Case Id: 10607d57-1623-4892-bbba-0c0dc66ac545
Date: 30/08/2016 13:39:56

Consultation on the revision of Regulation (EU) No
443/2009 and Regulation (EU) No 510/2011 setting CO2
emission performance standards for light duty vehicles
Fields marked with * are mandatory.

We are launching this consultation to collect the views of stakeholders and citizens with regard to the
revision of the EU regulations setting CO2 emission performance standards for cars and vans
(together referred to as light duty vehicles (LDVs)).
The consultation is divided into two sections: the first section asks questions of a general nature and
the second asks questions of a more technical nature related to the policy design and is thus
intended for a well-informed audience. You may choose whether you wish to answer only the first or
both of these sections.

Background to the consultation

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Transport represents around one quarter of Europe's greenhouse gas emissions and is the main
cause of air pollution in cities. Europe's answer to these challenges is an irreversible shift to
low-emission mobility in terms of carbon and air pollutants. By mid-century, greenhouse gas
emissions from transport will need to be at least 60% lower than in 1990 and be firmly on the path
towards zero.
The shift towards low-emission mobility will contribute towards reducing the EU's overall emissions,
as we have committed to do under the Paris Agreement on climate change. This shift also offers
major opportunities for the European automotive industry to keep its competitive advantage and
remain a front-runner through modernising, embracing new technologies and regaining the trust of
consumers.
The shift towards low-emission mobility has already started, but its pace should be accelerated as set
out in the Commission's Strategy for low-emission mobility.
The 2030 climate and energy policy framework agreed by EU Heads of State in October 2014
requires a 30% reduction greenhouse gas emissions in sectors not covered by the EU's Emission
Trading System ("non-ETS sectors") by 2030 compared to 2005. The impact assessment
accompanying the framework indicated that vehicle efficiency measures are the most important
measure for achieving the needed reductions.
The EU's Regulations setting carbon dioxide (CO2) emission standards for new cars and vans have
proven to be a strong driver for innovation and efficiency in automotive technology. A review of those
Regulations to establish post-2020 targets for cars and vans was announced by the Commission in
February 2015 and included into the Action plan of the Strategy for low-emission mobility.
An extensive evaluation of the existing Regulations has been carried out. This identifies that while the
Regulations have been largely effective and have delivered CO2 reductions at lower cost than
originally foreseen, there are areas deserving consideration for the future revision. These include the
measurement of the emissions and the utility parameter (a way to differentiate between
manufacturers' fleets).
The existing Regulations foresee a review covering the emissions target and existing modalities and
the use of a utility parameter (as a way to differentiate between manufacturers' fleets).
The Strategy for low-emission mobility also notes that the transformational change towards low- and
zero-emission vehicles will need to be supported by a wide range of measures at all levels of
policy-making to engage both manufacturers and users. The Commission will analyse the impact of
different ways to incentivise low- and zero-emission vehicles in a technology neutral way, such as
setting specific targets for them.
The Commission is carrying out this consultation in order to be properly informed by public opinion in
preparation for possible future legislative action in this area. The results of the consultation will be
summarised and published as well as being used to inform the Impact Assessment.
If data, other information or studies are available which are relevant to the assessment, these can be
submitted as part of a stakeholder's general comments or directly to the mail box.

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General information about respondents

*In what capacity are you completing this questionnaire?
As an individual / private person
Public authority
Academic / Research institution
International organisation
Civil society organisation
Professional organisation
Private enterprise
Other

*Please give your name if replying as an individual/private person, otherwise give the name of your
organisation:
Text of 3 to 200 characters will be accepted
Dutch Ministry of Infrastructuure and Environment

If your organisation is registered in the Transparency Register, please give your Register ID number:
20 character(s) maximum

If your organisation is not registered, you can register now.
Please give your country of residence/establishment:
Netherlands

(Please note that regardless of the option chosen, your contribution may be subject to a request for
access to documents under Regulation 1049/2001 on public access to European Parliament, Council
and Commission documents. In this case the request will be assessed against the conditions set out
in the Regulation and in accordance with applicable data protection rules.)

Section one: General questions
This section asks general questions about the policy of reducing CO2 emissions from cars and light
commercial vehicles (together referred to as LDVs) and is aimed at citizens as well as specialist
stakeholders.
A free text section is available at the end of the questions to enable you to provide any additional
clarifications or observations.

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Main problem to address
The Regulations setting CO2 targets for new cars and light commercial vehicles request the
Commission to bring forward proposals to set new targets for the period beyond 2020.
In your view, how important is the following action?
Very
important

Important

Somewhat

Not

I don't

important

important

know

Setting CO2 emission
targets for new cars
and light commercial
vehicles in the EU in
order to reduce
emissions from this
segment and
contribute to meeting
the EU's overall climate
goals

The need for EU action
There is a single market for LDVs across the EU. If no EU action was taken to address the problem,
Member States would adopt individual approaches to reduce LDV CO2 emissions, in order to achieve
the needed reductions for the non-ETS sector. As the evaluation of the Regulations highlighted, the
use of differing tools and levels of ambition by Member States could lead to market fragmentation.
This would lead to higher costs, both for industry and vehicle purchasers for achieving the goal and
probably be less effective at actually reducing greenhouse gas emissions. Current evidence from the
use of CO2 linked vehicle taxation clearly demonstrates the widely differing approaches which would
result from Member State action and the additional costs this would cause.
In your view, what would be likely to happen without EU action?
Likely

Neutral

Unlikely

Member States would individually implement legislation
to reduce LDV CO2 emissions
Legislation introduced by individual Member States
would lead to market fragmentation and higher costs
Member States would have difficulty to achieve the
necessary reductions to meet EU climate goals

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Main policy objectives
In your view, how important are the following objectives for future LDV CO2 legislation?
Important

Neutral

Unimportant

Continuing to reduce CO2 emissions from cars
and light commercial vehicles cost effectively and
in line with EU climate and energy goals

Ensuring technology neutrality (e.g. between
different powertrains)
Ensuring competitive neutrality between
manufacturers
Preserving the competitiveness of EU automotive
manufacturing
Ensuring that the legislation's impacts are socially
equitable
Promoting the market uptake of low-emission and
zero-emission vehicles

Contributing to reducing air pollution caused by
cars and light commercial vehicles (emissions of
nitrogen oxides, particulate matter, …)

Form that action should take to reduce LDV CO2 emissions

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Please indicate your preference for the following options to reduce new LDV CO2 emissions, and
contribute to the 2030 Energy and climate targets (with 1st being your most preferred option and 7th
the least preferred)?
1st

2nd

3rd

4th

5th

6th

7th

Legislation setting LDV CO2
emissions targets at EU level
Use of vehicle or fuel taxes or other
incentives by Member States to
affect vehicle choice and use
A voluntary agreement with industry
to reduce new vehicle CO2
emissions
Member State actions to influence
vehicle choice in other ways such as
restricting access to urban areas for
certain types of vehicles
Development of international
standards for LDV fuel economy
No action
Other

Other – please specify:
100 character(s) maximum
CO2 reduction obligation in fossile fuel chain or blending obligation for
advanced biofuels

The level of future LDV CO2 emissions targets
The EU Regulations currently set new vehicle fleet average CO2 targets of 95gCO2/km for cars from
2021 on and of 147gCO2/km for light commercial vehicles from 2020 on. Without further action, these
targets will remain unchanged after those dates.
The current targets require manufacturers to reduce new car emissions by about 5% per year
between 2015 and 2021 and new light commercial vehicle emissions by about 5.5% per year
between 2017 and 2020.

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In comparison to the current reduction rates, do you think new targets for the period after 2020 should be
set at levels which require:
a rate of reduction less than that required under the current Regulations?
a similar rate of reduction to that required under the current Regulations?
a higher rate of reduction than that required under the current Regulations?

What is your view on the timetable for the post-2020 strategy on cars and vans?
200 character(s) maximum
A standard in 2025 of WLTP-equivalent of 70 grams of CO2 per km (NEDC). For
2030 a standard of WLTP-equivalent of 35 grams of CO2 per km(NEDC)

Innovation and competitiveness
The Paris Climate agreement and the obligations on participating countries may increase the global
competition for technologies to reduce road vehicle CO2 emissions.
Do you think EU legislation to regulate CO2 emissions for LDVs will:
Agree

Neutral

Disagree

Increase the competitiveness of EU industry on the
global market
Increase the likelihood of the EU automotive industry
developing further CO2 reducing technology for
conventional engines
Increase the likelihood of the EU industry developing
technology for alternative powertrains

Social impacts
LDVs have an average of 3 or 4 owners over their life. Lower income groups within a country's
population and countries with lower GDP are likely to have larger shares of second hand vehicles
entering their fleets. It may be the case that vehicle CO2 emissions and fuel efficiency are viewed and
experienced differently by purchasers of second hand vehicles than by purchasers of new vehicles. In
turn, such differences may occur between income groups and Member States.

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The following questions seek your views on this issue:
Yes

No

Neutral

Is the distributional impact of LDV CO2 legislation likely to lead
to benefits for lower income social groups and countries?
Should the impact on second hand LDV purchasers be
considered when assessing the social impacts of the
legislation?
Should cross-border trade in second hand vehicles be taken
into consideration in assessing the impacts of the legislation?

Any additional comments
If you have any comments or supplementary information to add to your replies to the questions in section
1, please insert this here:
1000 character(s) maximum
Fuel efficient cars consume less. This is an advantage for every owner/driver
during the life cycle of the vehicle. After some years the 2nd hand buyer will
benefit from the high write-off of additional cost for new fuel saving
technologies and/or alternative power trains. Ideally, the target will
decrease linearly between 2025 and 2030 by 7 grams each year, whereby OEMs
will be able to trade among themselves the allowances for this in order to
assure optimum flexibility. Additional policy is necessary to grow towards
100% sales of zero-emission vehicles in 2035, because within the foreseeable
future the technological potential for CO2 reduction with the combustion
engine will be exhausted.

Section two: policy design questions

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This section asks more specific question about potential policy design options for reducing CO2
emissions from cars and light commercial vehicles and their impacts.
The questions below are based on the initial analysis carried out by the Commission and presented in
its Inception Impact Assessment.
The evaluation of the existing legislation identified a number of areas to be considered. The
co-legislators have also requested a number of aspects to be assessed in developing new legislative
proposals and stakeholders have proposed options for consideration.
The following questions seek your views on which of these different possible aspects should be
included in the future legislation and how important the different aspects are for you.
It is not mandatory to answer all questions.

Aspects of the Regulatory approach
.

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.
Yes

No

Neutral

In addition to cars (M1) and Light Commercial
Vehicles (N1), should the legislation also cover
heavier vehicles (N2 type)?

Should the car Regulation also include small
Light Commercial Vehicles?

Should cars and Light Commercial Vehicles be
covered by the same Regulation?

Should the current approach where
manufacturers are the regulated entity be
replaced by regulating manufacturer groups?

Should the current Tank To Wheel (TTW)
metric be replaced by a Well To Wheel (WTW)
metric?

Should the current approach based on CO2
emissions be replaced by an approach based
on energy use?

Should the metric used to set the target also
include emissions occurring during
manufacturing and at the time of disposal of
the vehicle ?

Measuring performance

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Concerns over the growing divergence between test cycle CO2 emissions and those experienced in
real driving will be largely tackled by the foreseen change from the current NEDC test cycle to the
World harmonised Light vehicle Test Procedure (WLTP) for regulatory purposes. However, this
approach is different to the one taken for pollutant emissions where a 'real driving emissions' test is
being introduced.

In view of this:

Yes

No

Neutral

Do you think the Commission should explore what
potential exists to further reduce the divergence between
the test cycles and real world emissions?

Should supplemental driving tests be implemented to give
values closer to real emissions?

Should data based on mass monitoring of fuel
consumption in vehicles be used for monitoring
programmes?

Other

Technology specific requirements

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.
Yes

No

Neutral

Yes

Neutral

Should manufacturers be given the freedom to choose the
mix of technologies and emission levels for their vehicles
provided they meet the overall target set for them?

Should specific CO2 targets be set for different fuel types or
technologies?

Should manufacturer's targets continue to be set based on
their sales weighted average registrations (as in the current
legislation)?

Should average mileage by fuel and vehicle segment be
taken into account in establishing targets?

How should the effort be shared between different actors?
.
No

Should a utility parameter be used to distribute the effort
between different vehicle manufacturers (as in the current
legislation)?

Incentivising low- and zero-emission vehicles
The following questions relate to possible elements in future legislation relating to low- and zeroemission vehicles such as plug-in hybrid vehicles, battery electric vehicles and fuel cell electric
vehicles.

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.
Yes

No

Neutral

No

Neutral

Should there be a mechanism in the CO2 legislation to
encourage the deployment of low- and zero-emissions
vehicles?

What criteria should be used for defining low- and zero-emissions vehicles?

Yes

CO2 emission performance

If yes, how could an appropriate criterion be defined?
200 character(s) maximum
CO2 targets in 2025 and 2030 should to continue and to reinforce the initiated
transition towards a zero-transmission power train. A low emission vehicle in
2030 should not emit more than 15 gr. 0=0

What criteria should be used for defining low- and zero-emissions vehicles?

Yes

No

Neutral

No

Neutral

Zero emission range (km)

What criteria should be used for defining low- and zero-emissions vehicles?

Yes

Other

Technologies which reduce CO2 emissions but not during the type approval test
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.
Yes

No

Neutral

Should CO2 emission reductions arising from the
deployment of technology which reduces emissions in
normal driving but whose benefit is not shown in the normal
test cycle be taken into account in the legislation?

If yes, please show your preference for the following options with 1st being your most preferred option:
1st

2nd

3rd

4th

Continuation of the current eco-innovation scheme
List of technologies eligible for off-cycle credits
An approach based on measuring in-use fuel consumption
from vehicles fitted with the technology
Other – please specify below

Other - please specify
200 character(s) maximum
No opinion yet

Small volume and niche manufacturers

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.
Yes

No

Neutral

Should derogations for small volume manufacturers (less
than 10,000 registrations per year) be continued?

Should derogations for niche manufacturers (10,000 to
300,000 registrations per year) be continued

If derogations are continued, should these be based on
worldwide sales (instead of EU sales) for those
manufacturers?

Should derogations be granted for certain types of vehicles
rather than for manufacturers?

Additional Comments
If you have any comments or supplementary information to add to your replies to the questions in section
2, please insert this here:
200 character(s) maximum
we would like to ask the Commission to come with the proposal a.s.a.p. but
definitly no later than Q1 2017

Contact
CLIMA-CONSULTATION-LDV-POST-2020@ec.europa.eu

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