COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND THE COUNCIL amending Regulations (EC) No 561/2006, (EU) 2018/858, (EU) 2019/2144 and (EU) 2024/1257 of the European Parliament and of the Council as regards the simplification of technical requirements and testing procedures for motor vehicles and repealing Council Directive 70/157/EEC and Regulation No 540/2014 of the European Parliament and of the Council
Date: 2025-12-16
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: European standard, approval, carbon neutrality, electricity storage device, market supervision, motor vehicle, motor vehicle industry, safety standard, sustainable mobility, technical standard

EN 

  EN 

   EUROPEAN COMMISSION  Strasbourg, 16.12.2025  SWD(2025) 1056 final  COMMISSION STAFF WORKING DOCUMENT         Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND THE COUNCIL amending Regulations (EC) No 561/2006, (EU) 2018/858, (EU) 2019/2144 and (EU) 2024/1257 of the European Parliament and of the Council as regards the simplification of technical requirements and testing procedures for motor vehicles and repealing Council Directive 70/157/EEC and Regulation No 540/2014 of the European Parliament and of the Council          {COM(2025) 993 final}  
 
 
1. 

Introduction ..................................................................................................... 3 

2.  EU automotive regulatory framework ............................................................. 5 

3.  Main issues and ways to address them ............................................................ 6 

3.1.  Regulation  (EC)  No 561/2006  on  the  harmonisation  of  certain  social 
legislation relating to road transport, and Regulation (EU) No 165/2014 
on tachographs in road transport ........................................................... 6 

3.1.1.  Tachograph obligations for electric vans in domestic transport 
with a weight between 3.5 tonnes and 4.25 tonnes ................. 7 

3.1.2.  Tachograph  obligations  for  motor  caravans  used  exclusively 
for non-commercial carriage by road .................................... 11 

3.2.  Regulation  (EU) 2019/2144  on type-approval  requirements for motor 
vehicles  and  their  trailers,  and  systems,  components  and  separate 
technical units intended for such vehicles, as regards their general safety 
and the protection of vehicle occupants and vulnerable road users .... 13 

3.2.1.  Speed-limiting  device  obligation  for  e-Vans  with  a  weight 
between 3.5 tonnes and 4.25 tonnes ...................................... 14 

3.3.  Regulation  (EC)  2024/1257  on  type-approval  of  motor  vehicles  and 
engines  and  of  systems,  components  and  separate  technical  units 
intended for such vehicles, with respect to their emissions and battery 
durability (Euro 7) ............................................................................... 17 

3.3.1.  Laboratory test of low temperature for emissions in light-duty 
vehicles .................................................................................. 18 

3.3.2.  Vehicle  types  for  Euro  7  engine  (Separate  Technical  Unit) 
type-approval ......................................................................... 21 

3.3.3.  OBM and OBFCM data infrastructure and common methods
 ............................................................................................... 25 

3.4.  Regulation (EC) 540/2014 on the sound level of motor vehicles and of 
replacement silencing systems ............................................................ 29 

3.4.1.  Misalignment with UN Regulations on noise ....................... 29 

3.5.  Regulation (EU) 2018/858 on the approval and market surveillance of 
motor  vehicles  and  their  trailers,  and  of  systems,  components  and 
separate technical units intended for such vehicles ............................. 30 

3.5.1.  New vehicle subcategory for small cars ................................ 31 

3.5.2. 

Improving electric vehicle to grid interoperability ................ 32 

4.  Further simplification measures to be considered outside the Omnibus ....... 34 

4.1.  Grouping  all  new  regulatory  requirements  into  batches,  becoming 
mandatory at the same time to ease compliance for manufacturers and 
reduce homologation costs .................................................................. 34 

4.2.  Respecting lead time for industry between the adoption of regulations 
and the application dates ..................................................................... 35 

4.3.  Applying new regulatory requirements for new types of vehicles only 
and not vehicles already type-approved .............................................. 35 

 
 
4.4.  Simplifying the type-approval framework .......................................... 35 

Consideration of further specific simplification measures ............................ 36 

4.5.  Type-approval framework for electric trucks with range extenders.... 36 

4.6.  Direct vision requirement for trucks .................................................... 36 

4.7. 

In-service CO2 verification ................................................................. 37 

5.  Conclusions ................................................................................................... 37 

Annex I: Methodology and evidence collected ..................................................... 40 

Annex II: Organisations that were consulted as part of the stakeholder consultation
 ....................................................................................................................... 40 

2 

 
 
 
 
 
 
 
 
 
 
1. 

INTRODUCTION 

The  automotive  value  chain  is  a  pillar  of  the  EU  economy,  accounting  for  EUR  589.3 
billion and 3.7% of total value added of Europe’s GDP , and direct employment of  10.6 
million Europeans (1). In the context of Europe’s twin transition towards climate neutrality 
and  digital  transformation  and  the  increasingly  unpredictable  trade  environment, 
maintaining a robust and competitive automotive industry is essential for safeguarding the 
EU’s strategic autonomy and global economic standing. 

The analysis included in the recent reports of Enrico Letta (2) and Mario Draghi (3) places 
the reduction of regulatory burden and the simplification of EU legislation among the top 
priorities.  While  the  existing  regulatory  framework  brings  predictability  and  helps  to 
achieve the EU’s public policy objectives, it should, however, not put undue burden and 
unjustified costs on industry.  

In  her  political  guidelines  for  the  European  Commission’s  2024–2029  mandate  (4), 
President von der Leyen outlined a vision focused on driving sustainable prosperity and 
strengthening  competitiveness  across  Europe,  emphasising  the  need  to  make  doing 
business faster and easier. Central to this vision are simplifying regulation and reducing 
regulatory burdens to create a more competitive and attractive Europe. The Commission 
has set a target to reduce administrative burden by at least 25% for businesses and by 35% 
for SMEs by 2029. (5) 

As part of this work, the Commission adopted the Competitiveness Compass in January 
2025 (6)  and  the  Clean  Industrial  Deal  in  February  2025 (7).  In  line  with  the  agenda  to 
simplify,  the  Industrial  action  plan  for  the  European  automotive  sector (8),  adopted  in 
March 2025, stated that the Commission in consultation with stakeholders would develop 
a regulatory simplification package for the automotive industry by improving coherence 
and  consistency  between  different  regulatory  requirements.  This  is  part  of  the 
Commission’s efforts to improve the business environment for the European automotive 
industry. 

The Automotive Omnibus forms part of a wider package of measures aimed at simplifying 
the  EU’s  automotive  regulatory  framework.  The  simplification  agenda  will  be  carried 

(1)  Figures  based  on  Eurostat  FIGARO  data:  https://ec.europa.eu/eurostat/web/esa-supply-use-input-

tables/information-data#figaro 

(2)  E. 

Letta, 

Much 

available 
https://www.consilium.europa.eu/media/ny3j24sm/much-more-than-a-market-report-by-enrico-
letta.pdf 
(3)  M.  Draghi, 

competitiveness, 

European 

market, 

future 

2024, 

2024, 

more 

than 

The 

available 

of 

a 

at: 

at: 

https://commission.europa.eu/topics/eu-competitiveness/draghi-report_en#paragraph_47059, p. 18. 

(4)  Political Guidelines for the next European Commission 2024-2029, available at: 

https://commission.europa.eu/document/download/e6cd4328-673c-4e7a-8683-f63ffb2cf648_en  
(5)  A  simpler  and  faster  Europe:  Communication  on  implementation  and  simplification,  available  at: 
https://www.europarl.europa.eu/RegData/docs_autres_institutions/commission_europeenne/com/2025/
0047/COM_COM(2025)0047_EN.pdf 

(6)  Communication:  A  Competitiveness  Compass  for  the  EU  (COM(2025)  30  final),  available  at: 

https://commission.europa.eu/topics/eu-competitiveness/competitiveness-compass_en  

(7)  Communication: The Clean Industrial Deal: A joint roadmap for competitiveness and decarbonisation 
(COM(2025)  85  final),  available  at:  https://commission.europa.eu/topics/eu-competitiveness/clean-
industrial-deal_en  

(8)  Communication:  Industrial  action  plan  for  the  European  automotive  sector  (COM(2025)  95  final), 
https://transport.ec.europa.eu/document/download/89b3143e-09b6-4ae6-a826-

available 
at: 
932b90ed0816_en  

3 

 
 
 
 
 
 
forward when evaluating the type-approval framework regulation in 2026, when preparing 
secondary legislation for motor vehicles, in the parallel proposal for a revision of the CO2 
performance standards for cars and vans and in upcoming reviews, such as the one for CO2 
performance standards for heavy-duty vehicles. 

A  smarter  approach  to  regulation  –  one  that  removes  redundant  requirements,  avoids 
duplication, and ensures consistency – will help unlock the full potential of the automotive 
industry  as  a  driver  of  sustainable  European  prosperity,  without  compromising  social 
rights,  road  safety,  and  the  environment.  This  simplification  exercise  will  also  deliver 
tangible savings to SMEs and large companies. 

Process for identifying amendments for this Omnibus  

At the beginning of 2025 the Commission announced that it would organise the Strategic 
Dialogue  on  the  Future  of  the  European  Automotive  Industry  with  European  industry 
leaders, social partners, and stakeholders. The Commission received position papers from 
stakeholders  before  and  after  the  Dialogue  that  took  place  on  30  January  2025,  which  
highlighted  their  request  for  a  simplification  of  the  automotive  regulatory  framework. 
These initial industry contributions were of a general nature and thus cannot be taken up 
in the context of a legislative omnibus proposal, but are discussed further in section 4.  

This  was  followed  up  by  several  bilateral  exchanges  as  well  as  concrete  simplification 
suggestions  from  industry associations  and individual  companies. These  exchanges  and 
the  targeted  stakeholder  consultation  led  to  a  number  of  potential  amendments  being 
proposed by stakeholders.  

On that basis, a preliminary number of simplification measures was put for discussion in 
the Motor Vehicle Working Group, a Commission expert group made up of Member State 
representatives and a broad range of stakeholders from the automotive industry and civil 
society.  

Finally,  the Commission  launched a targeted stakeholder  consultation  in  October 2025. 
This  survey  was  sent  to  over  130  stakeholders  (68  replies)  of  the  automotive  industry, 
comprising  vehicle  manufacturers,  automotive  component  manufacturers,  industry 
associations, NGOs, fleet operators, national type approval authorities, market surveillance 
authorities and other relevant national authorities.. 

The  Commission  applied  the  following  criteria  to  determine  which  measures  would  be 
included:  

•  The simplification measures must improve the coherence and consistency of the 

automotive regulatory framework; 

•  The simplification measures are limited to automotive-specific requirements (i.e., 
no changes to EU legislation with a scope beyond the automotive sector); (9)  

(9)  Many  regulatory  requirements  and  reporting  obligations  to  which  the  automotive  industry  is  subject 
stem from regulations that are not automotive-specific, such as the Battery Regulation, the Deforestation 
Regulation, the Renewable Energy Directive, the Waste Framework Directive, the Data Act, the AI Act 
etc.  Such  regulations  are  outside  the  scope  of  this  Automotive  Omnibus  but  are  addressed  where 
appropriate  in  other  Omnibus  proposals  (e.g.,  Chemicals  Omnibus,  Environmental  Omnibus,  Digital 
Omnibus) 

4 

 
 
 
 
 
 
 
  
 
•  The simplification measures  are limited to  changes that cannot  be done  through 

secondary legislation, as the Omnibus is directed at primary legislation; 

•  The  simplification  measures  must  demonstrate  a 

tangible  reduction 

in 

administrative burden and/or cost savings;  

•  The simplification measures have no negative social, environmental, or economic 

impact.  

On the basis of these criteria, nine proposed amendments were retained for the Automotive 
Omnibus.  These  proposals  are  described  in  detail  in  section  3.  Possible  further 
simplification measures beyond the Automotive Omnibus are described in section 4. 

2.  EU AUTOMOTIVE REGULATORY FRAMEWORK  

The EU’s automotive regulatory framework is designed to ensure vehicle safety, security, 
environmental  protection,  and  the  coherence  of  the  single  market.  The  type-approval 
system, laid out in Regulation 2018/858, (10) is a procedure where an authority in an EU 
Member State certifies that a vehicle model, system, or component meets all relevant EU 
safety, environmental, and technical requirements before it can be sold, registered, or put 
into  service  in  the  EU.  Once  approved  in  one  Member  State,  the  approval  is  valid 
throughout the entire EU, allowing for the free movement of the approved products within 
the single market.  

The type-approval system is underpinned by Regulation 2019/2144 (the General Safety 
Regulation, ‘GSR’). (11) The (GSR mandates advanced safety technologies in new vehicles 
to  reduce  road  deaths  and  serious  injuries.  It  requires  manufacturers  to  fit  a  range  of 
features, such as automated emergency braking and lane keeping systems, to all new cars, 
vans, trucks, and buses sold in the EU.  

The  environmental  performance  of  vehicles  sold  in  the  EU  is  regulated  by  Regulation 
2024/1257  (‘Euro  7’). (12)  This  regulation  sets  maximum  levels  for  pollutant  emissions 
during the lifetime of vehicles and includes limits for emissions from brakes and tyres, as 
well as requirements for the battery durability of electric vehicles. 

In  addition,  the  EU’s  legal  framework  for  vehicles  also  covers  specific  type-approval 
regulations for noise and for eCall, an in-vehicle emergency call system that automatically 
dials Europe's single emergency number, 112, after a serious road accident.  

United  Nations  (UN)  Regulations  play  an  important  role  in  the  EU’s  type-approval 
framework. The World Forum for the Harmonization of Vehicle Regulations (WP.29) is a 
permanent working party in the institutional framework of the United Nations that adopts 
globally  harmonised  technical  regulations  on  vehicle  safety  and  environmental 
performance. In WP.29, the European Union votes based on a Council Decision on new 

(10)  Regulation  (EU)  2018/858  of  the  European  Parliament  and  of  the  Council  of  30  May  2018  on  the 
approval and market surveillance of motor vehicles and their trailers, and of systems, components and 
separate technical units intended for such vehicles 

(11)  Regulation (EU) 2019/2144 of the European Parliament and of the Council of 27 November 2019 on 
type-approval requirements for motor vehicles and their trailers, and systems, components and separate 
technical units intended for such vehicles, as regards their general safety and the protection of vehicle 
occupants and vulnerable road users 

(12)  Regulation (EU) 2024/1257 of the European Parliament and of the Council of 24 April 2024 on type-
approval  of  motor  vehicles  and  engines  and  of  systems,  components  and  separate  technical  units 
intended for such vehicles, with respect to their emissions and battery durability (Euro 7) 

5 

 
 
 
 
UN  regulations  and  amendments  to  UN  Regulations.  The  majority  of  type-approval 
requirements in the EU directly refers to harmonised UN regulations. The links between 
UN regulations and EU regulations allow manufacturers to access both EU and non-EU 
markets thanks to a harmonised set of regulatory requirements.   

The automotive industry is also subject to CO2 emission standards. The EU has adopted 
CO2  emission  performance  standards  for  new  cars  and  new  light  commercial  vehicles 
under  Regulation  2019/631,  which  mandates  that  the  average  emission  level  of  these 
vehicles be zero from 2035. (13)  A proposal for a revision of the Regulation is presented 
in parallel to the Automotive Omnibus. Lorries and buses are subject to the CO2 standards 
for heavy-duty vehicles, which will be reviewed in 2027. 

The automotive industry is also impacted directly or indirectly by certain rules governing 
the EU internal market for commercial road transport. These include rules on maximum 
weights  and  dimensions  of  vehicles (14),  or  rules  on  on-board  vehicle  units  aimed  at 
supporting the enforcement of the internal market for road transport and enhancing road 
safety, such as the tachograph and speed limitation devices for heavy duty vehicles. 

Other pieces of legislation outside the automotive sector apply to motor vehicles, including 
the Data Act, the Artificial Intelligence Act, the REACH Regulation, and the Renewable 
Energy Directive. (15)  

3.  MAIN ISSUES AND WAYS TO ADDRESS THEM 

3.1.  Regulation  (EC)  No 561/2006  on  the  harmonisation  of  certain  social 
legislation relating to road transport, and Regulation (EU) No 165/2014 
on tachographs in road transport 

Regulation (EC) No 561/2006 lays down rules on driving times, breaks, and rest periods 
for drivers of vehicles engaged in the carriage by road of goods or passengers: Its objective 
is  to  ensure  fair  competition  among  road  transport  operators,  to  improve  working 
conditions of drivers, and to contribute to road safety. 

To check that the rules on driving times and rest periods are adhered to, some categories 
of vehicles are required to have a tachograph. The manufacture, installation, and use of the 
tachograph is regulated by Regulation (EU) No 165/2014. Vehicles registered in the Union 
and  falling  in  the  scope  of  Regulation  (EC)  No 561/2006  must  be  equipped  with  a 
tachograph, per Article 3(1) of Regulation (EU) No 165/2014.   

(13)  Regulation (EU) 2019/631 of the European Parliament and of the Council of 17 April 2019 setting CO2 

emission performance standards for new passenger cars and for new light commercial vehicles 

(14)  Council Directive 96/53/EC of 25 July 1996 laying down for certain road vehicles circulating within the 
Community the maximum authorized dimensions in national and international traffic and the maximum 
authorized weights in international traffic 

(15)  Regulation (EU) 2023/2854 of the European Parliament and of the Council of 13 December 2023 on 
harmonised  rules  on  fair  access  to  and  use  of  data  (Data  Act);  Regulation  (EU)  2024/1689  of  the 
European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial 
intelligence (Artificial Intelligence Act); Regulation (EC) No 1907/2006 of the European Parliament 
and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and 
Restriction  of  Chemicals  (REACH),  establishing  a  European  Chemicals  Agency;  Directive  (EU) 
2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the 
use of energy from renewable sources 

6 

 
 
 
These regulations apply to vehicles that exceed 3.5 tonnes in mass (including any trailer 
or semi-trailer) where the vehicle is used for road transport. The regulations equally apply 
to vehicles above 3.5 tonnes in mass that are used to carry more than nine people (including 
the driver).  

From  1  July  2026  smart  tachographs  must  be  installed  in  Light  Commercial  Vehicles 
(LCVs) (i.e., vans, light trucks, or pick-up trucks with mass less than 3.5 tonnes) engaged 
in the international carriage of goods, unless the goods are for the driver’s own use. 

Any vehicle under 7.5 tonnes in  mass that is  not  used for commercial road transport is 
exempt from these regulations, per Article 3(h) of Regulation (EC) No 561/2006.  

Article 13 of Regulation (EC) No 561/2006 provides that “each Member State may grant 
exceptions from [driving times, breaks and rest periods rules]” to certain vehicles which 
are  identified,  either  by  their  use-case  (e.g.,  13(1o)  vehicles  used  exclusively  on  roads 
inside hub facilities such as ports, interports and railway terminals), or by a combination 
of the use case and their technical characteristics (e.g., 13(1i) vehicles with between 10 and 
17 seats used exclusively for the non-commercial carriage of passengers). An exception is 
also already available for “vehicles used for the carriage of goods within a 100 km radius 
from the base of the undertaking and propelled by means of natural or liquefied gas or 
electricity,  the  maximum  permissible  mass  of  which,  including  the  mass  of  a  trailer  or 
semi-trailer, does not exceed 7.5 tonnes”. These exceptions can also apply cross-border 
“with the agreement of the States concerned.” 

3.1.1. 

Tachograph obligations for electric vans in domestic transport with 
a weight between 3.5 tonnes and 4.25 tonnes 

Issue description  

Electric vans (also called LCVs) with a maximum permissible mass exceeding 3.5 tonnes 
and not exceeding 4.25 tonnes must have a tachograph installed unless they are not used 
for commercial road transport, in accordance with Regulation (EU) No 165/2014.  

Although they have the same payload as a combustion engine van, electric vans are heavier 
as a result of their batteries. This additional weight, which pushes them over the 3.5 tonne 
threshold  of  Regulation  (EC)  No 561/2006,  means  that  they  must  be  equipped  with  a 
tachograph  and  that  their  drivers  must  follow  the  rules  on  driving  times  and  rest.  As  a 
result,  they  suffer  from  a  competitive  disadvantage  vis-a-vis  combustion  engine  vans 
(which are usually classed as N1, while the electric vans are classed as N2 owing to the 
added  weight  of  their  batteries),  rendering  them  less  attractive  to  customers--many  of 
whom  are  SMEs--due  to  the  costs  involved  in  installing  and  using  a  tachograph. 
Furthermore, for SMEs there is an additional administrative burden involved in having the 
tachograph in that they must organise and record their drivers’ working times according to 
the rules on driving times and rest periods. 

According to original equipment manufacturers (OEMs), this additional burden hampers 
the uptake of electric vans compared to similar combustion engine vans, which can result 
in increased difficulty for OEMs to reach CO2 performance targets for vans. To reach the 
EU’s target to have 100% zero-emission vans and cars in 2030, approximately 17% of van 

7 

 
sales  in  2025  need  to  be  zero-/low-emission. (16)  According  to  industry  data,  zero-  and 
low-emission vans sold in 2024 amounted to only 8.1% of sales, meaning that reaching the 
2025 target will be difficult. (17)  

This issue has also been recognised and considered in the recent revision of the EU Driving 
Licence Directive (18), whereby a category B licence will be valid two years after it was 
issued for the first time for vehicles with a maximum authorised mass exceeding 3.5 tonnes 
but not exceeding 4.25 tonnes. 

Stakeholder views  

Stakeholders from OEMs, trade associations, civil society, type-approval authorities, and 
market  surveillance  authorities  raised  the  requirement  for  smart  tachographs  in  e-Vans 
with a gross vehicle weight (GVW) between 3.5 tonnes and 4.25 tonnes as an inconsistency 
vis-a-vis  their  fossil  fuel  equivalent.  As  one  market  surveillance  authority  noted,  “the 
adjustments to the regulations could make the relevant vehicle models more attractive on 
the market and lead to a greater increase in the proportion of electric commercial vehicles,” 
thus contributing to the decarbonisation of road transport.  

The proposed amendment was perceived by stakeholders during the targeted stakeholder 
consultation to have a positive impact on administrative burden (33 out of 43 responses, 
others  “N/A”),  a  positive  impact  on  the  environment  (31  out  of  41  responses,  others 
“N/A”), and a positive social impact (23 out of 33 responses, others “N/A”).   

In addition, OEMs and a broad range of stakeholders, including fleet operators, mentioned 
that eliminating tachographs in e-Vans would save time and costs, as drivers of such vans 
are required to comply with reporting obligations related to driving times and rest and fleet 
operators must keep records of their drivers' activities and organise the work of their drivers 
to  meet  the  rest  requirements.  Civil  society  organisations  were  largely  in  favour  of 
removing  the  smart  tachograph  obligation  as  it  would  bring  down  the  costs  of  e-Vans 
vehicles, facilitating their deployment and therefore positively impacting the environment.  

One stakeholder mentioned that removing the obligation to have smart tachograph devices 
in  e-Vans  between  3.5  and  4.25  tonnes  would  have  a  positive  impact  on  the  current 
shortage  of  qualified  drivers,  who  otherwise  need  to  have  extended  driving  training  to 
operate smart tachographs.  

(16)  Fit 

for  55:  zero  CO2  emissions 

for  new  cars  and  vans 

in  2035,  available  at: 

https://www.europarl.europa.eu/news/en/press-room/20230210IPR74715/fit-for-55-zero-co2-
emissions-for-new-cars-and-vans-in-2035  

(17)  New commercial vehicle registrations: vans +8.3%, trucks -6.3%, buses +9.2% in 2024, available at: 
https://www.acea.auto/cv-registrations/new-commercial-vehicle-registrations-vans-8-3-trucks-6-3-
buses-9-2-in-
2024/#:~:text=New%20EU%20electrically%20chargeable%20bus%20registrations%20rose,growth%
20of%20161.7%25%2C%20while%20Spain%20increased%20by  

(18)  DIRECTIVE  (EU)  2025/2205  OF  THE  EUROPEAN  PARLIAMENT  AND  OF  THE  COUNCIL  of 
22 October 2025 on driving licences, amending Regulation (EU) 2018/1724 of the European Parliament 
and of the Council and Directive (EU) 2022/2561 of the European Parliament and of the Council, and 
repealing  Directive  2006/126/EC  of  the  European  Parliament  and  of  the  Council  and  Commission 
Regulation (EU) No 383/2012. 

8 

 
 
Accordingly, a simplification of the regulatory framework is considered both timely and 
necessary to facilitate the transition towards zero-emission mobility.  

Proposed amendment 

The  proposed  amendment  is  to  allow  Member  States  to  exempt  e-Vans  with  GVWs 
between 3.5 tonnes and 4.25 tonnes engaged exclusively in domestic transport from the 
obligation to install smart tachographs, thereby putting them on equal footing with their 
fossil fuel equivalent with the same payload.  

Therefore, the Commission proposes a new point (fa) in Article 13(1) of Regulation (EC) 
No 561/2006: 

‘(fa) vehicles used for the carriage by road of goods and propelled by means of 
electricity, the maximum permissible mass of which, including the mass of a trailer 
or semi-trailer, exceeding 3.5 tonnes but does not exceed 4.25 tonnes’; 

Expected impact  

The expected impact includes cost savings for road operators that will no longer have to 
pay for the purchase and installation of smart tachographs for e-Vans. The operators will 
benefit from the regulatory simplification thanks to the reduction in administrative burden 
linked to the smart tachograph (reporting requirements, organising drivers’ working time, 
etc.).  The  domestic  commercial  transport  sector  is  composed  primarily  of  SMEs  and 
microenterprises, many of which have only a few vehicles at their disposal and for which 
the tachograph represents an additional administrative burden. This measure will have a 
positive impact on simplifying SMEs’ operations compared to the current situation.  

The measure is expected to have no impact on road safety, as the equivalent fossil fuel van 
is  already exempt from  the smart  tachograph requirement.  It  is  also  expected to  have  a 
positive social impact, according to stakeholders, by reducing administrative burden. 

In addition, levelling the playing field between diesel vans and e-Vans that have the same 
payload  and  use-case  by  removing  the  costs  linked  to  the  installation  and  use  of  the 
tachograph  could  help  stimulate  the  uptake  of  such  e-Vans.  According  to  one  OEM’s 
market  data,  sales  could  increase  up  to  3.5x  if  the  smart  tachograph  obligation  was 
removed, with positive environmental effects in line with the EU’s CO2 regulation’s target 
of 100% zero-emission cars and vans by 2035.  

Currently, the scope of Regulations (EC) No 561/2006 and (EU) No 165/2014, which aim 
to improve the working  conditions of drivers, ensure fair competition among operators, 
and improve road safety, is determined for the carriage by road of goods primarily by the 
maximum permissible mass of the vehicle, with the result that the weight of the battery 
powering the vehicle determines whether the driver of the vehicle should be subject to EU 
rules on driving times and rest rules, and therefore the rules on the use of the tachograph. 
The scope of this amendment is limited to levelling the playing field between combustion 
engine  vans  and  electric  vans  vis-à-vis  tachograph  installation  by  allowing  national 
authorities to exempt electric vans from such rules. 

Moreover, this amendment proposal does not impact the objectives and agreement between 
the European Parliament and the Council of 2020 (Regulation (EU) 2020/1054, ‘Mobility 
Package 1’),  whereby vehicles engaged in  the carriage by road of goods  exceeding  2.5 
tonnes and engaged in international road transport or cabotage will be subject to the rules 

9 

 
 
  
on driving times and rest  periods, and the installation and use of the smart tachograph, 
from 1 July 2026. 

Impact per type (+ positive; - negative; o neutral)  

Environmental 

Safety  

Social 

+ 

o 

+ 

Cost savings for Businesses (Large companies and SMEs) 

The exemption of e-Vans with GVW between 3.5 and 4.25 tonnes from the obligation to 
have tachographs installed is expected to relieve the EU automotive industry of significant 
recurrent costs. The cumulative savings of the measure in the period between 2027 and 
2029  lie  between  EUR  629  million  (lower-bound  estimate19)  and  EUR  2203  million 
(upper-bound  estimate  20)  (see  Table  1),  with  the  upper-bound  estimate  based  on  sales 
increasing 3.5x in response to the removal of the smart tachograph. The savings are likely 
to be passed on to customers, with 78% of those savings going to SMEs and 22% going to 
large companies (21). 

Table 1 - Estimated Savings from Tachograph Exemption for e-Vans with GVW between 3.5t and 
4.25t 
Annual Savings  

2027 

2028 

2029 

Cumulative 
savings 
through 2029 

(in 
Euro) 

million 

Lower-bound 
Estimate 
(Adjustment 

117 

159 

208 

485 

(378 for SMEs) 

(19)  The “lower-bound estimate” of annual adjustment cost savings has been calculated using annual sales 
projections of electric light commercial vehicles (eLCV, or e-Vans) in the Bloomberg NEF database 
Electric Vehicle Sales, with the share of each year’s affected eLCVs estimated at 14% (Source: industry 
stakeholder).  Multiplying  these  two  figures  yields  the  number  of  affected  eLCVs  for  each  of  the 
following years: 2027: ~60000 affected eLCVs; 2028: ~78000 affected eLCVs; 2029: ~97000 affected 
eLCVs. Multiplying this sales estimate of exempted eLCVs with the cost savings per device yields the 
annual  “lower-bound  estimate”  for  cost  savings  presented  in  Table  1.  The  following  device  cost 
estimates were used: an average cost of EUR 1600 per tachograph device, installation costs of EUR 250 
(Source: 
(Source: 
) 
https://op.europa.eu/en/publication-detail/-/publication/77e544e8-8e4e-11ec-8c40-01aa75ed71a1 
Moreover, to quantify the administrative costs related to the handling of the tachograph, the following 
assumptions were used: operation of a tachograph requires 50 minutes per month, i.e., 10 hours per year 
(source:  tachograph  manufacturer)  and  an  average  hourly  labour  cost  in  the  transport  sector  of  EUR 
29.20 (Source: [lc_lci_lev] Labour cost levels by NACE Rev. 2 activity). 

stakeholders), 

calibration 

of  EUR 

industry 

annual 

costs 

100 

(20)  The “upper-bound estimate” is calculated using the amount that e-Van sales would increase by removing 
the smart tachograph requirement, estimated to be 3.5 times (Source: Industry stakeholder projection). 

(21) Share estimate based on Eurostat data of the share of SMEs and large companies operating in freight 
(Source: 

transport 
https://ec.europa.eu/eurostat/databrowser/view/sbs_sc_ovw__custom_18691566/bookmark/table?lang
=en&bookmarkId=f9acb0b4-6c19-495f-8c21-8a9bfffe96a8&c=1761901818000 ) 

removal 

services 

road 

and 

by 

10 

 
 
 
 
Cost 
Savings(22)) 

Lower-bound 
Estimate 
(Administrative 
Cost 
Savings(23)) 

TOTAL 
ANNUAL 
SAVINGS 
(lower-bound 
estimate) 

Higher-bound 
Estimate 
(Adjustment 
Cost Savings) 

Higher-bound 
Estimate 
(Administrative 
Cost Savings) 

TOTAL 
ANNUAL 
SAVINGS  
(higher-bound 
estimate) 

17 

40 

86 

144 

(113 for SMEs) 

134 

199 

294 

629 

(491 for SMEs) 

410 

557 

730 

1698 

(1324 for SMEs) 

61 

142 

302 

0505 

(394 for SMEs) 

471 

699 

1032 

2203 

(1718 for SMEs) 

* Differences between the cumulative amounts and the sum of the three years are due to rounding. 

3.1.2. 

Tachograph  obligations  for  motor  caravans  used  exclusively  for 
non-commercial carriage by road 

Issue description  

National divergences exist on whether large motorhomes (greater than 7.5 tonnes) need a 
tachograph installed. In case C-666/21, the Swedish authorities asked the Court to clarify 
whether Regulation (EC) No 561/2006 on driving times and rest rules applied to the drivers 
of such motorhomes. The Court ruled that the “the notion of ‘carriage by road of goods’, 
[…] covers carriage by road by a vehicle whose maximum permissible mass, within the 
meaning  of  Article 4(m)  of  Regulation  No 561/2006,  as  amended,  exceeds  7.5 tonnes, 
including where it is fitted out not only as a temporary private living area but also for the 

(22) Adjustment cost: costs of complying with substantive requirements in regulation, other than charges and 
administrative costs. The costs classified under adjustment costs are: tachograph device, installation cost 
of tachograph, calibration cost of tachograph. 

(23)  Administrative costs: costs of complying with the administrative requirements imposed by regulation. 
Commercial  drivers  must  regularly  spend  time  operating  the  tachograph  which  subtracts  from  their 
working time. Therefore, the cost listed under administrative costs is the labour cost for the time spent 
by the driver handling the tachograph in place of other work. 

11 

 
 
 
non-commercial loading of goods, without that vehicle’s cargo capacity or the category in 
which it appears in the national road traffic register having any effect in that regard.”  

The Court based its judgment on road safety considerations and the existing exemption 
under Article 3(h) of Regulation  (EC) No 561/2006  that sets  a ceiling  of 7.5 tonnes for 
vehicles  used  for  the  non-commercial  carriage  of  goods.  Following  the  judgment,  the 
European  Commission  has  been  contacted  by  several  citizens,  associations,  national 
authorities, and by the European Parliament (24) to clarify the legal framework applicable 
to large motorhomes. It is therefore desirable to have legal clarity regarding the installation 
and use of tachographs in motorhomes used exclusively for private purposes, as this device 
– originally designed for professional drivers – would represent a significant burden for 
non-professional drivers. 

Stakeholder views  

Following the judgement of the Court of Justice in Case C-666/21, the caravan industry 
identified differences in interpretation between Member States and has therefore called for 
a clarification on the rules that apply to motorhomes for private use in the EU. In certain 
Member States there has been a substantial decrease in sales of these large motorhomes 
following the judgement.  

Representatives from caravan users believe that the social and tachograph legislation was 
not designed for large private-use motorhomes, and therefore request a legal clarification 
in this Omnibus. 

National authorities have provided diverging feedback on the proposed amendment, with 
seven out of 16 against (others neutral or N/A) due to the possible impact on road safety 
that such large motorhomes may have, especially if they are carrying goods such as horses 
or  other  motor  vehicles.  The  national  authorities  in  favour  of  the  proposed  amendment 
highlighted  the  fact  that  Regulations  (EC)  No 561/2006  and  (EU)  No  165/2014  were 
already interpreted to mean that motorhomes were exempt from the tachograph obligation 
even  before  the  Court  judgment,  and  that  the  proposed  amendment  only  enshrines  this 
interpretation in the legal text. 

Proposed amendment  

The  proposed  amendment  is  to  add  a  new  point  (s)  in  Article 13  of  Regulation  (EC) 
No 561/2006 that would allow Member States to grant exceptions to motorhomes from the 
rules on driving times and rest periods, and those of the tachograph. Such an exception 
could be extended cross-border among Member States who have made use, notified this 
exemption,  and  agreed  with  the  other  Member  States  concerned.    The  Commission 
proposes therefore to introduce a new point, (s), in Article 13(1) of Regulation 561/2006: 

‘(s) motor caravans, as defined by point 5.1 of Part A of Annex I of Regulation 
(EU) 2018/858, used exclusively for non-commercial carriage by road.’; 

While  this  does  not  ensure  an  EU-wide  exemption  to  the  rules  on  driving  times,  rest 
periods, and the use of the tachograph, it makes use of the existing practice of Article 13 
of  Regulation  (EC)  No 561/2006,  whereby  domestic  exceptions  can  be  extended  cross-
border in agreement with the Member States concerned. This reflects the feedback received 

(24)  See for example Petition 0242/2025 of the European Parliament. 

12 

 
 
 
 
through the targeted stakeholder consultation, where Member States have different views 
on how large motorhomes of more than 7.5 tonnes are to be treated regarding driving times, 
rest  periods,  and  the  use  of  the  tachograph  insofar  as  road  safety  is  concerned.  It  will 
therefore remain for Member States to balance the benefits and possible risks of such an 
exception.  

Expected impact 

This  measure  is  expected  to  alleviate  the  adjustment  costs  faced  by  citizens  and 
the  current  ambiguity  resulting  from  divergent  national 
manufacturers  due 
interpretations of recent court rulings. It is expected to have a neutral environmental, social, 
and safety impact. 

to 

Impact per type (+ positive; - negative; o neutral)  

Environmental 

Safety  

Social 

o 

o 

o 

Cost Savings 

The exemption of motorhomes from the obligation to install a tachograph is expected to 
relieve motorhome customers of EUR 550 000 per year in costs (see Table 2). 

Table  2  -  Estimated  Savings  for  Motorhome  Owners  from  Tachograph  Exemptions  of  Large 
Motorhomes (25) 
Annual Savings  
(in Euro) 

2028 

2029 

2027 

Cumulative 
savings 
through 2029 
1 650 000 

550 000 

550 000 

550 000 

N/A 

N/A 

N/A 

N/A 

550 000 

550 000 

550 000 

1 650 000 

Estimate 
(Adjustment 
Cost Savings) 

Estimate 
(Administrative 
Cost Savings) 

TOTAL 
ANNUAL 
SAVINGS 
(lower-bound 
estimate) 

3.2.  Regulation  (EU)  2019/2144  on  type-approval  requirements  for  motor 
vehicles  and  their  trailers,  and  systems,  components  and  separate 

(25) The annual savings estimates were calculated using an average cost of EUR 1600 per tachograph device, 
installation  costs  of  EUR  250  (Source:  industry  stakeholders),  annual  calibration  costs  of  EUR  100 
https://op.europa.eu/en/publication-detail/-/publication/77e544e8-8e4e-11ec-8c40-
(Source: 
01aa75ed71a1  ),  and  sales  of  295  per  year  for  motorhomes  above  7.5  tonnes  (Source:  Industry 
association). Future sales increases due to the tachograph exemption could not be quantified and are thus 
not taken into account in the calculations. 

13 

 
 
 
 
 
 
 
technical units intended for such vehicles, as regards their general safety 
and the protection of vehicle occupants and vulnerable road users 

Regulation  (EU)  2019/2144,  also  known  as  the  General  Safety  Regulation  (GSR),  lays 
down  EU  vehicle  safety  requirements  for  vehicle  type-approval,  including  those 
addressing the specific concerns of vulnerable road users, such as pedestrians and cyclists. 
It  requires  vehicles,  including  passenger  cars,  vans,  trucks,  buses,  and  coaches,  to  be 
equipped with a number of advanced vehicle safety systems. The regulation is expected to 
save over 25 000 lives and prevent at least 140 000 serious injuries by 2038. (26)   

Amongst the advanced safety features required under the regulation are intelligent speed 
assistance  and  automated  emergency  braking.  Intelligent  speed  assistance  helps  drivers 
adhere to the speed limit by automatically informing them of the speed limit. Depending 
on  the  system's  level  of  activation,  it  can  range  from  simple  warnings  to  active  speed 
reduction. Automated emergency braking (AEB) automatically applies the brakes to avoid 
or mitigate collisions with other vehicles, pedestrians, and cyclists.  

Additional  safety  features  in  Regulation  2019/2144  are  driver  drowsiness  and  attention 
warning systems, which use sensors and vehicle data to monitor for signs of fatigue and 
distraction before providing a warning to the driver to take a break. These systems analyse 
driving patterns like lane drifting or jerky steering, as well as direct driver cues like eye 
movements and yawning, to assess alertness. If drowsiness is detected, the system alerts 
the driver through visual, auditory, or haptic feedback, helping to prevent accidents caused 
by fatigue.  

The  regulation  also  requires  reversing  detection,  which  uses  cameras  and/or  sensors  to 
detect  obstacles  when  reversing,  and  emergency  lane  keeping  (ELK),  which  prevents 
unintentional lane departures. Finally, vehicles must have an event data recorder (EDR) 
that records key data from the moments leading up to a collision. 

The regulation was implemented in two phases, with new cars and some other vehicles 
required to have certain features by July 2022. A second phase of requirements took effect 
in July 2024 for all new vehicles.    

3.2.1. 

Speed-limiting device obligation for e-Vans with a weight between 
3.5 tonnes and 4.25 tonnes 

Issue description  

Council Directive 92/6/EEC sets out rules on the installation and use of speed limitation 
devices  for  buses,  coaches,  and  heavy  goods  vehicles.  The  Directive  was  subsequently 
amended by Directive 2002/85/EC to extend the scope to lighter vehicles of categories, 
including  Vans  above  3.5 tonnes. The speed limitation  device has been included in  the 
General  Safety  Regulation  as  a  requirement  for  all  commercial  vehicles  with  a  weight 
above 3.5 tonnes.  

(26)  COMMISSION  STAFF  WORKING  DOCUMENT  IMPACT  ASSESSMENT  Accompanying  the 
document Proposal for a Regulation of the European Parliament and of the Council on type-approval 
requirements for motor vehicles and their trailers, and systems, components and separate technical units 
intended for such vehicles, as regards their general safety and the protection of vehicle occupants and 
vulnerable road users 

14 

 
 
As with the smart tachograph requirement, e-Vans with GVWs between 3.5 tonnes and 
4.25 tonnes (which fall into category N2 due to the weight from their batteries) are required 
to be equipped with a speed limitation device, while their fossil fuel equivalent (category 
N1) with essentially the same payload and use-cases is not subject to this requirement. The 
inclusion of such a device in these e-Vans thus means that diesel vans can drive at higher 
speeds.  Furthermore,  the  speed  limitation  device  adds  additional  expense  to  the  e-Van, 
discouraging their uptake by customers, of which there are many SMEs, compared to their 
combustion engine equivalent.  

Similar to the tachograph, this issue has been taken into account in the recent revision of 
the EU Driving Licence Directive (27), whereby a category B licence will be valid for two 
years after it was issued for the first time for vehicles with a maximum authorised mass 
exceeding 3.5 tonnes but not exceeding 4.25 tonnes. 

Stakeholder views  

In the targeted stakeholder consultation, OEMs and industry associations mentioned the 
positive impact removing the speed-limiting device would have on levelling the playing 
field between e-Vans and their fossil-fuel equivalent.  Because the speed limitation device 
adds costs to the e-Van, several stakeholders noted that eliminating this requirement would 
contribute to decreasing the total cost of ownership of these vehicles, used by many SMEs, 
in particular tradesmen, that need vans with this payload. 

Seven  type-approval  authorities  raised  concerns  that  removing  speed-limiting  devices 
would  impact  negatively  on  safety.  Although  some  of  the  specific  tests  for  vehicles  of 
category N1 are not applicable to vehicles of category N2 (e.g., rear and side impact tests), 
the level of safety of e-Vans with GVWs between 3.5 tonnes and 4.25 tonnes is expected 
to remain robust due to the comprehensive standards, such as the cab impact and electric 
safety  tests,  that  ensure  a  high  level  of  vehicle  integrity  and  occupant  protection.  In 
addition, the widescale deployment of advanced driver assistance systems (ADAS) in these 
vehicles today  contributes to  their enhanced safety  performance, providing equivalency 
compared to their fossil-fuel counterparts with similar use-case and payload.  

Proposed amendment  

The proposed amendment is to exempt e-Vans with GVWs between 3.5 tonnes and 4.25 
tonnes  (classed  as  N2  vans)  from  the  obligation  to  be  equipped  with  speed  limitation 
devices, thereby putting them on equal footing with their fossil fuel equivalent, N1 diesel 
vans. 

In Article 9 of Regulation (EU) 2019/2144, the Commission proposes adding the following 
paragraph: 

‘5a.  Vehicles  of  category  N2  propelled  by  means  of  electricity,  with  maximum 
permissible technical laden mass between 3.5 and 4.25 tonnes, shall not be required 
to be equipped with speed limitation devices in accordance with UN Regulation 
No 89.; 

(27)  DIRECTIVE (EU) 2025/2205 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 22 
October 2025 on driving licences, amending Regulation (EU) 2018/1724 of the European Parliament 
and of the Council and Directive (EU) 2022/2561 of the European Parliament and of the Council, and 
repealing  Directive  2006/126/EC  of  the  European  Parliament  and  of  the  Council  and  Commission 
Regulation (EU) No 383/2012. 

15 

 
 
  
 
Moreover, through a separate Directive proposal (also adopted as part of the Automotive 
Package),  the  Commission  proposes  adding  a  new  paragraph  in  Article  3  of  Directive 
92/6/EEC exempting the vehicles in question from the need to be equipped with a speed 
limitation device to allow them to be used on the road: 

‘1.  Member  States  shall  take  the  necessary  measures  to  ensure  that  motor  vehicles  of 
categories  N2  and  N3,  except  those  vehicles  of  category  N2  propelled  exclusively  by 
means of electricity and with a maximum permissible mass between 3,5 and 4,25 tonnes, 
may be used on the road only if equipped with a speed limitation device set in such a way 
that their speed cannot exceed 90 kilometres per hour.’. 

Expected impact 

Removing the requirement to have speed limitation devices in e-Vans with GVW between 
3.5 and 4.25 tonnes would encourage the uptake of such zero-emission vans versus their 
fossil fuel counterpart, thus delivering positive environmental effects in line with the CO2 
Regulation.  It would remove an adjustment cost that would likely benefit customers, many 
of whom are SMEs. From a social perspective, the impact is likely to be neutral.  

Impact per type (+ positive; - negative; o neutral) 

Environmental 

Safety  

Social 

+ 

o 

o 

Cost savings for the automotive value chain 

The exemption of e-Vans from the obligation to install speed limiting devices is expected 
to relieve the EU automotive industry of significant recurrent  adjustment costs, as light 
commercial  vehicles  between  3.5t  and  4.25t  sold  in  the  future  will  benefit  from  these 
savings. The total savings of the measure lie between EUR 223.7 million (lower-bound 
estimate  19)  and  EUR  782.9  million  (upper-bound  estimate  20)  from  2027  to  2029  (see 
Error! Reference source not found. 3). Of these savings, 78% are attributable to SMEs 
and 22% to large companies.  

2027 

Table 3 - Estimated Savings from Speed Limiting Device Exemption for e-Vans with GVW between 
3.5t and 4.25t (28) 
Annual Savings  
(in 
million 
Euro) 
Lower-bound 
Estimate 
(Adjustment 
Cost Savings) 

Cumulative 
savings 
through 2029 
223.7 

(174.5   for SMEs) 

2029 

2028 

74.6 

57.1 

92.0 

(28) The Annual savings were calculated using an average cost of EUR 700 per speed limiting device and 
installation costs of EUR 250 (Source: industry stakeholders). The lower- and upper-bound estimates 
were calculated with the same methodology as in Table 1. 

16 

 
 
 
 
 
 
 
Lower-bound 
Estimate 
(Administrative 
Cost Savings) 

TOTAL 
ANNUAL 
SAVINGS 
(lower-bound 
estimate) 

Higher-bound 
Estimate 
(Adjustment 
Cost Savings) 

Higher-bound 
Estimate 
(Administrative 
Cost Savings) 

TOTAL 
ANNUAL 
SAVINGS 
(higher-bound 
estimate) 

N/A 

N/A 

N/A 

N/A 

57.1 

74.6 

92.0 

223.7 

(174.5   for SMEs) 

199.9 

260.9 

322.2 

782.9 

(610.7   for SME) 

N/A 

N/A 

N/A 

N/A 

199.9 

260.9 

322.2 

782.9 

(610.7   for SME) 

3.3.  Regulation  (EC)  2024/1257  on  type-approval  of  motor  vehicles  and 
engines and of systems, components and separate technical units intended 
for such vehicles, with respect to their emissions and battery durability 
(Euro 7) 

Regulation  (EU)  2024/1257,  also  known  as  the  Euro  7  Regulation,  covers  the  type-
approval of vehicles, engines, and related systems and components with respect to their 
emissions and battery durability, aiming to reduce air pollution from both exhaust and non-
exhaust sources like brakes and tyres. It introduces measures for on-board monitoring of 
emissions, battery performance, and emission performance throughout a vehicle's lifetime. 

Euro 7 builds on the emission rules in the Euro 6 Regulation for light-duty vehicles and 
Euro VI Regulation for heavy-duty vehicles, continuing the latest Euro 6/Euro VI emission 
test methods, but widens the scope to address durability and emerging sources of pollution 
from  brakes  and  tyres.  Stronger  lifetime  requirements  mean  vehicles  must  maintain 
compliance  over  higher  mileage  and  longer  years  in  service,  closing  gaps  between 
laboratory and real-world performance.  

In addition, by regulating particulate emissions from brake systems and setting minimum 
battery durability standards, Euro 7 recognises that electrification alone does not eliminate 
all environmental impacts and seeks to  ensure  clean mobility  across diverse propulsion 
technologies. 

The expected benefits of Euro 7 include improved air quality, especially in dense urban 
environments,  and  thus  a  reduction  in  health  impacts  linked  to  nitrogen  oxides, 

17 

 
 
particulates, and other harmful pollutants. By mandating continuous on-board monitoring 
and  transparent  reporting,  the  regulation  aims  to  increase  consumer  confidence,  reduce 
regulatory loopholes, and ensure vehicles remain clean in day-to-day use rather than only 
during type-approval testing.  

In parallel, durability provisions for batteries and other emission-control components are 
designed  to  extend  useful  life,  minimise  premature  degradation,  and  promote  more 
sustainable resource use. Collectively, these measures support the EU’s broader climate 
and public-health objectives while encouraging innovation in cleaner propulsion, filtration, 
and energy-management technologies. 

3.3.1. 

Laboratory  test  of  low  temperature  for  emissions  in  light-duty 
vehicles  

Issue description  

Regulation (EU) 2024/1257 (Euro 7) sets out the methods for measuring emissions from 
light-duty (passenger cars and vans) and heavy-duty vehicles (lorries, coaches, and buses), 
as well as the emission limits that manufacturers must demonstrate compliance with. These 
are set out in Annex I of the Regulation. The Euro 7 Regulation establishes that the methods 
for  measuring  pollutant  exhaust  and  evaporative  emissions  from  light-duty  vehicles 
(passenger cars and vans) shall reflect those laid down in Regulation (EU) 2017/1151 (i.e., 
the Euro 6e rules, which are currently applied).  

The  ‘laboratory  test  at  low  temperature’  is  an  emissions  test  for  which  OEMs  must 
demonstrate compliance at -7 °C. Under the currently applicable Euro 6e rules, this test 
applies a dedicated set of limits (29) that reflect the expected increase of emissions at low 
temperatures. However, the Euro 7 Regulation did not include the specific emission limits 
for  this  test,  as  was  the  case  under  Euro  6.  Moreover,  the  conditions  for  the  low-
temperature  emissions  test  overlap  with  the  Real  Driving  Emissions  test  specifications, 
which covers emissions in temperatures ranging from -7 °C to 38 °C.  

The  temperature  conditions  of  the  ‘laboratory  test  of  low  temperature  for  emissions’ 
referred to in Table 1 and 2 of Annex V of the Euro 7 regulation are covered by the ‘gaseous 
pollutant and particle number (PN) in the road testing (‘Real Driving Emissions’ - RDE) 
test that are also provided in the same tables. Having to perform a dedicated cold ambient 
test  in  a  laboratory  to  demonstrate  compliance  with  the  new  Euro  7  emission  limits 
constitutes a significant type-approval testing burden for vehicle manufacturers. Therefore, 
it is deemed justified to simplify the specific low-temperature laboratory (Type 6) test. 

To that end, the Commission considered two possible approaches: 

Option 1: introduction of the dedicated Euro 6 emission limits for the ‘laboratory test at 
low temperature for emissions’ in Euro 7 to reduce the development burden for vehicle 
manufacturers;  

(29)  Commission Regulation (EU) 2017/1151 of 1 June 2017 supplementing Regulation (EC) No 715/2007 
of  the  European  Parliament  and  of  the  Council  on  type-approval  of  motor  vehicles  with  respect  to 
emissions from light passenger and commercial vehicles (Euro 5 and Euro 6).  

18 

 
 
 
Option  2:  elimination  of  low-temperature  (Type  6)  tests  in  their  entirety,  reducing 
development burden and the number of tests at type-approval.  

Stakeholder views  

Of the 68 stakeholders who submitted replies to the targeted stakeholder consultation, 44 
responded to the proposal on simplifying the Euro 7 Type 6 test. A large majority (n=40; 
91%) supported action to tackle this problem, while three (7%) opposed it.  

Supporters  of  option  1  (12  stakeholders),  i.e.,  those  in  favour  of  maintaining  the  low-
temperature  test  with  the  inclusion  of  Euro  6  limits  in  Euro 7,  highlighted  the  need  to 
preserve the intent of the co-legislators to adhere to Euro 6 rules. They emphasised reduced 
regulatory  burden,  legal  certainty,  and  consistent  environmental  testing  at  low 
temperatures. They argued that this approach complements Real Driving Emissions (RDE) 
testing  and  does  not  negatively  affect  environmental  outcomes  if  limits  for  carbon 
monoxide (CO) and hydrocarbons (HC) remain. This group included automotive suppliers, 
business associations, national authorities, and vehicle manufacturers. 

Proponents of option 2 (12 stakeholders), i.e., eliminating the Type 6 test, argued that the 
test is redundant, as RDE testing already covers the relevant temperature range and modern 
vehicles are able to meet stricter standards. Removing the test would cut testing costs  and 
simplify type-approval without impacting environmental protection. Support came from 
automotive  suppliers,  business  associations,  one  NGO,  type-approval  authorities,  and 
vehicle manufacturers. 

16  stakeholders  supported  both  options,  citing  similar  benefits  such  as  reduced 
administrative effort while maintaining high environmental standards. 

A  small  group  (three  stakeholders)  opposed  both  options,  fearing  that  removing  or 
weakening the low-temperature test would hinder detection of non-compliance at -7°C and 
undermine  consumer,  environmental,  and  health  safeguards,  because  these  temperature 
conditions are not often observed in Europe and would therefore not be tested through the 
RDE  test.  One  stakeholder,  who  was  neither  in  favour  of  nor  against  the  proposals, 
cautioned  that  emissions  could  increase  in  northern  Member  States  from  this 
simplification. 

Proposed amendment  

The  proposed  amendment  is  to  delete  the  row  corresponding  to  Laboratory  test  of  low 
temperature for emission in table 1 and table 2 of Annex V of Regulation (EU) 2024/1257 
regarding application of test requirements and declarations for vehicles of categories M1 
(passenger  cars)  and  N1  (vans)  for  respectively  manufacturers  and  for  Member  States, 
Commission and recognised third parties (Option 2 (30)). 

This  amendment  reflects  option  2,  i.e.,  the  option  that  provides  the  highest  level  of 
simplification by significantly reducing regulatory burden and the number of tests while 
avoiding duplication, creating cost savings, and maintaining stringent emission control and 
public health protection. 

(30)  As Option 1 involves keeping existing Euro 6 testing standards, it would not entail any cost savings for 

manufacturers nor for type-approval authorities and was therefore ruled out. 

19 

 
 
 
Expected impact 

The removal of the Type 6 low-temperature laboratory test from the Euro 7 framework 
would not reduce the level of environmental protection afforded by Union legislation. The 
purpose of the Type 6 test under Euro 6 was to verify the control of pollutant emissions of 
petrol vehicles only at low ambient temperatures in a laboratory environment (-7 °C) using 
a modified version of the now-obsolete New European Driving Cycle (NEDC).  

Under the Euro 7 framework, these conditions are already covered comprehensively by the 
Real Driving Emissions (RDE) test, which requires the verification of pollutant emissions 
for all powertrains under a wide range of ambient conditions, including temperatures down 
to  –7  °C.  The  RDE  procedure  provides  a  more  representative  assessment  of  emissions 
during actual driving,  including  the cold-start  phase, and applies to  all vehicle and fuel 
types (unlike the Type 6 test, which excludes diesel vehicles).  

Moreover, the continuous verification of emission control system performance through on-
board monitoring (OBM) and the reinforced in-service conformity testing regime under 
Euro 7 provide oversight of emissions during real use and throughout the vehicle’s lifetime. 
Consequently, maintaining a separate laboratory Type 6 test would duplicate requirements 
without additional  environmental  benefit. Conversely,  its  removal streamlines  the  type-
approval process without compromising environmental outcomes. 

Impact per type (+ positive; - negative; o neutral)  

As  described  above,  the  proposed  amendment  would  reduce  administrative  burden  for 
manufacturers  and for  Member States, the European Commission,  and  recognised third 
parties.  It  would  not  entail  any  adjustment  costs,  nor  would  it  have  any  impact  on  the 
environment, road safety, or society.  

Impact per type (+ positive; - negative; o neutral) 

Environmental 

Safety  

Social 

o 

o 

o 

Cost savings for the automotive value chain 

OEMs  would  benefit  from  recurrent  adjustment  cost  savings,  detailed  in  Table  4,  that 
would  be  generated  through  the  simplification  of  test  procedures  during  type-approval, 
resulting in a significant decrease in complexity and regulatory burden.  

2027 

Table 4 - Estimated cost savings from removing low-temperature emissions test (31) 
2028 
Annual Savings  
(in 
million 
Euro) 
Lower-bound 
Estimate 

2029 

155 

465 

155 

155 

Cumulative savings through 
2029 

(31)  Using a conservative estimate that the low-temperature test represents 6% (lower-bound estimate) to 
10% (upper-bound estimate) of the type-approval testing budget (this test being one test out of seven), 
and assuming that the light-duty vehicle industry’s annual budget for emission type approval (Euro 6/7) 
ranges from EUR 1 650 000 000 to 3 500 000 000 (Source: EU industry).  

20 

 
 
 
(Adjustment 
Cost Savings) 

Lower-bound 
Estimate 
(Administrative 
Cost Savings) 

TOTAL 
ANNUAL 
SAVINGS 
(lower-bound 
estimate) 

Higher-bound 
Estimate 
(Adjustment 
Cost Savings) 

Higher-bound 
Estimate 
(Administrative 
Cost Savings) 

TOTAL 
ANNUAL 
SAVINGS 
(higher-bound 
estimate) 

N/A 

N/A 

N/A 

N/A 

155 

155 

155 

465 

275 

275 

275 

825 

N/A 

N/A 

N/A 

N/A 

275 

275 

275 

825 

Removing the low-temperature emissions testing of the full Type 6 test procedure would 
therefore lead to a cost savings of EUR 155 000 000 to 275 000 000 per year.  

Other economic impacts for Member States and Citizens 

Removing the low-temperature test will have a positive impact and significant spillover 
effects for type-approval authorities and technical services in charge of type-approvals of 
vehicles  for  emissions  at  Member  State-level,  as  it  will  facilitate  the  management  and 
assessment of type-approval files. It is however not possible to quantify the corresponding 
cost savings.  

3.3.2. 

Vehicle  types  for  Euro  7  engine  (Separate  Technical  Unit)  type-
approval 

Issue description 

In  accordance  with  Regulation  (EU)  2024/1257  (Euro  7),  heavy-duty  vehicles  (HDVs) 
must undergo a Real Driving Emissions (RDE) demonstration test for every vehicle type 
to obtain a Euro 7 engine type-approval (i.e., a type-approval of the engine as a separate 

21 

 
 
 
 
technical unit). This marks a departure from the current provisions in Euro VI (32), where 
the engine type-approval RDE tests are performed per vehicle category (e.g., N3 heavy 
lorries), rather than per vehicle type (roughly equivalent to a vehicle model).  

The type-approval Regulation (EU) 2018/858 sets out in article 4 that a vehicle ‘category’ 
refers to a broader classification of vehicles based on similar characteristics, such as size 
or function (e.g., city buses, coaches, or lorries), while a vehicle ‘type’ is a more specific 
classification within a vehicle category, distinguished by design or operational features. 
Vehicle type is to be understood as ‘type of vehicle’ as defined in article 3(32) of the type-
approval  Regulation  (EU)  2018/858.  For  example,  within  the  category  of  buses,  there 
might be different type of vehicles based on size, purpose, or engine used. 

The  additional  testing  requirement  therefore  places  a  disproportionate  financial  and 
operational burden on manufacturers, especially for those producing diverse types within 
a  single  vehicle  category,  without  providing  additional  environmental  benefits,  as  the 
results are essentially the same across vehicle types within the same vehicle category. The 
requirement to test each type of vehicle separately, even when they use the same engine 
family, is unnecessarily costly and complex and appears to be an oversight in the drafting 
of Annex V of the Regulation,  which became  evident during the preparation  of Euro 7 
implementing rules for heavy-duty vehicles. 

Feedback from industry stakeholders highlights that small-volume manufacturers who rely 
on large engine manufacturers face significant commercial pressures and may suffer major 
setbacks  from  the  Euro  7  per-type  testing  requirements,  potentially  disrupting  the  EU 
commercial  vehicle  market.  Industry  stakeholders  have  expressed  concerns  over  the 
survival  of  these  small  manufacturers;  correcting  the  oversight  by  requiring  testing  per 
vehicle category instead of per type would reduce the burden of compliance. At the same 
time, it is crucial to maintain clear divisions of responsibility and compliance obligations 
between engine manufacturers and vehicle original equipment manufacturers (OEMs).  

Ultimately,  aligning  the  Euro  7  requirements  with  the  initial  intention  of  strengthening 
emission limits without expanding testing complexity  would ensure a balanced and fair 
regulatory  environment  that  supports  the  sustainability  and  competitiveness  of  the 
European vehicle industry. 

Stakeholder views  

Of the 68 consulted participants, 34 (50%) responded on the proposal to refer to vehicle 
categories  rather  than  types  for  heavy-duty  vehicle  type-approval.  Among  them,  most 
(n=23; 68%) supported the change, eight (24%) had no clear preference, and none opposed 
it, though three (9%) offered nuanced views. 

Supporters  highlighted  the  reduced  administrative  and  testing  burdens  the  proposed 
amendment  would  bring  without  compromising  environmental  standards.  The  measure 
would  avoid  redundant  engine  testing  across  vehicle  types,  lower  approval  costs,  and 
enhance regulatory coherence, predictability, and market stability, potentially leading to 

(32)  Euro VI refers to Regulation (EC) No 595/2009 on type-approval of motor vehicles and engines with respect to 
emissions from heavy-duty vehicles, while Euro 6 refers to Regulation (EC) No 715/2007 on type-approval of motor 
vehicles with respect to emissions from light passenger and commercial vehicles. Euro 7 (Regulation (EU) 2024/1257 
on type-approval covers emissions from both light- and heavy-duty vehicles.  

22 

 
 
lower HDV prices and accelerating fleet renewal. One engine manufacturer estimated cost 
reductions of up to 90% for type-approval. Positive or neutral environmental, social, and 
safety  impacts  were  expected,  alongside  clear  economic  benefits.  Support  came  from  a 
range  of  stakeholders,  including  automotive  suppliers,  business  associations,  NGOs, 
market surveillance and type-approval authorities, and HDV manufacturers. 

The  three  organisations  who  did  not  indicate  a  preference  for  or  against  the  proposed 
amendment consisted of one manufacturer and two national authorities. These stakeholders 
provided neutral views, citing the potential  concern that the proposed amendment might 
make it more difficult to harmonise Euro 7 and UNECE regulations. 

Proposed amendment  

The proposed amendment is to refer to ‘vehicle categories’ rather than ‘vehicle types’ for 
Euro 7 engine (Separate Technical Unit) type-approval, i.e., ‘Required demonstration tests 
for  all  fuels  for  which  the  type-approval  is  granted  per  vehicle  type  category  and  a 
declaration of compliance for all fuels, all payloads and all applicable vehicle categories 
in respectively tables 3, 4, 7 and 8 of Annex V to Regulation (EU) 2024/1257.’ 

Expected impact 

As  outlined  above,  the  expected  impact  on  the  environmental  will  be  neutral  with  no 
change  in  impact  on  safety  or  society.  There  would,  however,  be  major  administrative 
burden reduction.  

Impact per type (+ positive; - negative; o neutral)  

Environmental 

Safety  

Social 

o 

o 

o 

Cost savings for the automotive value chain 

The total cost saving is recurrent and would consist of administrative cost savings as the 
testing  procedure  simplification  relieves  manufacturers  of  heavy-duty  vehicles  and/or 
engine manufacturers that supply engines for OEMs (in cases where the OEM does not 
manufacture its own engines) from substantive testing obligations.  

Based on discussions with industry stakeholders and presentations as part of the Advisory 
Group  Vehicle  Emissions  Standards  (AGVES),  on  average  heavy-duty  vehicle 
manufacturers  that  produce  Category  N3  and  M3  vehicles  have  4  or  5  types  within  a 
specific category. In certain situations, this can exceed 10 to 15 types per category. Some 
stakeholders referred to an increase in type-approval procedures from 4 to 10 if ‘type’ is 
mentioned  instead  of  ‘vehicle  category.’  Therefore,  a  conservative  estimate  is  that  1.5 
times  more  procedures  must  be  carried  out  if  ‘type’  is  mentioned  instead  of  ‘vehicle 
category.’ 

The resulting adjustment cost savings range from EUR 262 500 000 to EUR 1 125 000 
000 per year for car manufacturers. Table 5 presents an overview of the cost savings. 

23 

 
 
2027 

Table 5 - Estimated savings from transitioning Euro 7 RDE testing from vehicle types to vehicle 
categories for heavy-duty engine type-approval (33) 
2028 
Annual Savings  
(in 
million 
Euro) 
Lower-bound 
Estimate 
(Adjustment 
Cost Savings) 

Cumulative 
savings 
through 2029 
789 

2029 

263 

263 

263 

N/A 

N/A 

N/A 

N/A 

263 

263 

263 

789 

1 125 

1 125 

1 125 

3 375 

N/A 

N/A 

N/A 

N/A 

1125 

1125 

1125 

3375 

Lower-bound 
Estimate 
(Administrative 
Cost Savings) 

TOTAL 
ANNUAL 
SAVINGS 
(lower-bound 
estimate) 

Higher-bound 
Estimate 
(Adjustment 
Cost Savings) 

Higher-bound 
Estimate 
(Administrative 
Cost Savings) 

TOTAL 
ANNUAL 
SAVINGS 
(higher-bound 
estimate) 

Other economic impacts for Member States and Citizens 

The simplification and clarification as well as the streamlining of the documentation will 
have some positive impact and significant spillover effects for type-approval authorities 
and technical services in charge of type-approvals of vehicles for emissions at Member 
States  level.  This  will  significantly  facilitate  the  management  and  assessment  of  type-
approval files. It is however impossible to quantify the corresponding cost savings. 

(33) Annual EU type-approval costs for EU HDV manufacturers, assuming an EU type-approval budget of 
EUR 500 000 and EUR 1 500 000, for 350 to 500 type-approval certificates per year, would be from EUR 
175 000 000 to EUR 750 000 000 per year. The additional cost estimate amounts to the yearly EU type-
approval estimated budget at EU industry level that is multiplied by 1.5x to account for additional testing 
that would be required if done by vehicle type instead of vehicle category. (Source: EU industry)   

24 

 
 
 
 
3.3.3. 

OBM and OBFCM data infrastructure and common methods 

Issue description  

Under the Euro 7 Regulation, new vehicles will periodically transmit data about their real-
world fuel consumption and emissions to manufacturers who will then transmit it to type 
approval/market  surveillance  authorities  through  so-called  on-board  fuel  and  electric 
energy  consumption  monitoring  (OBFCM)  devices  and  on-board  monitoring  (OBM) 
systems.  

The  information  from  OBM  and  OBFCM  can  support  the  work  of  Member  State 
authorities,  enabling  more  targeted  testing  and  providing  a  realistic  picture  of  the 
environmental performance of Euro 7 vehicles. To fully realise the potential of OBM and 
OBFCM data, it is essential that the data are available in common data formats, and that 
quality  control  procedures  be  put  in  place  to  make  datasets  comparable  across 
manufacturers.  

However, there is currently no provision at EU level to enable the receiving, compiling, 
processing and storage of OBM data. Creating specific rules for OBM data management 
by  authorities  would  ensure  clarity  and  harmonisation  in  this  respect,  increase 
effectiveness, reduce administrative burden for manufacturers and authorities, and provide 
simplification.  A  shared  repository  managed  at  EU  level  could  aggregate  anonymised 
OBM data, ensuring consistent reporting and enabling cross-border analysis. This would 
complement the systems already in place for OBFCM under Regulation (EU) 2019/631 
and could later be extended to data on pollutants. 

Stakeholder views  

Stakeholder  views  on  this  matter  were  collected  during  the  development  of  the  Euro  7 
implementing  rules.  The  need  for  simplified  OBM  and  OBFCM  data  management  was 
raised repeatedly in the Advisory Group Vehicle Emissions Standards (AGVES). At the 
20th AGVES meeting on 25–26 September 2024, discussions centred on the outcomes of 
an  ad  hoc  meeting  on  the  data  annex  of  the  draft  On-Board  Monitoring  (OBM) 
implementing  act.  Member  State  representatives  underlined  the  importance  of  effective 
data management, especially regarding storage solutions, and suggested exploring server-
based approaches to limit the volume of stored and transmitted data. 

At  the  22nd  AGVES  meeting  on  4–5  February  2025,  discussions  centred  on  the  data 
infrastructure required for OBM across the Union. Stakeholders provided technical input 
on  implementation,  highlighting  the  need  to  reduce  data-collection  burdens  without 
compromising  regulatory  robustness.  Industry  representatives  called  for  clear  timelines 
and obligations for data transmission. There was broad agreement on ensuring that OBM 
and OBFCM data are received, compiled, processed, and stored in a harmonised way to 
support the effective monitoring of in-use compliance with Euro 7 standards. Both industry 
and  Member  State  authorities  expressed  support  for  a  streamlined  approach  that  would 
simplify procedures and reduce administrative burden. 

Proposed amendment  

In  Regulation  (EU)  2024/1257,  Article  14(4)  point  (j)  is  replaced  by  the 
following:‘(j)  the  methods,  requirements  and  tests,  including  compliance 

25 

 
 
 
thresholds,  to  ensure performance of  OBFCM devices,  OBD  and OBM  systems 
and the sensors of such devices and systems, for off-board communication of data 
recorded  by  such  devices  and  systems,  including  for  the  purpose  of  monitoring 
compliance of vehicle types t.’ 

With this measure, it will be clarified that the Commission is empowered to ensure that 
OBM, OBD and OBFCM data are received, compiled, processed and stored effectively in 
a harmonised manner to monitor real-world performance of Euro 7 vehicle types. 

Expected impact 

The development of OBM and OBFCM data infrastructure and common methods for its 
processing will help fully realise the potential of OBM and OBFCM data. Member States 
could use aggregated data to identify vehicles or technologies with abnormal emission or 
fuel-consumption behaviour, focusing laboratory and on-road tests where anomalies are 
detected, thereby reducing the administrative costs related to enforcement of the Euro 7 
standard.  

The  Commission,  Member  States,  and  technical  services  could  develop  shared 
methodologies for interpreting OBM and OBFCM data (e.g., statistical baselines, criteria 
for  anomaly  detection).  Making  simplified  summaries  of  OBM  and  OBFCM  data 
accessible (via the web, for example) could raise awareness of real-world efficiency and 
pollutant emission performance of vehicles.   

Impact per type (+ positive; - negative; o neutral)  

Environmental 

Safety  

Social 

o 

o 

o 

Cost savings for the automotive value chain 

A harmonised EU-level OBM/OBFCM data infrastructure could generate substantial cost 
savings in comparison to each Member State developing and maintaining its own system. 
The  savings  arise  from  economies  of  scale,  reduced  duplication,  and  harmonised 
compliance  processes.  Instead  of  dealing  with  multiple  national  systems,  vehicle 
manufacturers would be able to transmit standardised data one time, reducing software-
integration and certification expenses. 

Developing one secure EU platform would avoid separate national investments in servers, 
databases, cybersecurity systems, and maintenance contracts at each Member State issuing 
Euro  7  emission  approvals  and  for  car  manufacturers  who  are  currently  processing, 
compiling and storing the same data at their own level. A single analytical engine would 
be  able  to  identify  anomalies  across  the  EU  fleet,  allowing  economies  of  scale  in  data 
science  and  algorithm  development.  Lastly,  shared  insights  from  harmonised  analytics 
help  all  Member  States  focus  limited  testing  resources  where  non-compliance  is  most 
likely, saving time and laboratory costs. 

At  car  manufacturers’  level,  setting  up  common  measures  for  compiling,  managing, 
processing and storing data would lead to recurrent annual cost savings starting from the 
entry into force of such measures. Such recurrent annual cost savings can be estimated as 
follows:  

26 

 
 
•  The data platform would cover both Light-Duty Vehicles (LDVs) and Heavy- 

Duty Vehicles (HDVs)  

•  Data volumes: tens of millions of vehicles would transmit data each year 
• 

Infrastructure & storage: must include receipt of data, validation, 
anonymisation/aggregation, secure storage, retrieval/reporting, 
redundancy/backup, long term archive 

•  Annual operating costs would include: cloud/data centre cost, software 

maintenance and upgrades, data management staff, compliance/security, 
aggregation/reporting, type-approval authority overhead 

•  There would be economies of scale: once the system is built, per-vehicle cost 

declines, but data volumes likely increase and complexity (many OEMs, many 
vehicle variants) grows. 

On this basis, the cost savings are related to: (i) input, processing and storage of data; (ii) 
reporting and saving data; (iii) cloud and storage as well as IT management; (iv) security 
and back up. These cost savings are estimated for each of the above-mentioned categories 
while taking into account the estimated number of LDVs reporting to the system (20 000 
000) and HDVs (2 000 000). This gives rise to potential savings for OEMs of EUR 150 
000 (lower-bound estimate) to 2 400 000 (upper-bound estimate) per year (see Table 6). 
Some cost savings would also exist at the level of part and components manufacturers (due 
to the highly cross-integrated value chain) but this could not be assessed quantitatively. 

2027 

Table 6 – Estimated savings for OEMs from implementing a harmonised EU-Level OBM/OBFCM 
data infrastructure under Euro 7 standards 
Annual Savings  
(in 
million 
Euro) 
Lower-bound 
Estimate 
(Adjustment 
Cost Savings) 

Cumulative 
savings 
through 2029 
N/A 

2028 

2029 

N/A 

N/A 

N/A 

Lower-bound 
Estimate 
(Administrative 
Cost Savings) 

TOTAL 
ANNUAL 
SAVINGS 
(lower-bound 
estimate) 

Higher-bound 
Estimate 
(Adjustment 
Cost Savings) 

Higher-bound 
Estimate 

0.15 

0.15 

0.15 

0.45 

0.15 

0.15 

0.15 

0.45 

N/A 

N/A 

N/A 

N/A 

2.40 

2.40 

2.40 

7.20 

27 

 
 
(Administrative 
Cost Savings) 

TOTAL 
ANNUAL 
SAVINGS 
(higher-bound 
estimate) 

2.40 

2.40 

2.40 

7.20 

Other economic impacts for Member States and Citizens 

As OBM data infrastructure has yet to be developed, cost saving estimates for authorities 
are based on a representative scenario where savings are realised by using a harmonised 
EU-level approach rather than a national approach for each Member State issuing Euro 7 
vehicle approvals. In this illustrative scenario, it is assumed that a harmonised EU platform 
would be developed once and then accessed by Member States through dedicated portals, 
with  each  Member  State  responsible  only  for  limited  national  adaptations,  help-desk 
functions, and enforcement modules.  

Cost Savings for Member States 

Although the cost to the European Commission would be EUR 1 200 000, the EU-level 
approach is estimated to result in cumulative savings of EUR 20 000 000 for Member 
States, including one-off savings and recurrent savings (see Table 7). 

One-Off 

Table 7 - Estimated cost savings for Member States from implementing a harmonised EU-level 
OBM data infrastructure compared to national data infrastructure (34) 
2029 
Annual Savings  
(in 
million 
Euro) 
Estimate 
(Adjustment 
Cost Savings) 

Cumulative 
savings 
through 2029 
12.5 

2027 

2028 

12.5 

N/A 

N/A 

N/A 

Estimate 
(Administrative 
Cost Savings) 

TOTAL 
ANNUAL 
SAVINGS 

N/A 

2.5 

2.5 

2.5 

7.5 

12.5 

2.5 

2.5 

2.5 

20 

(34) Assuming each Member State independently develops its system, the one-off cost would total EUR 16 
200 000 for all 27 Member States, compared to EUR 1 200 000 for a central EU platform. This would result 
in EUR 15 000 000 savings in 2027. With annual operating costs of EUR 2 700 000 (assuming EUR 100 000 
per Member State for 27 Member States) versus EUR 200 000 for the EU system, additional savings of EUR 
2 500 000 per year are projected for 2028 and 2029, totalling EUR 20 000 000 in cumulative savings for the 
Union over three years. 

28 

 
 
 
 
 
 
 
(lower-bound 
estimate) 

3.4.  Regulation  (EC)  540/2014  on  the  sound  level  of  motor  vehicles  and  of 

replacement silencing systems 

Regulation  (EC) 540/2014 establishes the technical  and administrative rules for the EU 
type-approval of motor vehicles and replacement silencing systems based on their sound 
levels.  Its  main  objectives  are  to  reduce  noise  pollution  from  vehicles,  protect  the 
environment and public health, and ensure the proper functioning of the internal market by 
harmonising noise requirements.  

The regulation includes labelling requirements for manufacturers and distributors and the 
obligation for manufacturers to include an Acoustic Vehicle Alerting System (AVAS) in 
new hybrid electric and electric vehicles are equipped to alert pedestrians to their presence.   

3.4.1. 

Misalignment with UN Regulations on noise  

Issue description  

When demonstrating compliance of a new vehicle type with noise-related requirements, 
vehicle manufacturers in  the EU must comply with Regulation  (EU) No 540/2014.  UN 
Regulations have an enhanced scope that restricts noise from backfire, sound actuators, 
and sound enhancement systems are considered equivalent under EU type-approval but are 
not mandatory in the EU.  

Because the EU Regulation does not contain any legal empowerment that would enable it 
to be updated in line with technology developments, it has not been updated in more than 
six years.  EU manufacturers apply the UN regulations to be competitive on international 
markets.  The  incoherence  between  mandatory  requirements  in  540/2014  and  the  UN 
regulations  carries  the  risk  of  creating  a  competitive  disadvantage  and  generates  an 
administrative burden.  

Stakeholder views  

During  the  targeted  stakeholder  consultation,  no  stakeholders  came  out  in  favour  of 
keeping Regulation 540/2014. For OEMs, although Regulation (EU) No 540/2014 is less 
restrictive than the UN rules, the majority of OEMs (6 out of 11) stated their support for 
this  regulatory  simplification,  citing  the  reduced  costs  and  administrative  burden  in 
applying  one  global  standard  for  noise;  the  other  five  OEMs  expected  no  impact  from 
repealing  the  regulation.  Of  other  stakeholders  who  replied,  the  majority,  including 
industry associations (11 out of 13), market surveillance authorities (2 out of 3) and type 
approval authorities (7 out of 11), supported repealing this regulation, citing the stronger 
environmental  benefits  offered  by  the  UNECE  regulations  through  reduced  noise 
pollution.  

Proposed amendment  

The proposed amendment is to repeal Regulation (EU) No 540/2014 with effect from the 
date of application of the Omnibus Regulation. In addition, an amendment to Annex II to 
Regulation (EU) 2018/858 is proposed to replace the reference to the repealed Regulation 

29 

 
 
 
 
 
by a reference to the noise-related UN Regulations: UN Regulations 51 on noise of M and 
N categories of vehicles; UN Regulation 59 on replacement silencing systems; and UN 
Regulation  138  on  quiet  road  transport  vehicles  or  AVAS.  Transitional  provisions  are 
proposed to ensure smooth transition of the industry to the modified legal framework. 

Expected impact 

The  proposed  amendments  would  remove  a  competitive  disadvantage  for  EU  car 
manufacturers  when  selling  their  cars  globally  by  preventing  them  from  having  to 
demonstrate administrative compliance with two sets of requirements on noise. This will 
likely  reduce  administrative  burden  (i.e.  duplication  of  tests  and  markings),  although 
OEMs did not provide any data on this. The proposed changes would remove any potential 
loopholes and result in a simpler, more consistent framework and likely have a positive 
economic  impact  for  the  automotive  industry,  type-approval  authorities,  and  market 
surveillance authorities alike. In addition, society would benefit from the enhanced scope 
under the UN Regulations that restricts noise from backfire, sound actuators, and sound 
enhancement systems.   

Impact per type (+ positive; - negative; o neutral)  
Environmental  Safety  

Social 

o 

o 

+ 

Cost savings for the automotive value chain 

There is no clear data on the number of OEMs applying only EU Regulation No 540/2014 
and  not  the  UN  Regulations  on  noise,  but  it  is  expected  that  the  streamlining  of  the 
regulatory requirements will remove unnecessary cost for any OEM operating globally and 
facing double certification.  

3.5.  Regulation  (EU)  2018/858  on  the  approval  and  market  surveillance  of 
motor  vehicles  and  their  trailers,  and  of  systems,  components  and 
separate technical units intended for such vehicles 

Regulation  (EU)  2018/858  is  a  framework  for  the  approval  and  market  surveillance  of 
motor vehicles in the European Union that replaced the previous Directive 2007/46/EC. 
Its  objective  is  to  enhance  the  quality  and  independence  of  motor  vehicle  testing, 
strengthen checks on cars already on the market, and increase overall EU oversight of the 
automotive sector.  

The regulation increases the quality and independence of vehicle type-approval and testing 
by ensuring technical services have robust management systems and qualified personnel. 
Furthermore, to ensure continued compliance, the regulation mandates increased checks 
on vehicles that have already been approved and are on the market. It includes measures 
to  strengthen  the  process  for  enforcing  conformity  of  production  requirements  and  to 
regularly  verify  the  performance  of  national  approval  authorities.  In  addition,  there  are 
provisions for type-approval of new technologies or concepts that may be incompatible 
with existing regulations to encourage innovation.  

30 

 
 
 
3.5.1. 

New vehicle subcategory for small cars 

Issue description 

Between  2020  and  2024,  vehicle  prices  in  the  EU  rose  18.3%,  according  to  official 
European statistics published by Eurostat. Between 2020 and 2024, vehicle prices in the 
EU rose 18.3% , (35) This is even more pronounced for battery-electric vehicles, partially 
due  to  manufacturers  having  started  electrification  upmarket  with  larger  vehicles  and 
SUVs  to  off-set  the  costs  associated  with  batteries  (making  up  to  40%  of  total  EV 
value(36)).  Between  2020  and  2024,  vehicle  prices  in  the  EU  rose  18.3%,  according  to 
official European statistics published by Eurostat. (37) This is even more pronounced for 
battery-electric  vehicles,  partially  due  to  manufacturers  having  started  electrification 
upmarket  with  larger  vehicles  and  SUVs  to  off-set  the  costs  associated  with  batteries 
(making up to 40% of total EV value (38). At the same time, yearly sales of small passenger 
cars, i.e., segments A and B, in the EU have decreased by 1.6 million units since 2019. 
European car manufacturers’ market share has been eroded by competition from China. 
There  is  therefore  a  need  to  develop  a  new  sub-category  of  small  electric  car  made  in 
Europe that would give consumers more choice of zero-emission models and would benefit 
European manufacturers.  

Developing  a  new  sub-category  of  small  affordable  electric  car  would  enable  Member 
States to developed targeted incentives for such cars, providing benefits to both citizens 
through increased choice and to OEMs, who would benefit from the demand in this market 
segment. To ensure that the car would indeed be small, it should not exceed 4.2 metres in 
length. This length was chosen by comparing the available electric models on the market 
that  are  under  EUR  25,000,  which  demonstrates  that  there  is  very  little  choice  in  the 
market, with only 12 battery-electric vehicle models of this size with a sales price (before 
purchase incentives) below EUR 25,000. 

Stakeholder views 

In bilateral discussions, one OEM suggested the introduction of a new vehicle category for 
small cars, with lighter regulatory requirements. Other OEMs saw the need for a label or 
vehicle subcategory as a basis for targeted support measures.  

The  discussion  in  the  Motor  Vehicle  Working  Group  on  2  October  and  subsequent 
roundtable discussions with stakeholders from industry and civil society showed negative 
views  on  a  possible  introduction  of  a  new  vehicle  category,  but  broad  support  for  a 
subcategory within the established passenger cars (M1) vehicle category. OEMs and some 

(35)  Source: 

Eurostat, 

HICP 

- 

annual 

data 

(average 

index 

and 

rate 

of 

change)[prc_hicp_aind__custom_19207785] 

(36)  Reshaping the Road Ahead: Exploring Supply Chain Transformations in the EU Automobile Industry. 
https://single-market-economy.ec.europa.eu/publications/reshaping-road-ahead-

Available 
exploring-supply-chain-transformations-eu-automobile-industry_en 

at: 

(37)  Source: 

Eurostat, 

HICP 

- 

annual 

data 

(average 

index 

and 

rate 

of 

change)[prc_hicp_aind__custom_19207785] 

(38)  Reshaping the Road Ahead: Exploring Supply Chain Transformations in the EU Automobile Industry. 
https://single-market-economy.ec.europa.eu/publications/reshaping-road-ahead-

Available 
exploring-supply-chain-transformations-eu-automobile-industry_en 

at: 

31 

 
 
 
 
 
 
civil society organisations also expressed a preference for this subcategory to be defined 
by length only to not interfere with battery size. 

OEMs  asked  for  regulatory  simplification  measures  for  such  a  vehicle  subcategory,  in 
particular  a  “freezing”  of  regulatory  requirements  to  avoid  costly  redevelopment  of 
existing vehicle types for small cars, and targeted support measures of fiscal and non-fiscal 
nature.  Civil  society  organisations  saw  a  need  to  incentivise  small  electric  vehicles  but 
expressed concerns about possible derogations from existing safety requirements. Member 
State  authorities  also  expressed  concerns  about  any  derogations  from  regulatory 
requirements. 

Proposed amendment 

The  proposed  amendment  consists  of  the  introduction  in  Annex  I,  Part  A,  point  2  of 
Regulation (EU) 2018/858 of a new point 2.4 defining a sub-category for small electric 
vehicles of category M1 (‘M1E’), based on a maximum length of 4.2 metres.  

Expected impact 

By  introducing  a  new  sub-category  of  passenger  cars,  the  ‘M1E’  classification, 
policymakers at both the EU and national levels will have a legal definition of small cars 
that can be used for targeted support schemes using fiscal and/or non-fiscal incentives to 
stimulate production. 

This amendment will facilitate the introduction of targeted simplification measures in EU 
Regulations when appropriate and allows Member States to target fiscal and/or non-fiscal 
incentives to support demand for small electric vehicles in line with State aid rules, where 
applicable.  This  will  lead  to  positive  impacts  on  the  environment  in  line  with  the  CO2 
Regulation and will bring societal benefits by giving consumers more choice when buying 
a zero-emission vehicle.   

Impact per type (+ positive; - negative; o neutral)  

Environmental 

Safety  

Social 

+ 

o 

+ 

Cost savings for the automotive value chain  

The  proposed  amendment  will  provide the  industry  with  some  limited  gains.  However, 
targeted  incentive  mechanisms  and/or  simplification  measures  for  this  sub-category  of 
small electric cars can lead in the future to important cost savings for the automotive value 
chain and consumers. 

3.5.2. 

Improving electric vehicle to grid interoperability   

Issue description  

With electric vehicle technology evolving rapidly and the penetration of electric vehicles 
on the market  increasing, interoperability between vehicles, the charging  infrastructure, 
and the electricity grid is becoming increasingly critical.  

32 

 
 
 
 
 
 
 
 
 
 
 
The motor vehicle type-approval framework does currently not permit the introduction of 
technical requirements to address the vehicle’s interaction with charging infrastructure and 
the  electricity  grid.  There  is  an  increasing  risk  of  fragmentation  with  certain  technical 
requirements  for  motor  vehicles  being  introduced  outside  of  the  vehicle  type-approval 
framework,  as  is  the  case  with  the  Renewable  Energy  Directive  where  Art.  20a  (3) 
introduces requirements on the access to battery data for vehicle manufacturers.  

Similarly,  the  implementation  of  the  revised  Network  Codes  that  address  market  rules, 
system  operation,  and  grid  connection  rules,  will  establish  technical  requirements  for 
manufacturers  of  electric  vehicles.  Furthermore,  improved  interoperability  will  become 
important  to  support  faster  development  of  new  services  such  as  vehicle-to-grid  (V2G) 
functionalities that can contribute to stabilising electricity supply and balance peak demand 
while  lowering  energy  costs  for  vehicle  owners  and  supporting  greater  integration  of 
renewable power.  

Stakeholder views 

OEMs have called for a repeal of Art. 20a (3) of the Renewable Energy Directive. 

Stakeholders from the energy industry, grid operators, and charging operators have called 
for the inclusion of the specifications contained in ISO 15118-20 into the type-approval 
framework to enable Vehicle-to-Grid (V2G) communication for electric vehicles. OEMs 
called  for  the  incorporation  of  network  codes  into  the  motor  vehicle  type-approval 
framework to create legal certainty for OEMs vis-à-vis compliance with vehicle-to-grid 
interoperability  requirements,  but  did  not  consider  the  ISO  15118-20  standard  mature 
enough to be included in the type-approval framework.  

Proposed amendment 

Article 5 of Regulation (EU) 2018/858 is amended as follows: 

a) 

the following paragraph 4 is inserted:  

‘The  Commission  is  empowered  to  adopt  delegated  acts  in  accordance  with  Article  82 
supplementing  this  Regulation  by  laying  down  technical  requirements  as  regards  the 
communication  and  physical  interconnection  of  pure  electric  vehicles  (PEV)  and  off-
vehicle charging hybrid electric vehicles (OVC-HEV) with the recharging infrastructure, 
the  electricity  grid  and  the  stationary  power  systems  capable  of  supporting  smart  and 
bidirectional charging functionalities.’ 

Expected impact 

The  proposed  amendment  is  expected  to  help  to  facilitate  the  integration  of  electric 
vehicles  into  the  energy  system,  with  positive  effects  from  optimisation  of  the  energy 
system. . The safety and social impacts are neutral. 

Impact per type (+ positive; - negative; o neutral)  

Environmental 

Safety  

Social 

+ 

o 

o 

33 

 
 
Cost savings for the automotive value chain 

The proposed amendment will reduce the costs for automotive manufacturers in terms of 
having  clear  approval  mechanisms  for  network  codes,  avoiding  legal  uncertainty  for 
conformity  with  this  legislation  and  avoiding  unnecessary  administrative  burden  from 
technical requirements outside motor vehicle legislation. However, the exact cost savings 
will depend on future secondary legislation. 

4.  FURTHER SIMPLIFICATION MEASURES TO BE CONSIDERED OUTSIDE THE OMNIBUS 

The  Automotive  Omnibus  includes  only  a  limited  number  of  targeted,  but  effective 
simplification  measures.  In  the  simplification  context,  the  Association  of  European 
Automotive  Manufacturers  (ACEA)  had  cited  approximately  130  upcoming  pieces  of 
legislation  affecting  the  automotive  industry.  However,  this  list  includes  25  pieces  of 
horizontal legislation. (39) 

The  list  includes  upcoming  requirements  in  Battery  Regulation  delegated  acts  (carbon 
footprint, due diligence), Euro 7 Implementing Acts for light-duty vehicles and for heavy-
duty  vehicles,  CO2  in-service  verification,  potential  Data  Act  Delegated  Acts,  nine 
potential  REACH  restrictions,  nine  future  requirements  in  the  End-of-Life  of  Vehicles 
Regulation (which is still in trilogues). The Euro 7 secondary legislation does not add any 
new requirements, but clarifies the methods needed for emissions type-approval, giving 
manufacturers legal certainty.  

Furthermore, the list from ACEA includes nearly 70 updates of UN Regulations, which 
are not all mandatory in EU legislation at this point. Of these, the European Commission 
has  identified  approximately  40  amendments  of  existing  UN  Regulations  or  new  UN 
Regulations.  

Stakeholders raised other issues concerning simplification of the regulatory framework for 
the automotive industry that are not addressed in this Omnibus but will be considered in 
the further development and implementation of motor vehicle legislation.  

4.1.  Grouping  all  new  regulatory  requirements  into  batches,  becoming 
mandatory at the same time to ease compliance for manufacturers and 
reduce homologation costs 

The  Association  of  European  Automotive  Manufacturers  (ACEA)  proposed  that  the 
Commission  group  all  regulatory  requirements  into  batches  with  the  same  mandatory 
application  at  a  single  date  per  year  to  ease  compliance  for  manufacturers.  For 
requirements stemming from motor vehicle type-approval, this can be implemented by the 
Commission  when  setting  the  mandatory  application  dates  in  secondary  legislation  – 
unless the legislator has established a different date in the legal act.  

(39)  REACH Regulation; Classification, Labelling, and Packaging of substances and mixtures Regulation; 
Persistent Organic Pollutants Regulations; Battery Regulation; Renewable Energy Directive; Data Act; 
Regulation on fluorinated greenhouse gases; Restriction of hazardous substances Directive; Critical Raw 
Materials Act; European Sustainable Products Regulation; Radio Equipment Directive; Low-Voltage 
Directive; Electromagnetic Compatibility Directive; Pyrotechnic Articles Directive; Alternative Fuels 
Infrastructure  Regulation;  Artificial  Intelligence  Act;  Market  Surveillance  Regulation;  Pressure 
Equipment  Directive;  Pressure  Vessels  Directive;  Transportable  Pressure  Equipment  Directive; 
Intelligent  Transport  Systems  Directive;  Network  Code  on  Grid  Connectors;  Cyber  Resilience  Act; 
Machinery Regulation; Roadworthiness Directive. 

34 

 
 
However, it would not be appropriate to set application dates for regulatory requirements 
affecting several industrial sectors based solely on the needs of the automotive industry. 
When  it  comes  to  primary  legislation,  be  it  horizontal  or  sector-specific,  it  is  the 
prerogative of the legislator to establish the application dates, taking into consideration the 
implications on businesses and enforcement authorities. 

4.2.  Respecting  lead  time  for  industry  between  the  adoption  of  regulations 

and the application dates 

ACEA and other industry stakeholders proposed in addition that the Commission recognise 
the  need  for  lead  time  for  the  industry  to  adjust  to  new  regulatory  requirements,  in 
particular for heavy-duty vehicles that have longer development cycles. In the Industrial 
Action Plan for the EU automotive sector, the Commission has committed to give, when 
making  legislative  proposals,  sufficient  lead  time  for  the  industry  to  reflect  such  new 
regulatory requirements in the product development process. This is a general principle, 
but it cannot be turned into a legal requirement in an Omnibus Act. 

4.3.  Applying new regulatory requirements for new types of vehicles only and 

not vehicles already type-approved 

ACEA  requested  that  new  regulatory  requirements  should  only  apply  to  new  types  of 
vehicles  and  not  to  existing  type-approved  vehicles  to  avoid  costs  associated  with  the 
redevelopment or redesign of existing type-approved vehicles. It is easier to develop and 
design  new  vehicle  types  according  to  the  regulatory  requirement,  while  a  continuous 
redevelopment or redesign of type-approved vehicles for new regulatory requirements can 
lead to additional costs. However, it is not possible in horizontal legislation outside motor 
vehicle type-approval to distinguish between new vehicle types and existing vehicle types. 
Horizontal legislation applies to products placed on the market.  

In motor vehicle type-approval legislation, there is always a different application date for 
new vehicle types and  for all new vehicles  (i.e., for existing  vehicle types) to  take into 
account  the  need  for  redevelopment.  In  certain  cases,  such  as  the  eCall  Regulation, 
requirements have only been established for new vehicle types. The decision not to regulate 
existing vehicle types needs to be taken on a case-by-case basis, considering on the one 
hand the costs of redevelopment of existing vehicle types, which can have a high impact 
on small cars with lower margins, and on the other hand the societal benefits of the new 
regulatory requirements.  

4.4. 

Simplifying the type-approval framework  

With the increasing speed of innovation in the industry, in particular trends on automated 
driving and software updates, it is appropriate to assess the simplification potential in the 
EU  type-approval  framework  for  motor  vehicles.  Regulatory  complexity  can  be  a 
constraint  for  EU  manufacturers  in  global  competition  with  manufacturers  from  other 
jurisdictions.  

In  2026,  the  Commission  will  undertake  an  evaluation  of  the  Motor  Vehicle  Type-
Approval  Framework  Regulation,  Regulation  (EU)  2018/858.  This  will  help  assess  the 
potential  to  reduce  testing  and  reporting  costs  for  the  automotive  industry.  Preliminary 
analysis by the Commission services, taking into account suggestions from stakeholders, 
has identified the potential to reduce the number of laboratory tests during type-approval 
by using more virtual testing and by using risk-assessment practices to assess how ex-ante 
tests  can  be  best  combined  with  in-use  monitoring  (as  already  applied  in  the  Euro  7 

35 

 
Regulation,  where  lighter  ex  ante  tests  are  complemented  by  on-board  monitoring  of 
emission performance).   

Consideration of further specific simplification measures 

Several  stakeholders  requested  simplification  measures  that  can  be  addressed  through 
secondary legislation. Below is a non-exhaustive overview of topics that will be considered 
for further simplification. 

4.5.  Type-approval framework for electric trucks with range extenders  

Several  heavy-duty  vehicle manufacturers requested the  current  emission  type-approval 
provisions for heavy-duty vehicle engines be made more flexible to make extended-range 
electric vehicles (EREV) economically viable. EREV are electric vehicles that use a small 
internal combustion engine (ICE) or another type of generator to recharge the main traction 
battery, but the engine does not directly power the wheels. This allows the driver to rely 
on electric power until the battery is low, at which point the range extender kicks in to 
recharge it, allowing for continuous driving and eliminating range anxiety.  

In type-approval terms, EREVs are the same legal category, ‘off-vehicle charging hybrid 
electric vehicle,’ as plug-in hybrid electric vehicles. During the current ramp-up of electric 
charging infrastructure for heavy-duty vehicles, extended-range electric vehicles (EREV) 
might be a potential solution to extend the range of a full battery-electric vehicle. 

The current emission type-approval regulations (Euro VI and in the future Euro 7) do not 
provide flexibility for such technologies, as the engine for charging the battery would have 
to be tested against the same requirements as an internal combustion engine used for the 
propulsion of the vehicle. It seems appropriate to develop new test methods for the type-
approval  of electric trucks with  range  extenders  in  Euro 7 implementing legislation for 
heavy-duty vehicles, without prejudging the CO2 determination of such vehicles.  

4.6. 

 Direct vision requirement for trucks  

Several  manufacturers  and  components  suppliers  argued  that  the  Direct  Vision 
requirements are very costly and equivalent levels of safety could be achieved through less 
burdensome technical solutions, such as driver assistance systems, without having to re-
design the truck cabin to meet the direct vision requirements.  

Direct vision requirements for heavy-duty truck and buses were introduced in Regulation 
(EU) 2019/2144 to decrease blind spots and thus  improve the safety of vulnerable road 
users like pedestrians and cyclists. Vehicles are assessed and given a star rating (from 0 to 
5)  based  on  how  much  a  driver  can  see  directly  through  the  windows,  with  the  rating 
usually fixed at the point of manufacture. Vehicles with a lower star rating (e.g., 0, 1, or 2) 
must be fitted with a Progressive Safe System to be compliant.  

The Direct Vision requirements are considered an important achievement for the protection 
of  vulnerable  road  users  from  accidents  with  heavy-duty  vehicles.  In  the  absence  of  a 
requirement to achieve the same result with less costly solutions, a simplification of the 
existing requirement would have serious negative consequences on road safety. However, 
the Commission recognises the cost on vehicle manufacturers and is considering a delay 
of mandatory application of next- generation Direct Vision requirements developed in the 
UN context.   

36 

 
4.7. 

 In-service CO2 verification  

Tyre manufacturers have raised strong concerns about the requirement that new original 
equipment tyres are used for the in-service verification of heavy-duty vehicles under the 
Heavy-Duty Vehicles CO2 Emissions Regulation, although such tyres are already subject 
to  type-approval  testing  under existing  legislation. This  requires a further technical  and 
legal assessment and could be addressed either in the upcoming Revision of the Heavy-
Duty  Vehicles  CO2  Emissions  Regulation  (due  December  2027)  or  in  secondary 
legislation under that Regulation. 

5.  CONCLUSIONS 

The  measures  proposed  in  the  Automotive  Omnibus  would  simplify  requirements  and 
streamline procedures under Regulation (EC) No 561/2006, Regulation (EC) 2019/2144, 
Regulation (EC) 2024/1257, Regulation (EC) 540/2014, and Regulation (EU) 2018/858, 
in  addition  to  a  separate  Directive  proposal  (also  adopted  as  part  of  the  automotive 
package)  amending  Directive  92/6/ECC,  with  the  aim  and  expectation  of  reducing 
administrative  cost  for  industry  and  authorities,  while  maintaining  a  high  level  of  road 
safety and environmental protection. 

As regards tachograph obligations for electric Vans with GVW between 3.5 and 4.25 
tonnes, the proposed amendment will reduce administrative burden for their owners and 
will facilitate the uptake of e-Vans in line with the CO2 Regulation, thus delivering positive 
benefits for the environment. The savings from the proposed changes could amount to at 
least EUR 134 000 000 and up to EUR 471 000 000 in 2027, the first full year that the 
measure would likely take effect. The range of cost savings represents the possible ramp-
up (estimated at 3.5x) associated with the amendment, substantially accelerating the move 
to zero-emissions road transport by levelling the playing field between electric vans and 
diesel vans with the same payload. 

As  regards  tachograph  obligations  for  motorhomes  used  exclusively  for  private 
transport, the proposed measure will reduce costs for manufacturers and will create legal 
clarity  regarding  installation  of  tachographs  following  the  CJEU  judgement  in  case 
C666/21. The savings from the proposed changes could amount to at least EUR 550 000 
in 2027, the first full year the measure would take effect.  

As regards speed limiting devices for electric vans with a GVW between 3.5 and 4.25 
tonnes, the proposed measures will reduce costs for manufacturers. The savings from the 
proposed changes could amount to at least EUR 57 100 000  and up to EUR 199 900 000 
in 2027, the first full year the measure would take effect.  

As regards laboratory tests of low temperature for emissions in light-duty vehicles, the 
proposed measures  will reduce costs for manufacturers. The savings from the proposed 
changes could amount to at least EUR 155 000 000 and up to 825 000 000 in 2027, the 
first full year the measure would take effect.    

As regards vehicle types for Euro 7 engine (Separate Technical Unit) type-approval, 
the proposed measures will reduce costs for manufacturers. The savings from the proposed 
changes could amount to at least EUR 263 000 000 and up to EUR 789 000 000 in 2027, 
the first full year the measure would take effect.  

37 

 
As regards OBM and OBFCM data infrastructure and common methods, the proposed 
measures  will  reduce  administrative  costs  for  manufacturers.  The  savings  from  the 
proposed changes could amount to at least EUR 150 000 and up to EUR 2 400 000 in 
2027, the first full year the measure would take effect. 

The  digitalisation  of  reporting  requirements  for  on-board  fuel  and  electric  energy 
consumption monitoring (OBFCM) devices and on-board monitoring (OBM) systems can 
reduce the administrative burden for authorities and facilitate analysis of the accompanying 
data. The electric vehicle to grid interoperability measure will facilitate the penetration of 
electric vehicles on the market.   

The proposed repeal of the EU’s noise regulation in favour of the UN Regulations on noise 
will  deliver  societal  benefits  by  reflecting  the  latest  technological  innovations.  The 
amendments  to  the  type-approval  framework  to  create  a  new  sub-category  for  small 
affordable electric vehicles will facilitate the creation of demand-side measures. 

Beyond  direct  cost  savings,  these  regulatory  adjustments  are  expected  to  enhance 
operational  efficiency  for manufacturers and their customers,  in particular SMEs. 
Overall,  the  amendments  support  a  more  efficient  regulatory  environment,  allowing 
industry to maintain compliance while fostering long-term resilience and innovation. 

Savings for all measures  

(in million euro) 

One-off 

Recurrent  
annual average 
savings (40) 

Cumulative  
recurrent cost savings for 
2027, 2028, 2029 

Businesses 

SMEs 

Administrative 
cost savings 

SMEs 

Adjustment 
cost savings 

N/A 

N/A 

Large 
companies 

Administrative 
cost savings 

N/A 

• 

• 

• 

• 

• 

37.6 (e-Van 
tachograph) 

126 (e-Van 
tachograph) 

58.3 (Speed 
Limiting 
Device) 
10.6 (e-Van 
tachograph) 

00.15 (Euro 7 - 
OBM and 
OBFCM data 
infrastructure) 

• 

• 

• 

• 

• 

113 (e-Van 
tachograph) 

378 
tachograph) 

(e-Van 

175 
Limiting Device) 

(Speed 

32 (e-Van 
tachograph) 

0.45 (Euro 7 - 
OBM and 
OBFCM data 
infrastructure) 

(40)  Recurrent cost savings are calculated by dividing by three the cumulative savings for 2027, 2028 and 

2029  

38 

 
 
 
 
 
 
 
 
 
 
 
 
 
• 

• 

• 

• 

35.6 (e-Van 
tachograph) 

16.3 (Speed 
Limiting 
Device) 

155 (Euro 7 
low-
temperature 
emission test) 

263 (Euro 7 
vehicle 
category vs 
vehicle type) 
48.5 

654.3 

• 

• 

• 

• 

107 (e-Van 
tachograph) 

49 (Speed Limiting 
Device) 

465  (Euro  7  low-
temperature 
emission test)  

789 (Euro 7 vehicle 
category vs vehicle 
type)  

145.45 

1 963 

N/A 

N/A 

0.55 (Motorhome 
Tachograph) 

1.65 (Motorhome 
Tachograph) 

Large 
companies 

Adjustment 
cost savings 

N/A 

All 

All 

Citizens 

Administrative 
cost savings 

Adjustment 
cost savings 

Administrative cost savings 

Adjustment cost savings 

Member States 

N/A 

N/A 

N/A 

N/A 

Administrative cost savings 

N/A 

Adjustment cost savings 

12.5 (Euro 7 - 
OBM and OBFCM 
data infrastructure) 

2.5 (Euro 7 - OBM and 
OBFCM data 
infrastructure) 

7.5 (Euro 7 - OBM and 
OBFCM data infrastructure) 

N/A 

N/A 

Totals  

Total administrative cost 
savings 

Total adjustment cost 
savings 

Total Savings 

N/A 

12.5 

12.5 

51 

655 

706 

153 

1 965 

2 118 

39 

 
 
 
 
 
 
 
 
 
 
ANNEX I: METHODOLOGY AND EVIDENCE COLLECTED 

In the context of the Strategic Dialogue on the Future of the EU Automotive Industry in 
January 2025, industry leaders raised the issue of regulatory simplification. This led to the 
development of the Automotive Industrial Action Plan, which was adopted in March 2025. 
One of the actions in the Automotive Industrial Action Plan was a simplification package 
(Automotive Omnibus).  

In the months following the Strategic Dialogue, European Commission services gathered 
input  from  stakeholders  in  the  automotive  sector.  Trade  associations,  individual 
companies, civil  society, and other stakeholders  contributed policy simplification ideas, 
which  were  assessed  by  the  Commission  along  two  axes:  the  potential  to  reduce 
administrative  costs  for  the  automotive  industry  while  not  leading  to  adverse  social  or 
environmental impacts, and respecting the scope of an automotive-specific Omnibus. 

Furthermore,  numerous  bilateral  meetings  with  automotive  manufacturers,  automotive 
component suppliers, automotive industry associations, and civil society were held. The 
outcomes  of  these  bilateral  meetings  contributed  to  identifying  feasible  simplification 
measures within the scope of the Automotive Omnibus. (41)  

At  the  beginning  of  October,  based  on  stakeholder  input,  the  Commission  presented 
possible  simplification  measures  at  a  meeting  of  the  Motor  Vehicle  Working  Group 
(MVWG), a Commission expert group made up of Member State representatives and a 
broad  range  of  stakeholders  from  the  automotive  industry  and  civil  society.  Those 
measures that were presented to the MVWG have been explained in the Staff Working 
Document. 

On 14 October, after analysing the feedback from the Motor Vehicle Working Group, a 
Targeted  Stakeholder  Consultation  in  the  form  of  a  survey  was  sent  to  stakeholders 
impacted  by  the  Automotive  Omnibus  simplification  package,  including:  automotive 
manufacturers,  automotive  component  suppliers,  automotive  aftermarket  operators, 
transport operators, the respective business associations of all the above as well as business 
associations of motorcycles and large motorhomes, civil society, national type approval 
authorities, and other ministries. The objective of this targeted stakeholder consultation 
was firstly to collect evidence about the regulatory, social, and environmental impacts of 
the envisaged simplification measures, and secondly to receive additional suggestions for 
simplification.  The consultation also sought quantitative data for the cost savings that the 
concerned businesses expect to derive from the envisaged measures. Of the 130 invited 
stakeholders, the European Commission received 68 responses.  

ANNEX  II:  ORGANISATIONS  THAT  WERE  CONSULTED  AS  PART  OF  THE  STAKEHOLDER 
CONSULTATION  

Organisations that the Targeted Stakeholder Consultation was sent to: 

1.  All Members of the Working Group on Motor Vehicles (Error! Bookmark not 

defined.) 

(41)  See Process for identifying amendments for this Omnibus in the Introduction for more details on the 

criteria. 

40 

 
 
 
2.  In addition, the following organisations and companies: 

Name of the organisation 
that replied 

SMMT - Society of Motor 
Manufacturers and Traders 

UETR – European Union of 
Road Transport 

CONFETRA – 
Confederazione Generale 
Italiana dei Trasporti e della 
Logistica 

FNTR - Federation 
Nationale de Transports 
Routiers 

BGL - Bundesverband 
Güterkraftverkehr Logistik 
und Entsorgung 

ZMPD - European Road 
Safety Charter 

TLP - Transport i Logistyka 
Polska 

Sector 
(industry/NGO/Public 
Authority/Academy) 

Business Association 

Business Association 

Business Association 

Business Association 

Business Association 

Business Association 

Business Association 

TLN - Transport en 
Logistiek Nederland 

Business Association 

IndustriAll 

Business Association 

DHL 

Amazon 

Fleet Operator 

Fleet Operator 

Recharge Batteries 

Business Association 

Milence 

ZF Group 

Valeo 

Automotive Industry 
Supplier 

Automotive Industry 
Supplier 

Automotive Industry 
Supplier 

41 

 
Mahle 

Forvia 

Automotive Industry 
Supplier 

Automotive Industry 
Supplier 

ChargeUp Europe 

Business Association 

Bosch 

Daimler Truck 

Volvo Group 

Iveco  

MAN 

Scania 

Tesla 

Nissan 

Honda 

Volvo cars 

Ford 

Hyundai/Kia 

Toyota Europe 

BMW 

Mercedes 

Automotive Industry 
Supplier 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

42 

 
Stellantis 

Renault 

Original Equipment 
Manufacturer 

Original Equipment 
Manufacturer 

Organisations that replied to the stakeholder consultation 

Name of the organisation 
that replied 

ACEM - Association des 
Constructeurs Européens de 
Motocycles 

Sector 
(industry/NGO/Public 
Authority/Academy) 

Business Association 

ADPA - Automotive Data 
Publishers' Association 

Business Association 

AECC - Association for 
Emission Control by 
Catalyst  

AIRC-International 
(Association Internationale 
des Réparateurs en 
Carrosserie) 

Business Association 

Business Association 

Amazon Europe Core 
SARL 

Fleet operator 

BMW Group 

Bundesverband 
Güterkraftverkehr Logistik 
und Entsorgung (BGL) e.V. 

Vehicle manufacturer 
(OEMs) 

Business Association 

Caravaning Industrie 
Verband e.V. 

Business Association 

CECRA (European Council 
for Motor Trades and 
Repairs) 

CITA (International Motor 
Vehicle Inspection 
Committee) 

Business Association 

Business Association 

43 

 
 
CLCCR (International 
Association of the Body and 
Trailer Building Industry) 

Business Association 

CLEPA European 
Association of Automotive 
Suppliers 

Automotive parts and 
components supplier 

CONEBI (Confederation of 
the European Bicycle 
Industry) 

Confederazione Generale 
Italiana dei Trasporti e della 
Logistica (CONFETRA) 

Business Association 

Business Association 

CSDD (Road Traffic Safety 
Directorate) 

Type approval authority 
(Latvia) 

Cummins  

Daimler Truck AG 

Automotive parts and 
components supplier 

Vehicle manufacturer 
(OEMs) 

Deutsche Post AG 

Fleet operator 

E-Mobility Europe  

Business Association 

ESCA - European Small 
Volume Car Alliance  

Business Association 

Eurogas Aisbl 

Business Association 

European Automobile 
Manufacturers' Association  
(ACEA) 

Business Association 

European Caravan 
Federation (ECF) 

European Cyclists' 
Federation (ECF) 

Business Association 

Non-governmental 
organisation (NGO) 

European Environmental 
Bureau 

Non-governmental 
organisation (NGO) 

European Garage 
Equipment Association 

European Tuning 
Organization (E.T.O) 

Business Association 

Business Association 

44 

 
Executive Agency Road 
Transport Administration 

Type approval authority 
(Bulgaria) 

Federal Ministry of 
Innovation, Mobility and 
Infrastructure 

Type approval authority 
(Austria) 

Federal Public Service 
Mobility and Transport (as 
Belgian Market Surveillance 
authority and Vehicle 
Regulation authority) 

Market surveillance 
authority (Belgium) 

Federal Roads Office 
FEDRO  

Market surveillance 
authority (Switzerland) 

Federation of European 
Manufacturers of Friction 
Materials (FEMFM) 

FIA (Federation 
Internationale de 
l'Automobile) 

FIGIEFA - Automotive 
Aftermarket Distributors 

Ford Motor Company 

FORVIA 

Honda Motor Europe (both 
vehicle AND motorcycle 
manufacturer) 

Business Association 

Business Association 

Business Association 

Vehicle manufacturer 
(OEMs) 

Automotive parts and 
components supplier 

Vehicle manufacturer 
(OEMs) 

Institute for Transport 
Sciences (KTI) 

Research institute 
(Hungary) 

Insurance Europe 

Business Association 

International Road 
Transport Union (IRU) 

Iveco Group 

Japan Automobile 
Manufacturers Association 

Business Association 

Vehicle manufacturer 
(OEMs) 

Business Association 

45 

 
Kraftfahrt-Bundesamt 
(Federal Motor Transport 
Authority) 

Type approval authority 
(Germany) 

Leaseurope 

Business Association 

Liquid Gas Europe 

Business Association 

MAHLE International 
GmbH 

Automotive parts and 
components supplier 

MAN Truck & Bus SE 

Vehicle manufacturer 
(OEMs) 

Ministry of Industry and 
Tourism 

Type approval authority 
(Spain) 

Ministry of Infrastructure 
and Transport 

Type approval authority 
(Italy) 

Ministry of Transport 

Ministry of Transport  

RDW (Rijksdienst voor het 
Wegverkeer) 

Renault Group 

Type approval authority 
(Czechia) 

Type approval authority 
(Slovakia) 

Type approval authority 

Vehicle manufacturer 
(OEMs) 

Road Safety Authority 
(Ireland) 

Market surveillance 
authority 

Robert Bosch GmbH 

Scania AB 

Automotive parts and 
components supplier 

Vehicle manufacturer 
(OEMs) 

State Office for Metrology 

Type approval authority 

Swedish Transport Agency 

Type approval authority 

the Danish Road Traffic 
Authority 

Toyota Motor Europe 

Type approval authority 

Vehicle manufacturer 
(OEMs) 

46 

 
Transport & Environment / 
T&E (European Federation 
for Transport and 
Environment AISBL) 

Non-governmental 
organisation (NGO) 

Transport and Logistic 
Netherlands 

Business Association 

Transportowy Dozór 
Techniczny 

Type approval authority 
(Poland) 

TyresEurope 

Business Association 

Business Association 

Vehicle manufacturer 
(OEMs) 

Vehicle manufacturer 
(OEMs) 

Business Association 

Verband der 
Automobilindustrie e.V. 

Volkswagen Group 

Volvo Car Corporation 

Zentralverband Karosserie- 
und Fahrzeugtechnik (ZKF) 
and AIRC (Association 
Internationale des 
Réparateurs en Carrosserie) 

Organisations that provided detailed proposals for the Omnibus: 

European Automobile Manufacturers' Association (ACEA) 

German Association of the Automotive Industry (VDA)  

European Association of Automotive Suppliers (CLEPA) 

Honda 

European Association of Motorcycle Manufacturers (ACEM) 

BMW 

European Tyre and Rubber Manufacturers Association 

47