Revision of Roadworthiness Package - Open
Public Consultation 2022

Introduction
The Roadworthiness Package (RWP) is a set of EU rules aimed at establishing a single European area for technical
inspections with an effective and more efficient inspection system. These EU rules consist of the following
Directives:

Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers;
Directive 1999/37/EC of 29 April 1999 as amended by Directive 2014/46/EU on the Registration Documents
for Vehicles;
Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles
circulating in the Union.

The main aim of the Periodic Roadworthiness Testing Directive is to improve road safety and the environment by
setting minimum standards for periodic tests of vehicles and their trailers used on public roads in the EU.
The main aim of the Vehicle Document Registration Directive is to regulate the withdrawal and the cancellation of
registration certificates of vehicles, to establish requirements on electronic registration databases, and the follow
up of roadworthiness test results, re-registration and destruction of vehicles.
The main aim of the Roadside Inspection Directive is to improve road safety and the environment. The Directive
establishes minimum requirements for technical roadside inspections of commercial vehicles circulating within the
the EU.
The European Commission is inviting the general public and stakeholders to express their opinion on the impact of
these EU rules as well as on possible policy measures and potential impacts of their revision. Information received in
this consultation will support the Evaluation and the Impact Assessment that the European Commission is currently
carrying out.

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*First name

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This list does not represent the official position of the European institutions with regard to the legal status or policy of the
entities mentioned. It is a harmonisation of often divergent lists and practices.

Afghanistan

Djibouti

Libya

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Åland Islands

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Republic

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and the
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and Antarctic
Lands

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and the South
Sandwich
Islands
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Jan Mayen

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Sweden

Bonaire Saint

Guadeloupe

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Guam

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Eustatius and
Saba
Bosnia and
Herzegovina
Botswana

Guatemala

X Netherlands

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New Caledonia

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Brazil

Guinea

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Guyana

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The Gambia

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Bulgaria

Heard Island and

Niue

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Islands

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United Arab

Guinea

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Italy

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United Kingdom

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Jamaica

Peru

United States

Cocos (Keeling)
Islands

Japan

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Minor Outlying
Islands

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Portugal

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Curaçao

Laos

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Cyprus

Latvia

Saint Barthélemy

Yemen

Czechia

Lebanon

Saint Helena

Zambia

Ascension and Tristan da Cunha
Democratic

Lesotho

Republic of the

Saint Kitts and

Zimbabwe

Nevis

Congo
Denmark

Liberia

Saint Lucia

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A: Additonal information about the respondent
1) Please indicate if you represent a specific interest:
Inspection bodies
Testing equipment manufacturers
Vehicle and equipment manufacturers/ suppliers
Automotive/ motorcycle federations
Automobile clubs
Other (please specify below*)
specific interest
*

No

The Ministry of Infrastructure and Water Management is the Dutch Ministry competent for all policy related
to transport. The ministry bears policy responsibility for the policy field in which public authorities such as the
RDW and ILT carry out public tasks.
The RDW (Netherlands Vehicle Authority) contributes to ensuring that road transport in the Netherlands is as
safe, clean, economically viable and well-regulated as possible. Our tasks lie in the areas of the licensing of
vehicles and their trailers, and of systems, components and separate technical units intended for such
vehicles, supervision and control, registration and information provision, and issuing documents. We are
responsible for the implementation of the periodic inspections in the Netherlands and the supervision thereof
and responsible for the necessary changes in the vehicle registration database.

B: General assessment of current EU rules on roadworthiness
2.
In your view, to what extent have the current EU rules on roadworthiness (all three
Directives) been effective in improving road safety and contributing to the reduction of
road fatalities and serious injuries in road transport in the EU?
Very effective
X Effective
Neutral
Less effective
Not effective
I do not know / No opinion

3.
In your opinion, how relevant are the current EU rules on periodic
roadworthiness testing and technical roadside inspections in improving road
safety?
Very
relevant
Periodic testing of high-speed
tractors and heavy motorcycles
Minimum standards for testing
centres, facilities and equipment
Minimum standards for
inspectors' competence, training
and objectivity
Categorising deficiencies during
the periodic inspection as either
minor, major, or dangerous
deficiencies
Obliging Member States to
perform roadside tests on a
minimum share of commercial
vehicles each year
Different time intervals between
periodic tests, according to the
age of vehicle, and vehicle type

Relevant

Neutral

Less
relevant

Not
relevant

not
know /
No
opinion

x
x

x

x

X

X

4.
In your opinion, how relevant are the current EU rules on periodic
roadworthiness testing and technical roadside inspections in reducing air
pollutant emissions?

Very
relevant
Periodic testing of high-speed
tractors and heavy motorcycles
Establishing minimum standards
for testing centres, facilities and
equipment
Minimum standards for
inspectors' competence, training

Relevant

Neutral

Less
relevant

X
X
X

Not
relevant

not
know /
No
opinion

and objectivity
Categorising deficiencies during
the periodic inspection as either
minor, major, or dangerous
deficiencies
Obliging Member States to
perform roadside tests on a
minimum share of commercial
vehicles each year
Different time intervals between
periodic tests, according to the
age of vehicle, and vehicle type

X

X

X

5.
In your opinion, how relevant are the current EU rules on the registration
documents for vehicles in facilitating free movement of goods and people within
the EU?

Very
relevant
Obligation on Member States to
recognise roadworthiness
certificates upon change of
ownership

Relevant

Neutral

Less
relevant

Not
relevant

Not
know /
No
Opinion

X

6.
Please provide your opinion below on how effective are the current EU
rules on periodic roadworthiness testing and technical roadside inspections in
improving road safety?
Very
effective
effective
Periodic testing of high-speed
tractors and heavy motorcycles
Minimum standards for testing
centres, facilities and equipment
Minimum standards for
inspectors' competence, training

Neutral

X
X
X

Not
Less
Not
know /
effective effective
No
opinion

and objectivity
Categorising deficiencies during
the periodic tests as either
minor, major, or dangerous
deficiencies
Obliging Member States to
perform roadside tests on a
minimum share of commercial
vehicles each year
Different time intervals between
periodic tests, according to the
age of vehicle, and vehicle type

X

X

X

7.
Please provide your opinion below on how effective are the current EU
rules on periodic roadworthiness testing and technical roadside inspections in
reducing air pollutant emissions?

Very
Effective
effective
Periodic testing of high-speed
tractors and heavy motorcycles
Minimum standards for testing
centres, facilities and equipment
Minimum standards for
inspectors' competence, training
and objectivity
Categorising deficiencies during
the periodic tests as either
minor, major, or dangerous
deficiencies
Obliging Member States to
perform roadside tests on a
minimum share of commercial
vehicles each year
Different time intervals between
periodic tests, according to the
age of vehicle, and vehicle type

Neutral

I don't
Less
Not
know /
effective effective
No
opinion

X
X

X

X

X

X

8.
Please provide your opinion below on how effective are the current EU
rules on the registration documents for vehicles in facilitating free movement of
goods and people within the EU?

Very
effective
Obligation on Member States to
recognise roadworthiness
certificates upon change
ownership

Effective

X

Neutral

Less
Not
effective effective

I don't
know /
No
opinion

C: Main problems to address
Recent regulatory provisions on emissions and safety show the technical limits of current
roadworthiness testing methods. With the introduction of advanced vehicle safety features and
significantly strengthened emission legislation, vehicles will attain even higher levels of technical
complexity. To keep pace with these trends, fundamentally new approaches in the field of vehicle
testing and inspection methods are needed.
A possible future revision of the Roadworthiness Package would address the issues in the following
areas:

The lack of adequate methods to test electronic safety & driver assistance systems in technical
roadside inspections;
Vehicles with alternative powertrain technologies (eg. hybrid, full-electric, hydrogen) may require
particular testing methods for their safety;
Vehicles circulating on the roads with defects or with tampered components or software
adversely impacting road safety and the environment;
Relevant vehicle data are not sufficiently available to enforcement authorities in the EU Member
States for cross-border traffic.

9.
In your opinion, how important is that the following problems are
addressed, in case of the revision of the EU roadworthiness rules?
Very
relevant
Methods for Periodical
Technical Inspections (PTI)
of vehicles to test
electronic safety & driver
assistance systems in
vehicles
Availability of relevant
vehicle data to
enforcement authorities
in the EU Member States
in cross-border traffic
Vehicles circulating on the
roads with defects or
tampered components

X

X

X

Moderately
important

Neutral

Do not
Low
Not
know /
importance important
No
opinion

10. Do you have any further comment on the functioning and/or problems related to any
of these EU roadworthiness rules?
1000 character(s) maximum
-

-

-

Current EU legislation does not sufficiently take into account the rapid development of vehicles, making
legislation quickly outdated.
Regulations should offer opportunities and flexibility to innovate given the rapid development of vehicles
(e.g. introduction of PN-measurement)
PTI based on the use of a vehicle is difficult to enforce (e.g. tractors)
The questions related to tractors and motorcycles are very difficult to answer as they are combined in
one question. In the Netherlands motor cycles are currently not part of the PTI scope, tractors are. It is
therefore rather difficult to give a clear answer to these questions
Emission requirements of tractors are not covered by the 2014/45/EU. Tractors are not approved under
the directive/regulation mentioned in 2014/45/EU Annex III 8.2.2 note 7 and therefore opacity
measurement is not applicable.
Comment re. question 9 ‘availability of relevant vehicle data to enforcement authorities in the EU
Member States in cross-border traffic’ → Why is this only relevant for cross-border traffic?

D: Policy measures
This section aims at identifying potential policy measures to overcome initially identified problems in view of a
possible revision of the EU rules.

11.

In your opinion, how important is it to include the following provisions in revising the

EU rules on periodic roadworthiness testing
Very
Moderately
important important
Extending the rules to powered
two- and three-wheelers (Lcategory vehicles)
Methods to test the functioning of
safety-relevant electronic
components, advanced driver
assistance systems (ADAS) and
automated functions
New methods for measuring
exhaust emissions, for example
particle number (PN) and nitrogen
oxides (NOx)
New methods to test vehicles with
alternative powertrain technologies
(hybrid, full-electric, hydrogen)
New methods for reading out onboard data stored in the vehicles
Extending (or clarifying) existing
rules on access to in-vehicle data
for the purpose of periodic
roadworthiness testing, with data
protection safeguards
Electronic Periodical Technical
Inspection (ePTI) of vehicles
New methods for tackling
odometer fraud
Ensuring that safety- and
environment-relevant software
updates have been done, e.g., as a
result of vehicle recalls
Mandatory data exchange of
roadworthiness certificate data to
verify their validity during the reregistration of a vehicle in another
EU Member State

Neutral

X

X

X

X
X

X

X
X

X

X

No
Low
Not
opinion/
importance important Do not
know

New measures to enable a vehicle
owner to obtain a valid
roadworthiness certificate, to be
accepted throughout the EU, in a
Member State other than the
Member State of registration of the
vehicle
Measures to specifically tackle
noise-related tampering / noncompliance problems in two- and
three-wheelers and quads (Lcategory vehicles)

X

X

12. In your opinion, how important is it to include the following provisions in revising the
EU rules on technical roadside inspections?

Very
Moderately
important important

Extending the rules to other
vehicles, (e.g., light commercial
vehicles, and
passenger vehicles, including cars,
powered two- and three-wheelers
(N1, M1
and L-category vehicles)
Extended emission testing (e.g., NOx
and PN), including the use of remote
sensing equipment
Follow-up in the Member States of
registration in case of a prohibition
or suspension abroad
Mandatory checks during roadside
inspections of commercial vehicles
to ensure the safe securing of cargo
Granting roadside inspection
authorities access to electronic data
Extending (or clarifying) existing
rules on access to in-vehicle data for
the purpose of technical roadside
inspections, with data protection
safeguards
Measures to specifically tackle
noise-related tampering / noncompliance

X

X

X

X
X

X

X

Neutral

No
opinion
Low
Not
/Do
importance important
not
know

problems in vehicles inspected at
the roadside

13. In your opinion, how important is it to include the following provisions in revising the
EU rules on the registration documents for vehicles?
Very
Moderately
important important
Improved exchange of
roadworthiness data between
Member
States in electronic format
Full digitalisation of registration
documents
Adding odometer data to the vehicle
register
Adding data on major accidents of a
vehicle to the vehicle register

X

X
X
X

Neutral

No
opinion
Low
Not
/
importance important
Do not
know

14. Do you have any suggestions for new provisions to be included in the EU roadworthiness
rules, other than the possible policy measures at questions 11 to 13 above? Maximum 1000
characters
1) Life time compliance
•

•

•

There is a need to have a continued link between manufacturers, authorities, repair and maintenance
market and vehicle owners throughout the lifecycle of the vehicle in order to ensure lifetime compliance
of the emission and safety control systems. During type approval there should already be a strong and
clear link to maintenance, in service conformity, market surveillance, PTI and enforcement authorities in
order to have the complete lifecycle of the vehicle in scope. The Netherlands is also pushing for life time
compliance in light of the soon to be published Euro 7 proposal;
It would involve simple checks and test procedures developed at type approval level that may have a
limited scope but will be appropriate for checking at PTI and road side inspections the applicable
emission levels and safety control systems. The checks on the emission and safety control system should
be made effective, i.e., robust, simple and stringent, throughout the lifetime of the vehicle. The PTI has a
100% coverage of vehicles in use and is in potential an effective instrument to monitor the performance
of the emission and safety control system throughout its lifetime;
Vehicles should not be allowed to be altered, throughout the lifetime of the vehicle, in a way that the
original functioning of the emission and safety control system is decreased or changed. It should be easy
to check any deviations or alterations during PTI or a road side inspection.

2) Plume chasing within Roadside Inspections
•

Consideration could be given to incorporating plume chasing checks as a roadside inspection. With
plume chasing, the emissions are measured by a measuring car that follows the car to be checked on
the road. By expanding the scope to other vehicles categories and to emissions and sound checks,
sustainability, in addition to safety, will be given a fixed value within the roadside inspections.

E: Impacts
15. How would you assess the likely impact of the following potential measures, if these were
included in the EU rules?

Fully
positive

Making more vehicles subject to periodic
inspections
Making more vehicles subject to roadside
inspections
Methods to test the functioning of safetyrelevant electronic components,
advanced driver assistance systems (ADAS)
and automated functions
New methods for measuring exhaust
emissions, for example particle number
(PN) and NOx measurements, during
periodic inspections
Extending (or clarifying) existing rules on
access to in-vehicle data for the
purpose of periodic inspections and
roadside inspection
New methods for measuring exhaust
emissions, for example particle number
(PN) and NOx measurements, during
roadside inspections, including the use of
remote sensing equipment
New methods to test vehicles with
alternative powertrain technologies
(hybrid, full-electric, hydrogen)
New methods for reading out on-board
data stored in the vehicles
Electronic Periodical Technical Inspection
(ePTI) of vehicles
New methods for tackling odometer fraud
Ensuring that safety- and environmentrelevant software updates have been
done, e.g., as a result of vehicle recalls
Mandatory exchange of roadworthiness
certificate data to verify their validity
during the re-registration of a vehicle in
another EU Member State

Somewhat
positive

X
X

X

X

X

X

X
X
X
X
X

X

Neutral

Somewhat
negative

Fully
negative

No
opinion
/ Do
not
know

Follow-up in the Member States of
registration in case of a prohibition or
suspension abroad
Mandatory checks during roadside
inspections of commercial vehicles to
ensure the safe securing of cargo
Improved exchange of roadworthiness data
between Member States in electronic
format
Full digitalisation of registration documents
Adding data on major accidents of a vehicle
to the vehicle register

X

X

X
X
X

16. Do you have any comment on other potential impacts (not mentioned
above) of the possible policy measures? Maximum 1000 characters

We believe that question 15 is not very well formulated. It is not specified what kind of impact is meant
(e.g. related to costs, road safety, emissions) and it also not clear whether with impact something
positive or negative is meant. We have now answered the question from a road safety and
environmental perspective, but the feasibility of different policy measures (e.g. making more vehicle
categories subject to technical inspections) is something that should be carefully examined.

F: EU added value
17. To what extent do you agree with following statements?
(For the purpose of answering some of the questions below, please note that EU
“Regulations” are EU rules which are directly binding on Member States across the
EU, whereas EU “Directives” are EU rules implemented through national laws.
Currently, the EU rules on periodic testing, registration documents, and roadside
inspections, are implemented through Directives.)

Fully
Agree

The objectives of the revision of
the EU rules on roadworthiness
could be better accomplished
through deployment of nonlegislative tools based on
guidance or recommendations
by the Commission

Neith
er
Somewh
agree Somewhat Completely
at
nor
disagree
disagree
agree
disagr
ee

X

No
Opinio
n

The objectives on periodic
roadworthiness testing could be
achieved better
through a Regulation rather
than a Directive
The objectives on technical
roadside inspections could be
achieved better
through a Regulation rather
than a Directive
The objectives on registration of
documents could be achieved
better through
a Regulation rather than a
Directive
The EU rules on roadworthiness
have added value for citizens
and businesses, compared to
what could be achieved by
Member States at
national and/or regional and
international level

X

X

X

X

Section F: Final remarks
18. You may want to add further comments to the replies already provided (maximum 2000
characters):
The Netherlands welcomes the revision of the RWP which comes at a good time. Many new developments
will have an impact on how we will test vehicles in the future. The General Safety Regulation outlines new
safety features for vehicles. Furthermore, upcoming legislative developments such as Euro 7/VII and
changes in RRR (Triple R) and End-of-Life Vehicles (ELV), show that this is an excellent timing to ensure
lifetime compliance with a comprehensive testing and surveillance scheme for vehicles. Inspections need
to be better adapted to potential tampering with safety or emission related systems. Finally, vehicle data
and digitalization play an increasingly important role. The improvement of data exchange between the
Member States (MS), the digitalization of registration documents and further harmonization of the reregistration process will most likely result in better transparency and prevention of fraud and reduce
administrative burdens.

19. If you would like to attach a document to complement or to support your reply you can
do so here (box to upload a document):
Only files of the type pdf,txt,doc,docx,odt,rtf are allowed

Contact
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