Euro 5 Impact Assessment - Automotive Industries Association of ...

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offers competitiveness benefits to the EU automotive industry which could be affectedby a change of approach.• It is not clear that a self commitment provides an adequate guarantee that a specificemission level will be reached or that there will be appropriate sanctions available if theself-commitment were to be breached.• As the issue of emission control has repercussions on the protection of the environmentand public health, it is questionable whether a self-commitment can be justified.• A self-regulation approach could take too much time to be negotiated and to deliverthe hoped-for effects. Due to the problem of several Member States to meet existingair quality targets, there is a certain urgency to introduce action that has moreimmediate effects.In addition, it is not apparent that the use of a voluntary approach would offer anyadditional benefits to the industry, governments or the general public. It is likely that asimilar compliance process would be used as currently exists in the type approval system,however there would be additional transaction costs in establishing an appropriatemonitoring and compliance mechanism. A regulatory approach instead would provideindustry with a stable and predictable framework in which investment in better technologysolutions would be stimulated.12
5. ANALYSIS OF IMPACTS5.1. Impacts of the policy optionsThis section analyses the impacts of policy option 1 (Regulatory approach) relative to thebaseline (No policy change). The potential economic, environmental and social impactshave been examined.5.1.1. Baseline - ‘No policy change’As discussed in Section 2.2 and 2.4 the option of no policy change is not considered aviable way forward due to the significance of the air pollution problems that the EU faces.However this option provides a baseline to consider the impact of the Regulatoryapproach. The impacts related to the baseline have been based on the forecasts madeunder the CAFE Programme. Any potential limitations with the forecasts have alreadybeen considered in the development of the CAFE Programme, so it is not necessary toconsider these issues in the present impact assessment.5.1.2. Option 1 - Regulatory approachConsiderable emphasis was given to gathering data from stakeholders to understand thecosts of varying emission limits. There is substantial information asymmetry as those withthe best information on these costs do not necessarily have clear incentives to make itpublic. Another key issue with cost data relates to understanding the effect of massproduction on new technology. A more detailed explanation of this process is provided insection 6.5.1.2.1. Economic impactsThe fulfilment of stricter emission limit values would require the development andintroduction of technologies to reduce emissions of pollutants. There are a number ofeconomic impacts that result from the further regulation of vehicle emissions:• Single marketHarmonised emission limit values throughout the European Union would have a positiveimpact on the competition in the internal market by sustaining a ‘level playing field’ for allautomotive businesses.• CompetitivenessThis policy option may have neutral direct impacts overall on the competitiveness of theautomotive industry within the European Union. The option may increase the operatingcosts of businesses in the automotive industry through the additional cost of additionalcomponents and also research and development expenditure. But these costs will beincurred for all the car manufacturers that sell vehicles on the European market, so for thecompetitors of the European automotive companies as well. Depending on the vehicle mixand export of vehicles, EU car manufacturers are affected differently. However, thecompetitive position of the manufacturers of the EU would not be influenced by the policyoption. Moreover, costs and economic impacts could be expected to diminish over time,once a new technology becomes established and production costs fall.13
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Page 18 and 19: or by means of lean NOx traps (LNT)
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Page 24 and 25: measures in other sectors. The Comm
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