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

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• Key elements of the draft proposal were presented to the CARS 21 High Level andSherpa group, giving stakeholders an early opportunity to comment on new Euro 5emission limit values.• The draft proposal of the Euro 5 Regulation was put to public consultation in July2005. The Commission services aimed to gather the views of all interested parties onthe Commission services’ draft and to take into consideration all relevant comments ofstakeholders in its proposal.• The provisions on access to repair information were developed from the start through astakeholders technical committee chaired by the Commission and working intensivelyover a substantial period of time. The only point on which agreement was not reachedduring the work of that Committee was the issue of cost, which has been addressed inthis proposal by allowing costs to be recouped and by imposing no retrospectiveobligation.The Commission’s standards for consultation of interested parties 25 were met throughoutthe consultation procedure.Issues raised during the consultationA total of 50 replies were received to the request for comments. Of these the breakdownby source is as follows:• Governmental organisations 11• Industry and business organisations 23• NGOs, consumer and professional groups 13• Individuals 3During the consultation, a number of issues were raised by stakeholders. This sectionsummarises the substantive issues raised and discusses how they have been taken intoconsideration.1. Date of entry into force of the regulationSome stakeholders wanted the Regulation to come into effect in 2010. Others said that a2008 implementation date was necessary for air quality reasons. If a rollingimplementation date were to be introduced, many industry stakeholders considered thatapplication of the regulation should come into effect either 24 or 36 months after entryinto force, rather than the 18 months currently proposed.There was not much support for the proposed 18 month gap between the regulationapplying to new type approvals and then all types, with a preference being expressed fora 12 month gap.There was considerable variation on the viewpoints as to when the Regulation shouldcome into effect. Some Member States, a number of public authorities and NGOs wanted25COM(2002) 704 final, 11.12.200234
early introduction for reasons of public health and air quality. There was great concernover the ability of some Member States to meet statutory air quality objectives for NO Xand PM. Industry generally favoured later introduction in order to plan productioneffectively.The formulation used in the preliminary draft proposal will result in fixed entry into forcedates, once the Regulation is adopted by the Commission. The formulation proposed is inline with other European legislation and can be seen to represent good regulatory practice.The original proposal by the Commission services seems to be a compromise betweenthese opposing viewpoints, so there is no clear reason to change the proposal at this stage.2. Dates of entry into force for light commercial vehiclesA number of stakeholders requested the addition of the approach used in Euro 3 and 4,where there had been a 1 year delay in application to heavier light commercial vehicles(N 1 , Class 2 and 3) and heavy passenger cars (M 1 vehicles over 2.5 tonnes). It waspointed out that bringing the dates forward as set in the draft regulation reduced productcycles from 5 years to 3 years for these vehicles.In relation to N 1 vehicles, the Commission services sees some merit in the comments madethat the system currently in place which provides for a 1 year delay in implementationshould be maintained to respect product cycles. The proposal has therefore been amendedaccordingly.However with heavy M 1 vehicles, the Commission services considers that the additional 1year delay allowed under previous legislation is still no longer justified. Many of thesevehicles are derived from cars, so these vehicles should be treated in the same manner aslighter M 1 vehicles, even if this means that product lifecycles anticipated by manufacturerswill now need to be 1 year shorter.3. NO X emission limits for diesel vehiclesThere were a number of stakeholders who considered that the proposed NOx emissionlimit of 200 mg/km was too high and that lower limits of 150 mg/km or 125 mg/kmshould be adopted instead.The rationale for the selection of the 200 mg/km emission limit is to avoid the need forafter-treatment, given that otherwise there would be two additional aftertreatment systemson diesel cars, a particulate filter and a NO x catalyst. Moreover the price of the vehiclewould considerably increase. The proposal to harmonise emission limits for all M 1vehicles, will still drive the development of technology used in diesel engines as the heavyvehicles will require higher reduction in NO X emissions than lighter M 1 vehicles.4. NO 2 limit for diesel vehiclesA number of stakeholders suggested that in addition to regulating total NO X emissionsfrom vehicles, there should be restrictions on the total proportion of NO X that couldcomprise NO 2 . There were concerns that even with lower emission limits for NO X theamount of NO 2 that diesel vehicles were emitting was increasing, due partly to the natureof aftertreatment technology.NO 2 is the pollutant which is regulated in European air quality legislation. The importanceof this issue will increase with the introduction of the NO 2 limit value coming into force in35
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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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