation’,  rather  than  under  the  alternative  category  of 
‘business association’.    

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 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

Given the relatively low level of response from some stakeholder groups, for the analysis 
we have grouped responses to more general categories. The largest of these is industry, 
which makes up 48% of the retained responses, as it brings together the responses from 
‘company / business organisations’ and ‘business associations’. The responses from both 
citizens  and  public  authorities  are  presented  separately,  while  the  remaining  retained 
responses are grouped together under Other, which together make up 29.0% of the retained 
responses. 

The organisations that responded, so all respondents other than citizens, were also asked 
to indicate their size (see Table 2). This indicates that the vast majority of responses (71%) 
were  from  small  or  medium  sized  organisations.  However,  this  includes  many  business 
associations,  consumer  groups  and  NGOs,  none  of  whom  would  generally  be  large. 
Looking  at  the  responses  of  companies  more  specifically,  i.e.  those  organisations  that 
classified  themselves  as  a  ‘company  /  business  organisation’  and  which  are  clearly  a 
company, there are 21 separate responses from SMEs and 16 from larger companies. For 
some relevant questions, the responses of these two groups are also compared.  

Table 2: Responses by organisation size 

Category 

Number of 
respondents 

Percentage of total number 
of respondents 

Micro (1 to 9 employees) 

Small (10 to 49 employees) 

Medium (50 to 249 employees) 

Large (250 employees or more) 

Total 

58 

23 

15 

39 

135 

43% 

17% 

11% 

29% 

100% 

Respondents  were  also  asked  to  indicate  whether  they  had  a  specific  interest,  which 
included categories that were effectively industry sub-categories, as well as other types of 
interest (see Table 3). Around 20% of respondents who answered this question indicated 
that  their  interest  lay  in  either  automotive  or  motorcycle  federations  (45;  20.5%)  or 
inspections  bodies  (42;  19.1%).  Around  10%  (23)  indicated  that  they  were  vehicle  and 
equipment manufacturers / supplier, while a further 17 (7.7%) indicated that their interest 
lay in automobile clubs and 4 (1.8%) were testing equipment manufacturers. However, two 
fifths of respondents (89) indicated that their specific interest lay elsewhere.  

In addition, for relevant questions, an analysis was performed of the responses of the 78 
unique industry respondents, according to their area of ‘specific interest’, a breakdown of 
which is also presented in Table 3. This shows that the majority of industry respondents’ 
main area of specific interest was not solely one of the areas explicitly listed in the survey. 
Of these, the majority (64.3%; 27 out of 42) had other interests, whereas 6 (14.3%) had a 
combination of the ‘specific interests’ mentioned in the survey. The remaining nine (21.4%) 
had  no  ‘specific  interest’. Of the  ‘specific  interests’  explicitly  mentioned  in  the  survey,  15 
(19.2%) responses came from both inspection bodies and vehicle equipment manufacturers 
and suppliers.   

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 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

Table 3: Responses by specific interest 

Category 

Inspection 
bodies 

Testing 
equipment 
manufacturer 

and 

Vehicle 
equipment 
manufacturers  / 
supplier 

Automotive 
motorcycle 
federations 

/ 

Automobile 
clubs 

Other 

Total 

Number of 
respondents 

Percentage of total 
number of 
respondents 

Number of 
industry 
respondents 

Percentage of 
total number of 
industry 
respondents 

42 

4 

23 

45 

17 

89 

220 

19.1% 

1.8% 

10.5% 

20.5% 

7.7% 

40.5% 

100% 

15 

3 

15 

3 

0 

42 

78 

19.2% 

3.8% 

19.2% 

3.8% 

0% 

53.8% 

100% 

Given the campaign that was identified, it is not surprising that the vast majority of the total 
number of responses were from France (744; 82.0%). There were more than 10 responses 
from  an  additional  five  Member  States:  Belgium  (43;  4.7%),  Germany  (21;  2.3%),  the 
Netherlands (20; 2.3%), Austria (153; 1.7%) and Slovakia (14; 1.5%), including the repeated 
response.  The  were  no  responses  from  eight  Member  States:  Cyprus,  Estonia,  Greece, 
Hungary, Latvia, Lithuania, Luxembourg and Romania. In addition, 14 responses came from 
stakeholders  based  outside  of  the  EU,  including  two  from  Switzerland,  one  each  from 
Norway and Iceland, and five from the UK. 

General assessment of current EU rules on roadworthiness 

As noted above, we are not analysing Questions 2 to 5, as these relate only to the evaluation 
study.   

Question 6 asked respondents to provide their opinion on the effectiveness of six specific 
measures of the EU’s rules on PTI and RSI in improving road safety. Around two-thirds 
of respondents believed that three of the different measures had been effective in improving 
road safety2. Specifically, 68% of respondents believed that both categorising deficiencies 
during  the  periodic  tests  as  either  minor,  major,  or  dangerous  deficiencies  (98,  20  ‘no 
responses’ or ‘Don’t knows’) and minimum standards for inspectors' competence, training 

2 i.e. they responded either “Very effective” or “effective” 

Directorate-General for Mobility and Transport 
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 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

and objectivity (95, 25 ‘no responses’ or ‘Don’t knows’) had been effective in improving road 
safety. In addition, 67% (96, 20 ‘no responses’ or ‘Don’t knows’) felt that road safety had 
been improved by minimum standards for testing centres, facilities and equipment. For each 
of these measures, industry respondents and public authorities were more likely to believe 
that these had been effective in improving road safety than were citizens. 

However, for the other three measures on which a question was asked, respondents were 
less convinced that they had been effective in improving road safety, as only around half 
held this view in each case. Overall, 53% (76, 20 ‘no responses’ or ‘Don’t knows’) thought 
that  different  time  intervals  between  periodic  tests,  according  to  the  age  of  vehicle,  and 
vehicle type had been effective in improving road safety and 51% (69, 28 ‘no responses’ or 
‘Don’t knows’) had the same view about obliging Member States to perform roadside tests 
on a minimum share of commercial vehicles each year. For both of these measures, public 
authorities were more positive than other stakeholder groups (67%, six, one ‘Don’t know’; 
and  80%,  eight,  respectively).  Finally,  less  than  an  overall  majority  (45%;  58,  36  ‘no 
responses’ or ‘Don’t knows’) thought that periodic testing of high-speed tractors and heavy 
motorcycles  had  been  successful  in  improving  road  safety,  although  this  figure  was  still 
larger than the share of respondents who that that this measure of the legislation had not 
been effective (43%; 53)3. A majority of industry respondents (55%; 30, 23 ‘no responses’ 
or ‘Don’t knows’) even felt that this measure had been successful in improving road safety. 

The next question asked respondents about the effectiveness of the same six measures 
of  the  legislation  in  relation  to  reducing  air  pollutant  emissions.  The  responses 
followed  a  similar  pattern  to  the  responses  to  the  previous  question  that  related  to  road 
safety, in terms of the measures that respondents felt had been more effective in reducing 
air pollutant emissions. However, for each measure, the share of respondents who believed 
that these measures had been effective in reducing air pollutant emissions was lower than 
the  share  that  believed  they  had  improved  road  safety.  Over  half  of  the  respondents 
believed that three measures had been effective in reducing air quality emissions. Nearly 
three-fifths  of  respondents  (57%;  75,  32  no  responses  or  ‘Don’t  knows’)  believed  that 
minimum standards for inspectors' competence, training and objectivity had been effective 
in  reducing  air  pollutant  emissions.  Just  over  half  of  respondents  felt  that  two  other 
measures  –  categorising  deficiencies  during  the  periodic  tests  as  either  minor,  major,  or 
dangerous  deficiencies  (54%;  76,  22  no  responses  or  ‘Don’t  knows’)  and  minimum 
standards for testing centres, facilities and equipment (51%; 73 22 no responses or ‘Don’t 
knows’) – had been effective in reducing air pollutant emissions. By stakeholder type, as 
with  the  question  above  in  relation  to  road  safety,  industry  respondents  and  public 
authorities were more likely to believe that these had been effective in reducing air pollutant 
emissions than were citizens.  

Respondents were more divided  in relation to the views on the effectiveness of two other 
measures in reducing air pollutant emissions, with similar shares believing that the measure 
had been effective and not effective. For obliging Member States to perform roadside tests 
on  a  minimum  share  of  commercial  vehicles  each  year,  39%  of  respondents  (53,  29  no 
responses  or  ‘Don’t  knows’)  thought  that the  measure had  been  effective in reducing  air 
pollutant emissions, whereas 37% (50) did not. The shares were very similar for different 
time intervals between periodic tests, according to the age of vehicle, and vehicle type, as 
again 39% (56, 22 no responses or ‘Don’t knows’) felt that the measure had been effective, 
compared to 37% (53) who did not. Finally, whereas 35% (45, 37 no responses or ‘Don’t 
knows’)  of  respondents  felt  that  periodic  testing  of  high-speed  tractors  and  heavy 
motorcycles had been effective in reducing air pollutant emissions, a larger share (47%; 60) 
felt that it had not. On the other hand, for each of these three measures, a majority of public 
authorities  thought  the  respective  measure  had  been  effective  in  reducing  air  pollutant 

3 i.e. they responded either “Not effective” or “ Less effective” 

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 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

emissions (67%, six, one ‘Don’t know’; 75%, six, two ‘no responses’ or ‘Don’t knows’); and 
80%, eight, respectively).  

Finally for this section, respondents were asked for their views on whether the obligation on 
Member States to recognise roadworthiness certificates upon change ownership had been 
effective  in  facilitating  the  free  movement  of  goods  and  people  within  the  EU 
(Question 8). A small majority of respondents (54%; 76, 22 ‘no responses’ or ‘Don’t knows’) 
felt that this measure had been effective. 

Main problems to address 

Respondents  were  asked  for  their  views  on  the  importance  of  a  revision  of  the  EU’s 
roadworthiness rules addressing three specific problems (Question 9). Between two-
thirds and four-fifths of respondents 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  Periodical 
Technical Inspections (PTI) of vehicles to test electronic safety & 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. Each stakeholder group gave similarly high levels of 
support to the importance of addressing each problem.  

For this question, the responses of industry stakeholders by their area of ‘specific interest’, 
as well as the responses of ‘SMEs’ compared to ‘large enterprises’, were also analysed. By 
their area of ‘specific interest’, most industry sub-groups also gave high levels of support to 
the  need  to  address  the  three  specific  problems  highlighted,  although  there  were  some 
notable  differences.  Vehicle  and  equipment  manufacturers/suppliers  and  testing 
equipment  manufacturers  both  unanimously  supported  the  need  to  address  vehicles 
circulating on the roads with defects or tampered components (100%; 14 out of 14, one ‘no 
response’, and three out of three, respectively). On the other hand, vehicle and equipment 
manufacturers/suppliers were less supportive than other stakeholder groups of the need 
to address the other two problems. Only 54% (seven, two ‘no responses’ or ‘Don’t knows’) 
agreed that methods for Periodical Technical Inspections (PTI) of vehicles to test electronic 
safety & driver assistance systems in vehicles needed to be addressed, while half (50%; 
six,  three  ‘no  responses’  or  ‘Don’t  knows’)  agreed  that  there  was  a  need  to  address  the 
availability of relevant vehicle data to enforcement authorities in the EU Member States in 
cross-border traffic.  

The level  of  support  from  companies  depending  on their size  (i.e.  whether they  were an 
SME or not) was similar for all three specific problems. Having said that, it was notable that 
for each specific problem, all of the minority of responses that considered the respective 
specific problem not to be important were SMEs.  

Respondents  were  then  asked  whether  they  had  any  further  comments  on  the 
functioning of, or the problems relating to, the EU’s roadworthiness rules (Question 
10).  Many  industry  respondents  underlined  that  it  was  important  to  ensure  that  the 
equipment  that  has  been  added  to  vehicles  to  improve  their  safety  and  environmental 
performance was checked as part of inspections. Others underlined the importance of the 
regular  testing  of  the  electronic  systems  that  were  becoming  increasingly  advanced, 
including  that  their  software  was  up  to  date.  Allowing  Member  States  to  inspect  foreign 
vehicles  was  also mentioned  by  a  number  of  industry  respondents,  as  being  particularly 
important. The safety risks associated with the use of unauthorised components were also 
highlighted, while others suggested that inspections of motorcycles should be allowed when 
there were concerns about their noise levels, as a result of tampering. The importance of 
training  vehicle  inspectors  so  that  they  were  able  to  properly  inspect  new  vehicle 

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 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

components was also underlined. While some respondents recognised the importance of 
amending inspections, they noted that any amendments should be proportionate and not 
lead to increased costs. A concern was also raised that the testing of the new safety and 
electronic systems would not be possible within a standard PTI, as a result of its complexity. 
It was also suggested that agricultural tractors should be subject to the same tests as trucks 
where they were used in the same type of operation.  

From the perspective of citizens, many of those who were part of the campaign suggested 
that inspections should not be extended to motorcycles, as this would bring little in the way 
of benefits. In addition, other responses from citizens suggested that it was important for 
vehicles to be able to be inspected in countries other than that in which they were registered, 
that all technical means should be taken to prevent the tampering of vehicles and annual 
emissions tests should be undertaken.  

A public authority underlined that EU roadworthiness legislation did not keep up with the 
rapid development of vehicles, so there was a need for the legislation to be more flexible to 
leave room for innovation to enable testing to keep up with vehicle development. Another 
authority  underlined  that  testing  was not  supposed  to keep  a vehicle in an  “approximate 
new” state, rather its purpose was to keep vehicles in an acceptable condition, while also 
noting that testing should be “relatively quick, simple and inexpensive”. They also called for 
the development of tests for high-speed tractors that take account of the need for mobile 
PTIs  for these vehicles. Other  authorities  emphasised  the  importance of access to data. 
One called for manufacturers to supply Member States with accessible and standardised 
information free of charge, as well as a higher level of exchange of data between Member 
States for vehicles that have been previously written off. Another public authority called for 
testing centres to be able to access data without “the manufacturer’s filter”.  

NGOs mentioned a number of different issues. New checks were called for in relation to 
advanced  driver-assistance  systems,  intelligent  speed  assistance  systems  and  camera 
devices,  as well  as for tests to include  technical  inspections of  eCall.  The importance of 
tests checking that the latest software updates, including over-the-air updates, had been 
installed  correctly  was  also  underlined,  as  was  the  importance  of  checking  the  safety 
performance  of  automated  vehicles.  Another  NGO  suggested  that  the  lack  of  sufficient 
checks and expertise to detect any tampering of software and hardware was a problem, 
and  also  called  for  more  stringent  penalties  to  prevent  tampering.  Roadside  checks  to 
address the tampering of motorcycles with respect to noise and emissions were also called 
for,  A  couple  of  NGOs  highlighted  that,  for  motorcycles  in  particular,  when  defects  did 
influence road safety, they were of the kind, such as low pressure tyres or lights failing, that 
happened quickly, and so it was important for users to be trained to regularly check their 
vehicles.  Another  NGO  underlined  that  the  affordability  of  the  test  for  consumers  was 
important.  One  NGO  called  for  the  inclusion  of  electric/powered  wheelchairs  in  checks, 
while  another  underlined  the  importance  of  the  continued  exemption  of  historic  vehicles 
from the legislation, as far as was possible. 

A trade union respondent also underlined the importance of access to data on vehicles, 
including calling for an extension of current rules for accessing onboard data, as well as 
new  methods  for  reading  these.  Responses  from  those  organisations  that  classified 
themselves as ‘Other’ called for high penalties to dissuade tampering and underlined the 
importance of maintaining the definition of ‘historic vehicle’. An academic called for effective 
roadside checks of cargo to reduce the number of accidents.     

Policy measures 

Respondents were asked for their views on including twelve different provisions in the 
revision of the rules on PTI (Question 11). A majority of respondents supported each of 
the twelve provisions being included in a revision of the PTI legislation. Similarly, for most 
provisions, a majority of each type of stakeholder also supported it being included in such 

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 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

a  revision.  For  these  questions,  the  responses  of  industry  stakeholders  by  their  area  of 
‘specific  interest’,  as  well  as  the  responses  of  ‘SMEs’  compared  to  those  of  ‘large 
enterprises’, were also analysed. Where there were notable differences in the support given 
to  a  particular  provision  between  those  with  different  ‘specific  interests’,  these  are  noted 
below.  There  were  no  notable  differences  in  the  support  given  to  different  provisions  by 
companies depending on their size, i.e. if they were an SME or not. However, for a number 
of the provisions, those not supporting the provision were mainly SMEs; these provisions 
are highlighted below. 

The provisions that received the most support were: 

- Mandatory data exchange of roadworthiness certificate data to verify their validity
during the reregistration of a vehicle in another EU Member State (72%; 111, 10
‘no responses’ or ‘Don’t knows’).

- Methods to test the functioning of safety-relevant electronic components,

advanced driver assistance systems (ADAS) and automated functions (70%; 106,
13 ‘no responses’ or ‘Don’t knows’). This received unanimous support from testing
equipment manufacturers (100%; three), although vehicle and equipment
manufacturers/suppliers were less supportive than those with other 'specific
interests’ (42%; five, three ‘no responses’ or ‘Don’t knows’).

These were followed by a further six provisions that received support from around two thirds 
of respondents, i.e.: 

- New methods for tackling odometer fraud (69%; 107, nine ‘no responses’ or ‘Don’t

knows’).

- Extending (or clarifying) existing rules on access to in-vehicle data for the purpose
of periodic roadworthiness testing, with data protection safeguards (67%; 102, 11
‘no responses’ or ‘Don’t knows’). Automotive/motorcycle federations (50%; one,
one ‘no response’ or ‘Don’t knows’) and vehicle and equipment
manufacturers/suppliers were less supportive of this provision than those with
other 'specific interests’ (58%; seven, three ‘no responses’ or ‘Don’t knows’).
- New methods to test vehicles with alternative powertrain technologies (hybrid, full-
electric, hydrogen) (66%; 100, 12 ‘no responses’ or ‘Don’t knows’). Vehicle and
equipment manufacturers/suppliers were less supportive than those with other
'specific interests’ of this provision (42%; five, three ‘no responses’ or ‘Don’t
knows’).

- Ensuring that safety- and environment-relevant software updates have been done,
e.g., as a result of vehicle recalls (65%; 100, nine ‘no responses’ or ‘Don’t knows’).
- New methods for measuring exhaust emissions, for example particle number (PN)
and nitrogen oxides (NOx) (64%; 96, 13 ‘no responses’ or ‘Don’t knows’). This
provision was not supported by automotive/motorcycle federations (0%; three).

- New measures 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 (63%; 97, 11 ‘no responses’ or ‘Don’t
knows’). Testing equipment manufacturer were less supportive of this provision
than those with other 'specific interests’ (33%; one).

Finally a further four provisions received less support, although this was still from a majority 
of respondents in each case: 

- New methods for reading out onboard data stored in the vehicles (59%; 92, nine

‘no responses’ or ‘Don’t knows’). Automotive/motorcycle federations (33%; one)
and vehicle and equipment manufacturers/suppliers were less supportive of
this provision (38%; five, two ‘no responses’ or ‘Don’t knows’) than those with other
'specific interests’.

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- Electronic Periodical Technical Inspection (ePTI) of vehicles (57%; 82, 21 ‘no

responses’ or ‘Don’t knows’).

- Measures to specifically tackle noise-related tampering / non-compliance problems

in two- and three-wheelers and quads (L category vehicles) (55%; 75, 27 ‘no
responses’ or ‘Don’t knows’). Vehicle and equipment manufacturers/suppliers
were less supportive of this provision than those with other 'specific interests’
(29%; two, eight ‘no responses’ or ‘Don’t knows’). In addition, SMEs were much
more likely than large enterprises not to support this measure, with 40% (eight;
one ‘no responses’ or ‘Don’t knows’) not supporting it, compared to no (0%) large
enterprises.

- Extending the rules to powered two- and three-wheelers (L category vehicles)

(53%; 73, 25 ‘no responses’ or ‘Don’t knows’). This received unanimous support
from testing equipment manufacturers (100%; three), although vehicle and
equipment manufacturers/suppliers were less supportive of this provision than
those with other 'specific interests’ (38%; three, seven ‘no responses’ or ‘Don’t
knows’).

Question 12 asked respondents a similar question relating to seven different provisions 
that could be covered by the revision of the rules on TRI. As with the potential measures 
relating to the PTI Directive, a majority of respondents felt that the inclusion of each of the 
provisions mentioned was important, and similarly a majority of each type of stakeholder 
also  supported  the  inclusion  of  most  provisions  in  such  a  revision.  Two  of  the  seven 
provisions received support from just under three-quarters of respondents: 

-

Follow-up in the Member States of registration in case of a prohibition or
suspension abroad (73%; 103, 22 ‘no responses’ or ‘Don’t knows’).

- Mandatory checks during roadside inspections of commercial vehicles to ensure

the safe securing of cargo (70%; 99, 22 ‘no responses’ or ‘Don’t knows’).

The  inclusion  of  a  further  three  provisions  was  supported  by  just  under  two-thirds  of 
respondents, i.e.: 

- Granting roadside inspection authorities access to electronic data (64%; 96, 14 ‘no

responses’ or ‘Don’t knows’). Vehicle and equipment manufacturers/suppliers
were less supportive of this provision than those with other 'specific interests’
(31%; four, two ‘no responses’ or ‘Don’t knows’).

- Extending (or clarifying) existing rules on access to in-vehicle data for the purpose
of technical roadside inspections, with data protection safeguards (62%; 93, 15 ‘no
responses’ or ‘Don’t knows’). Vehicle and equipment manufacturers/suppliers
were less supportive of this provision than those with other 'specific interests’
(50%; six, three ‘no responses’ or ‘Don’t knows’).

- Measures to specifically tackle noise-related tampering / noncompliance problems

in vehicles inspected at the roadside (60%; 91, 13 ‘no responses’ or ‘Don’t
knows’). SMEs were much more likely not to support this measure than large
enterprises, with 29% (six) not supporting it, compared to no (0%) large
enterprises.

The  remaining  two  provisions  received  support  from  just  over  half  of  the  respondents, 
although public authorities were much more likely to support these two measures than other 
stakeholders (88%; seven, two ‘no responses’ or ‘Don’t knows’; and 78%; seven, one ‘Don’t 
know’, respectively): 

- Extended emission testing (e.g., NOx and PN), including the use of remote

sensing equipment (53%; 78, 17 ‘no responses’ or ‘Don’t knows’). This provision
was not supported by automotive/motorcycle federations (0%; three). SMEs
were much more likely not to support this measure than large enterprises, with

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 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

40% (eight; one ‘no responses’ or ‘Don’t knows’) not supporting it, compared to no 
(0%) large enterprises.    

- 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’). SMEs were
much more likely not to support this measure than large enterprises, with 38%
(eight) not supporting it, compared to no (0%) large enterprises.

Respondents  were  then  asked  for  the  importance  of  the  inclusion  of  four  different 
provisions that could be covered by the revision of the rules on vehicle registration 
documents (Question 13). The results indicated that around three-quarters of respondents 
felt  that  the  inclusion  of  each  provision  was  important,  as  did  a  similar  proportion  of 
responses from each stakeholder type. In other words, there was broad support for:   

- Adding data on major accidents of a vehicle to the vehicle register (76%; 115, 13

-

-

‘no responses’ or ‘Don’t knows’).
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’).

- Adding odometer data to the vehicle register (72%; 111, nine ‘no responses’ or

‘Don’t knows’).

To  conclude the  discussion  on  policy  measures,  respondents  were asked  whether they 
had  any  suggestions  for  new  policy  measures  that  could  be  included  in  the 
roadworthiness rules, other than those mentioned in Questions 11 to 13 (Question 14). 
Several industry respondents called for more harmonisation across the EU, particularly of 
roadworthiness tests, although also for vehicle registration processes and documentation. 
Others called for the mutual recognition of PTIs undertaken in countries other than that in 
which the vehicle was registered, while noting that in the absence of harmonised testing 
some  countries  could  gain  a  reputation  for  being  more  lenient,  which  needed  to  be 
addressed. Another respondent suggested that this could be addressed, if a PTI undertaken 
in a country other than that in which the vehicle was registered was undertaken to the same 
standards as the PTI of the registering country. A number of respondents also identified the 
importance of  digitalising  the  process  as much as  possible,  including  vehicle registration 
and deregistration. Respondents also underlined the importance of tighter rules around the 
deregistration of a vehicle, including restricting the possibilities for temporary deregistration. 

Another  industry  respondent  suggested  that  the  legal  basis  of  the  roadworthiness  tests 
should be changed to include both road safety and environmental compliance. A number of 
other respondents highlighted specific safety or environmental concerns. The importance 
of  regulating  the  measurement  of  particle  numbers,  petrol  particulate  filters  and  NOx 
abatement technology at the EU level was underlined, rather than having country-specific 
approaches. Tampering was also raised by a number of industry respondents as an issue 
that needed to be addressed, particularly in relation to noise and emissions. On the other 
hand, one respondent suggested that adding accident data to a vehicle’s record could have 
the adverse effect of encouraging vehicle owners to use unregistered repairers, which could 
have knock-on effects for safety. Other respondents called for Member States to be allowed 
to  maintain  a  vehicle  inspection  system  that  was  divided  into  separate  safety  and 
environmental checks, and for these different checks to have different deadlines. They also 
underlined that, when carrying out a PTI, there should be a requirement to prove that the 
vehicle was actually present at the inspection. Another respondent called for vehicles that 
had been subject to a major accident being roadworthiness tested before being returned to 
the owner.   

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Other industry respondents suggested that conditions for access to vehicle data should be 
clearly  defined  and  apply  only  to  data that  was  relevant  for  PTIs,  while others  called  for 
access  to  such  data  and  their  evaluation  to  be  standardised.  Other  points  that  were 
mentioned included the need for the better testing of a vehicle’s suspension, as this was 
increasingly  important,  a  rethinking  of  headlight  testing,  as  lighting  had  become  an 
important driver assistance function, and the testing of the air conditioning system to make 
sure that the correct refrigerant was being used. Others called for the extension of technical 
inspections to trailers (O1 and O2), to restraints and ramps for wheelchair enabled vehicles 
and to the systems that connected trailers to tractors/vehicles, as well as better roadside 
checks for overloaded vehicles.  

Many of the citizens involved in the campaign called for the scrapping of roadworthiness 
testing for powered two wheelers. Other citizens underlined the importance of distinguishing 
between  different  categories  of  L-category  vehicles,  the  need  to  introduce  testing 
requirements for electric vehicles, the importance of frequent noise testing for all vehicles 
and  the  importance  of  tests  for  all  safety  features  of  vehicles.  In  relation  to  odometer 
readings, it was suggested that it should be mandatory to record odometer data at certain 
events, such as accidents and the transfer of ownership (including if a vehicle was stolen), 
and that potential buyers should have access to all of this information. The importance of 
considering  the  implications,  in  terms  of  additional  costs,  of  more  extensive  testing  on 
drivers was also noted. 

Public  authority  respondents  called  for  the  establishment  of  a  platform  where  PTI  data 
could be shared between Member States, the incorporation of plume chasing checks, for a 
uniform frequency for exhaust emission testing and for noise and emission testing to reflect 
both realistic and extreme driving conditions. Another public authority called for a stronger 
link between manufacturers, authorities, the maintenance market and owners throughout 
the lifetime of the vehicle, starting with checks in type approval that could then be checked 
in PTIs and RSIs. They also called for the alteration of vehicles to not be allowed, if it led to 
changes in their emission control or safety systems.     

Responses  from  NGOs  covered  many  different  points.  One  called  for  the  frequency  of 
testing for cars and light commercial vehicles to be four years after the first registration date, 
and then every two years thereafter, and for the same frequency of testing to be applied to 
all motorcycles, as well as annual tests for high mileage vehicles. They also called for the 
harmonisation  of  the  tolerance  level  for  the  frequency  of  testing.  In  relation  to  roadside 
checks, they called for these to be extended to vans and their trailers, as well as action to 
be  taken  to  further  improve  the  quality  of  such  checks.  The  importance  of  harmonised 
minimum requirements for cargo securing, as well as a harmonised training for personnel 
checking these, was also mentioned. Other NGOs underlined the importance of inspecting 
all  safety  and  environmental  electronic  vehicle  systems,  hybrid powertrains,  light  trailers, 
automated  driving  functions,  software  and  the  communication  systems  of  automated 
vehicles. It was also suggested that a reference should be made to the ISO ePTI standard. 
Several NGOs highlighted the importance of independent access to data, while underlining 
the  importance  of  the  maintaining  the  security  of  these  data.  Others  underlined  the 
importance of a more harmonised approach across the Member States and suggested that 
‘smart dynamic inspection technologies’ be considered to test safety systems. It was also 
suggested that measures should prevent the export and re-registration of vehicles that did 
not comply with emission limits, or which were subject to a recall action. Responses from 
trade  union  representatives  called  for  speed  limitation  devices  to  be  obligatory,  and 
mandatorily inspected, for the reintroduction of more ‘minor failures’ and the inclusion of all 
L-category vehicles in the legislation.

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 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

Impacts 

Respondents  were  asked  to  assess  the  impact  of  the  inclusion  of  17  potential 
measures  in  the  EU  roadworthiness  rules  (Question  15).  Overall,  a  majority  of 
respondents thought that the impact of each measure would be positive4. Around four fifths 
of respondents felt that two measures would have a positive impact:  

-

Follow-up in the Member States of registration in case of a prohibition or
suspension abroad (80%; 118, 16 ‘no responses’ or ‘Don’t knows’).

- Mandatory exchange of roadworthiness certificate data to verify their validity during
the re-registration of a vehicle in another EU Member State (79%; 119, 13 ‘no
responses’ or ‘Don’t knows’).

A further five measures were considered likely to have a positive impact by around three 
quarters of the respondents, i.e.:    

- Adding data on major accidents of a vehicle to the vehicle register (77%; 117, 12

-

‘no responses’ or ‘Don’t knows’).
Full digitalisation of registration documents (75%; 113, 14 ‘no responses’ or ‘Don’t
knows’).

- New methods for tackling odometer fraud (75%; 110, 18 ‘no responses’ or ‘Don’t

-

knows’).
Improved exchange of roadworthiness data between Member States in electronic
format (74%; 112, 13 ‘no responses’ or ‘Don’t knows’).

- Methods to test the functioning of safety relevant electronic components, advanced
driver assistance systems (ADAS) and automated functions (73%; 104, 22 ‘no
responses’ or ‘Don’t knows’).

An  additional  three  potential  measures  were  considered  to  have  the  potential  to  have  a 
positive impact by at least two-thirds of respondents: 

- Mandatory checks during roadside inspections of commercial vehicles to ensure

the safe securing of cargo (71%; 98, 25 ‘no responses’ or ‘Don’t knows’).

- Ensuring that safety- and environment relevant software updates have been done,

e.g., as a result of vehicle recalls (70%; 110, seven ‘no responses’ or ‘Don’t
knows’).

- Extending (or clarifying) existing rules on access to in-vehicle data for the purpose
of periodic inspections and roadside inspection (66%; 101, 12 ‘no responses’ or
‘Don’t knows’).

Over half of the respondents thought five further measures would have a positive impact, 
i.e.:

- New methods to test vehicles with alternative powertrain technologies (hybrid, full-

electric, hydrogen) (62%; 93, 13 ‘no responses’ or ‘Don’t knows’).

- New methods for reading out on-board data stored in the vehicles (61%; 91, 14 ‘no

responses’ or ‘Don’t knows’).

- New methods for measuring exhaust emissions, for example particle number (PN)
and NOx measurements, during periodic inspections (59%; 84, 21 ‘no responses’
or ‘Don’t knows’).

- Electronic Periodical Technical Inspection (ePTI) of vehicles (58%; 84, 20 ‘no

responses’ or ‘Don’t knows’).

4 i.e. they responded either “Fully positive” or “somewhat positive” 

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- Making more vehicles subject to roadside inspections (55%; 84, 10 ‘no responses’

or ‘Don’t knows’).

Around half of the respondents felt that the final two measures would have a positive 
impact: 

- New methods for measuring exhaust emissions, for example particle number (PN)
and NOx measurements, during roadside inspections, including the use of remote
sensing equipment (51%; 71, 24 ‘no responses’ or ‘Don’t knows’).

- Making more vehicles subject to periodic Inspections (51%; 78, 11 ‘no responses’

or ‘Don’t knows’).

Generally, the responses by different categories of stakeholder were similar to the overall 
level of response, although there were some notable exceptions. Eighty per cent (eight) of 
public  authorities  thought  that  new  methods  to  test  vehicles  with  alternative  powertrain 
technologies (hybrid, full-electric, hydrogen) would have a positive impact, as did 71% (20, 
one ‘Don’t know’) of citizens, whereas industry respondents were less convinced (58%; 43, 
four ‘Don’t knows’). Similarly, 80% (eight) of public authorities thought that new methods for 
measuring exhaust emissions, for example particle number (PN) and NOx measurements, 
during  roadside  inspections  would  have  a  positive  impact,  as  did  69%  of  citizens,  while 
support  amongst  industry  respondents  was  much  lower  (42%;  28,  12  ‘no  responses’  or 
‘Don’t  knows’).  On  the  other  hand,  whereas  overall  nearly  three-fifths  (58%;  84,  20  ‘no 
responses’  or  ‘Don’t  knows’)  felt  that  electronic Periodical  Technical  Inspection  (ePTI)  of 
vehicles would have a positive impact, public authorities were less convinced (38%; three, 
two ‘Don’t knows’).  

Respondents  were  then  asked  if  they  had  any  additional  comments  on  other  potential 
impacts  of  the  possible  policy  measures  (Question  16).  Many  respondents  repeated 
areas that they would like to see covered by the potential revision to the roadworthiness 
legislation, rather than mentioning additional impacts. Many respondents underlined that, if 
relevant  measures  were  implemented,  there  would  be  improvements  in  road  safety  and 
reduced air pollutant emissions, as well as potentially some reductions in CO2 emissions. It 
was  suggested  that  increasing  the  frequency  of  roadworthiness  tests  for  older  vehicles 
would  have  a  particularly  positive  impact  in  this  respect.  Overall,  it  was  considered  that 
relevant measures would have a positive impact on the quality of inspections, which in turn 
could  have  a  positive  economic  impact  by  improving  the  durability  of  vehicles.  Several 
respondents, including industry respondents, NGOs and citizens, raised concerns about the 
potential affordability to both those undertaking the inspections and vehicle owners of more 
extensive testing. It was also suggested that improved roadside inspections would lead to 
a reduction in tampered vehicles. Others noted that the beneficial impacts of ePTIs would 
only occur of they were part of the vehicle’s emission control system, rather than being seen 
as  an  alternative  to  PTIs.  Some  industry  respondents  were  not  convinced  that  having 
better access to vehicle data would have a beneficial impact on roadworthiness and were 
also not convinced of the added value of more emission testing during PTIs and RSIs, given 
that many stakeholders were exploring the potential of remote sensing in this respect.     

EU added value 

Respondents were then asked to indicate their level agreement with five statements on the 
implementation  of  the  three  pieces  of  legislation  (Question  17).  Nearly  two  thirds  of 
respondents agreed5 that the EU rules on roadworthiness have added value for citizens and 
businesses,  compared  to  what  could  be  achieved  by  Member  States  a  national  and/or 
regional  and  international  level  (64%;  96,  14  ‘no  responses’  or  ‘Don’t  knows’).  Similar 

5 i.e. they responded either “Fully agree” or “somewhat agree” 

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proportions  of respondents from  different stakeholder  groups  also  held this  view. On the 
other hand, less than a third of respondents agreed that the objectives of the revision of the 
EU  rules  on  roadworthiness  could  be  better  accomplished  through  deployment  of  non-
legislative tools based on guidance or recommendations by the Commission (30%; 44, 17 
‘no responses’ or ‘Don’t knows’). Indeed a majority (54%; 80) of respondents disagreed with 
this statement, as did a much larger proportion of public authority (90%; nine) respondents. 

Respondents  were  also  asked  whether  the  objectives  of  each  of  the  three  pieces  of 
legislation could be achieved better through a Regulation rather than a Directive. There was 
most support for the Directive on vehicle registration documents becoming a Regulation, as 
a majority of respondents (56%; 80, 21 ‘no responses’ or ‘Don’t knows’) agreed with the 
respective  statement.  A  majority  of  respondents  in  each  of  the  three  main  stakeholder 
categories also agreed that the objectives of this Directive would be better achieved through 
a Regulation.   

Opinion  on  whether  the  objectives  of  the  other  two  Directives  would  be  better  achieved 
through a Regulation was more divided. In relation to technical roadside inspections, there 
was no majority either agreeing or disagreeing with the statement. So, whereas 45% (66, 
18  ‘no  responses’  or  ‘Don’t  knows’)  agreed  that  the  objectives  of  the  Directive  would  be 
better achieved through a Regulation, 43% (63) disagreed. On the other hand, for periodic 
roadworthiness testing, a small majority disagreed with the statement, so only 41% (62, 12 
‘no responses’ or ‘Don’t knows’) agreed, as opposed to 51% (77) who disagreed. 

Final remarks 

At the end of the survey, respondents were asked whether they had any further comments 
(Question  18).  Many  re-iterated  points  that  they  had  made  in  response  to  previous 
questions.  A  number  of  additional,  more  general  points  were  made  by  various  industry 
respondents. Four similar responses underlined that PTIs should not be a tool to test the 
conformity  of  a  vehicle  with  the  relevant  type  approval  and  underlined  that  the  ability  of 
vehicles’  self-diagnosis systems  in detecting  faults,  so  suggested that  PTI  should not  be 
used  for  issues  covered  by  such  systems.  In  relation  to  data,  they  underlined  that  the 
revision to the PTI legislation should not be used to circumvent Regulation (EU) 2019/621 
and  that  the  car  pass  system  in  Belgium,  under which  odometer  readings  are  centrally 
recorded and made available to testing centres, should be implemented EU-wide. They also 
noted that the automotive industry supported ISO 20730 as a framework for ePTI, as it had 
the potential to create a single ePTI in the EU, and underlined that a harmonised approach 
to the relevant test procedures and equipment was important. They questioned whether an 
inspection of air conditioning systems for cars and vans was necessary. In addition, they 
suggested that PTI checks on alternative powertrain technologies should focus on visual 
checks  for  damage  and  leakages,  and  that  the  PTI  should  not  question  the  integrity  of 
software, as this would be in contradiction to the respective UN methodologies.  

Other  industry  responses  underlined  that  PTI  should  be  consistent  with  type  approval 
legislation, and not go beyond this, and that the PTI should not overlook the mechanical 
parts  of  the  vehicle.  Another  response  on  ePTI  underlined  that  importance  of  giving 
manufacturers sufficient lead time, if ePTI was implemented, along with there being clear 
definitions of the respective testing methods and inspection criteria. The challenges, and 
expense involved, of inspection services having a “dual plate wheel play detector” was also 
mentioned. It was also suggested that the non-legislative aspects of the PTI legislation had 
had  little  effect.  The  importance  of  there  being  EU-wide  binding  legislation  on  speed 
verification, overloading and uneven axle loading was also mentioned.  

The  importance  of  taking  action  on  tampering  was  also  underlined,  both  in  relation  to 
detecting the tampered system and the correct enforcement of anti-tampering provisions. 
Other  industry  respondents  highlighted  the  general  importance  of  access  to  data, 
particularly in relation to diagnostic devices and connected vehicles, and that the legislation 

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 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

should encourage the use of automation, digitalisation and remote enforcement techniques 
by the inspection authorities. There was a call for vehicles not to be allowed to fail a RSI in 
another  country,  if  they  met  the  PTI  requirements  of  the  country  in  which  they  were 
registered.  A  number  of  respondents  called  for  the  Directive  to  become  a  Regulation, 
although  a  Regulation  could  set  minimum  requirements  that  were  widely  applicable,  but 
which allowed Member States the flexibility to go further, if they desired. On the other hand, 
it was suggested that a Regulation would make the maintenance of the subsidiarity principle 
difficult. Another response suggested that all inspection equipment should be required to 
have “digital network capability” in order to enable the secure transmission of data between 
inspection sites and authorities.  

An additional response from a citizen suggested that electrically assisted bikes should also 
be registered and subject to inspection, as a result of their high speeds. A response from a 
public authority underlined the importance of improved data exchange between Member 
States,  supported  by  increased  digitalisation  and  improved  re-registration  processes. 
Responses from trade unions called for annual inspections for vans after eight years, an 
obligation on manufacturers that a vehicle passes a technical inspection before it obtains 
type  approval  and  for  a  ban  on  the  sale  of  kits  that  owners  can  use  to  tamper  with 
motorcycles.     

A response from an NGO suggested that the interval between PTIs should depend on both 
its  age  and  real  mileage,  and  so  the  latter  needed  to  be  reliable  and  subject  to  an  EU 
framework that set up comparable mileage recording databases in each Member State, and 
which  also  ensured  the  exchange  of  this  information.  Another  response  underlined  the 
importance of having enforceable cargo securing standards in all Member States. On the 
other hand, it was suggested that it was not reasonable to have a compulsory inspection of 
class  I  and  II  mopeds,  given  the  sparsity  of  inspection  facilities  in  some  larger  Member 
States,  and  that  it  should  be  left  to  Member  States  how  to  inspect  L-category  vehicles. 
Several responses also underlined the importance of maintaining the exemptions in relation 
to inspections for historic vehicles.  

Analysis of respondents’ additional contributions 

In  addition,  37  respondents  submitted  additional  contributions,  of  which  one  was 
submitted seven times and two others were submitted twice. 

There were 12 additional contributions from industry representatives, of which three were 
from representatives of the vehicle (and components) manufacturing sector. One of these 
highlighted the need for a sufficient lead time for manufacturers if ePTI was introduced in 
line with the respective ISO standards, along with the need to define the diagnosis target 
performance and function of each ePTI relevant system and the test method and judgement 
criteria. Another called for the regular technical inspection of trailers (O1 and O2) in all EU 
Member States. The third, from the French Fédération Nationale de l’Automobile (FNA), set 
out  a  number  of  issues  that  they  wanted  to  see  addressed  in  a  revision  of  the 
roadworthiness package. First, they called for the re-introduction of more ‘minor failures’ in 
the  different  aspects  of  technical  control,  as  these  were  useful  for  motorists.  In  addition, 
they  supported  the  extension  of  PTI  to  all  M1,  N1  and  L  category  vehicles,  for  the 
standardisation of rules between Member States and for new vehicles to have to pass a 
valid  technical  inspection  as  part  of  its  type  approval  process.  In  addition,  the  FNA 
suggested  that  the  inspection  of  vehicle  emissions  needed  to  be  strengthened  and  that 
better  access  to  relevant  vehicle  data  (including  onboard  data)  was  important  both  for 
inspections and the control of cross-border traffic. Finally, they called for the legislation to 
continue to be a Directive, so as to allow for flexibility at the national level.  

There  were  six  submissions  from  those  responsible  for  vehicle  inspections.  In  their 
respective  responses,  the  International  Motor  Vehicle  Inspection  Committee  (CITA)  and 
testing company DEKRA, further elaborated on their responses to various survey questions, 

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 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

making some similar points. Both called for an end to the possibility to exempt motorcycles 
and  agricultural  tractors  from  the  scope  of  the  PTI  Directive,  with  CITA  noting  that 
agricultural  tractors  were  increasingly  being  used  to  replace  trucks  in  local  transport 
activities.  CITA  also called  for  the  introduction  of  annual  PTIs  for  vehicles  older  than  10 
years  and  for  the  introduction  of  particle  number  counting.  DEKRA  called  for  the 
strengthening  of  the  minimum  standards  for  inspectors’  competence,  training  and 
objectivity,  in  light  of  the  technological  developments  in  vehicles,  and  for  the  full 
digitalisation  of  registration  and  roadworthiness  certificates.  They  also  underlined  the 
importance of PTI methods for checking new safety systems, including driver assistance 
systems and software updates, and for checking vehicles with alternative powertrains, along 
with access to the necessary data in both cases. CITA also called for stronger provisions in 
relation to access to data, although they 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. Both CITA and DEKRA were concerned with the 
resource  implications  of  extending  the  scope  of  vehicles  covered  by  the  TRI  Directive, 
arguing  that  an  extension  might  divert  resources  and  equipment  away  from  the  most 
important vehicles to inspect roadside, i.e. heavy commercial vehicles. Both organisations 
supported the legislation continuing to be Directives, arguing that this provided flexibility in 
a time of rapid technological development.  

The submission from the European Garage Equipment Association (EGEA) underlined the 
importance of extending roadworthiness testing to all road transport vehicles and of possibly 
increasing  the  frequency  of  inspections  for  high  mileage  vehicles.  They  underlined  the 
importance  of  testing  advanced  driving  assistance  systems  (ADAS),  automated  driving 
systems and the emissions of vehicles, and for direct access to in-vehicle data to facilitate 
this. With respect to emissions testing, while noting the importance of OBD, EGEA argued 
that OBDs were not able to detect all defects, so should be used in combination with other 
methods;  they  also  noted  that  there  was  no  easy,  short-term  solution to  measuring  NOx 
emissions.  The  EGEA’s  submission  included  more  detailed  recommendations  and 
requirements  for  the  testing  of  various  components,  such  as  advanced  headlighting 
systems,  a  vehicle’s  suspension  and  air  conditioning,  as  well  as  proposals  for  the 
implementation of ePTI based on the respective ISO standards. Finally, they called for all 
inspection equipment to have digital network capability to enable the secure transmission 
of data between inspection sites and the respective authorities. 

The response from the Austrian Bundesinnung der Fahrzeugtechniker underlined that the 
Roadworthiness  package should  continue  to  meet the  needs  of  different  Member  States 
and continue to ensure that inspections were relatively quick, simple and inexpensive. With 
the need to test more electronic systems, they suggested that the interval between tests 
could  be  shortened,  and  at  the  same  time  underlined  the  importance  of  vehicle  data  in 
roadworthiness testing. They also noted that the implementation of the ePTI Regulation had 
been more difficult than expected, so suggested that some of its more detailed provisions 
could be covered by roadworthiness legislation. Finally, they underlined the importance of 
introducing the OBD as a standard test method, and of testing the high voltage components 
of vehicles with alternative powertrains.     

In  its  submission,  the  European  Safe  Logistics  Association  (EUMOS)  underlined  the 
importance of the harmonised enforcement of the roadworthiness package across the EU 
and stated that they would support the Commission if the latter believed that a Regulation 
was  the  best  way  of  achieving  this.  In  addition,  they  supported  the  digitalisation  of 
roadworthiness information. In relation to cargo safety, they called for the development of a 
mandatory  approach  for  cargo  securing,  supported  by  appropriate  training  and  the 
introduction  of  European  Cargo  Safety  Cards,  both  in  line  with  standards  developed  by 
EUMOS.  

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 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

The additional contribution of the Austrian Chamber of Commerce underlined the support 
that it had provided to many of the questions in the survey. However, they did not believe 
that it was appropriate to include measures to combat odometer fraud in roadworthiness 
legislation, as it was not a matter of the safety or environmental performance of a vehicle. 
In  relation  to  checking  software  updates,  they  called  for  clear  guidelines  and  limits.  In 
addition,  they  did  not  support  either  the  cross-border  recognition  of  PTI  certificates  or 
vehicle  registration  documentation,  arguing  that  the  differences  in  approach  between 
Member  States  were  too  large.  The  submission  from  the  Dutch  Technical  Road 
Transportation Association (TRTA), which was also provided by a Dutch company, called 
for annual mandatory PTI for trailers to be allowed to be undertaken where trailers were 
located  at  the  time  of  the  inspection,  and  the  subsequent  mutual  recognition  of  such 
inspections. This was considered to be important, as having to take trailers back to their 
country of registration for their PTI often caused unnecessary mileage.     

The  single  additional  response  from  a  public  authority,  which  was  from  a  national 
governmental  department,  underlined  the  importance  of  the  PTI  and  TRI  Directives 
continuing  to  provide  Member  States  with  the  flexibility  to  put  shorter  intervals  in  place 
between inspections. In addition, they noted that they did not support the extension of the 
scope of PTI to two- and three-wheeled vehicles in all Member States and that a possible 
extension to agricultural tractors should first be discussed further by Member States and 
subject  to  a  comprehensive  assessment.  They  also  called  for  the  Commission  to  take 
account  of  the  tampering  with  (particularly  the  removal  of)  diesel  particulate  filters,  in 
addition  to  dealing  with  the  tampering  of  odometers,  and  proposed  that  emissions 
measurement systems be used in both PTIs and TRIs. Finally, they expressed their support 
for  the  sharing  of  roadworthiness  data  between  Member  States,  while  noting  that  if  the 
legislation  became  Regulations,  they  should  continue  to  provide  flexibility  for  Member 
States.     

Representatives of user groups and individual users submitted 14 contributions, one of 
which  was  a  repeated  submission.  In  its  policy  position  on  the  revision  of  the 
Roadworthiness legislation, the Fédération Internationale de l'Automobile (FIA) underlined 
that  any  new  measures  introduced  as  part  of  the  revision  should  have  minimal  cost 
implications  for  citizens.  At  the  same  time,  the  FIA  called  for  improvements  to  the 
environmental  monitoring  of  vehicles  (by  introducing  particle  number  counting  and 
continuous in-vehicle NOx monitoring), mandatory PTI checks for the ADAS introduced by 
the  General  Safety  Regulation  (GSR)  and  the  regular  inspection  of  the  high  voltage 
components of battery, hybrid and fuel cell vehicles. In relation to access to data, they called 
for  inspection  bodies  to  have  access  to  relevant  diagnostic  data  and  functions  free  of 
charge, while consumers should be able to choose whether or not they wished to provide 
access to non-mandatory data. Finally, they called on odometer system manipulation to be 
addressed via type approval legislation, rather than the revision of the PTI Directive. The 
Oesterreichischer Automobil Motorrad und Touring Club reiterated FIA’s position. 

The German Allgemeiner Deutscher Automobil Club (ADAC) also called for the inspection 
of the ADAS introduced by the GSR as part of PTI, as well as for shorter periods between 
testing for high mileage vehicles. On the other hand, ADAC believed that PTIs for electric 
scooters and separate measurements for NOx in PTI were not necessary. The Royal Dutch 
Touring Club (ANWB) called for more methods to test electrical safety and ADAS in TRIs 
and for drivers to be made aware of the implications if they turned these systems off. On 
the other hand, they called for more research on whether the checking of ADAS in PTIs was 
justified and also for more research into phantom braking, where ADAS applies the brakes 
for  no  apparent  reason.  Overall,  they  called  for  a  greater  harmonisation  of  PTI  and  TRI 
across  Europe  and  the  exploration  of  ePTI,  while  underlining  that  they  were  concerned 
about the potential increased costs to users of more checks.  

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 Impact Assessment Support Study on the Directives of the Roadworthiness Package 

The  submission  from  the  Federation  of  European  Motorcyclists’  Associations  (FEMA) 
underlined that they were not able to support the extension of PTI to motorcycles, arguing 
instead that studies showed that the technical condition of motorcycles played a very small 
role in accidents involving motorcycles. They argued that a Commission study on this topic 
used data from only one country, which could not be extrapolated across the EU. In addition, 
they noted that in the EU’s more sparsely populated countries, it was not practical to have 
regular  PTIs  for motorcycles due  to the  distances  involved  in travelling  to the respective 
inspection centres. Similar points were made in a submission from the Fédération Française 
des Motards en Colère (FFMC) and in other submissions from users. The two submissions 
from representatives of the owners of historic vehicles, the  Fédération Internationale des 
Véhicules  Anciens  (FIVA)  and  an  NGO  made  the  same  points.  They  both  called  on  the 
current definition of an historic vehicle to be maintained and that Member States be allowed 
to continue to exempt historic vehicles from the provisions of the PTI Directive. The Sveriges 
MotorCyklister (SMC) submitted a reasoned opinion of the Swedish Riksdag that noted that 
the body considered that the proposed extension of PTI to mopeds and historic vehicles 
was too far-reaching and not in line with the principle of subsidiarity. 

In  its  submission,  the  NGO  European  Transport  Safety  Council  (ETSC)  included 
recommendations for the revision to both the PTI and TRI Directives. In general for cars 
and light commercial vehicles, they called for the greater harmonisation of PTIs, with the 
first  PTI  four  years  after  registration  (and  then  every  two  subsequent  years),  although 
suggested that consideration be given to annual (or distance-based) inspections for high 
mileage vehicles. They also called for the mandatory extension of PTI to all motorcycles, 
including mopeds, at the same frequency as for cars. ETSC also wanted the actual PTI to 
cover  eCall,  new  in-vehicle  safety  systems  and  intelligent  speed  adaptation  systems  (to 
ensure that their detection capabilities were still satisfactory). The importance of ensuring 
that  PTIs  checked  that  vehicles  had  the  latest  software  correctly  installed,  as  well  as  to 
confirm that the software was original and type approved, was also underlined, as was the 
importance  of  checking  that  all  of  the  manufacturer’s  over-the-air  software  updates  had 
been implemented correctly. They also called for automated vehicles to be regularly tested 
to ensure their safety performance. In relation to the TRI Directive, ETSC called for action 
to improve the quality of the tests, and for their extension to light commercial vehicles. They 
also called for the development of harmonised minimum requirements for cargo securing 
and  harmonised  training  for  personnel  involved  in  cargo  securing.  The  Austrian  Federal 
Chamber of Labour (BAK) submitted a study on the manipulation of exhaust gases in trucks. 

A  repeated  submission  from  seven  Slovak  respondents  (ranging  from  companies  to 
individuals)  set  out  in  detail  the  changes  they  wanted  to  see  in  the  roadworthiness 
legislation.  They  called  for  Member  States  to  be  continued  to  be  allowed  to  maintain  a 
vehicle inspection system that could be split between a technical inspection of a vehicle’s 
safety systems and an inspection focusing on the vehicle’s emission control system, as well 
as allowing Member States to set different timescales for these. In their view, there should 
be  mandatory  testing  of  the  electronic  systems  relating  to  a  vehicle’s  emissions  from 
Euro5/VI  vehicles  onwards,  as  well  as  of  the  various  emission  reduction  systems 
themselves.  They  also  called  for  new  limits  in  PTIs  for  carbon  monoxide  for  Euro  6/VI 
vehicles and above, hydrocarbons for Euro 4/IV vehicles and above and smoke for Euro 
6/VI vehicles and above. For Euro 6/VI vehicles and above, they also called for greater in-
vehicle control and a visual check of the AdBlue system. Finally, they called for there to be 
an obligation in a PTI to provide proof of the actual presence of the vehicle at the PTI and 
also proof of its registration in relevant electronic information platforms.  

Directorate-General for Mobility and Transport 
IA for revision of the RWP 

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doi: 10.2832/8855617