As the new ACEA position paper makes clear, the basic requirement of such an important and far-reaching study is to determine the objective and need for potential new EU regulations, and to first establish what would be a proportional approach to the identified problem. Any new regulatory actions taken at EU level must be justified with the balance between additional cost vis-à-vis air quality benefits taken into account.
The latest Euro 6 and Euro VI regulations have yet to be fully implemented in the EU road vehicle fleet. New CO2 targets will push the introduction of more low- and zero-emission vehicles and all of these new vehicles will make a difference regarding the primary objective of a new pollutant emission regulation, which is to help improve air quality. If we couple that with fleet renewal schemes to aid industry recovery from the current crisis, the impact will be even greater.
So, the need for a new EU regulation must be first assessed against what the existing EU measures (and potentially new measures) will deliver for improved air quality to determine if new EU regulations are needed to close any gap, or maybe other measures might be more proportional.
Heavy-duty vehicles are not ‘bigger cars’. Indeed, the heavy-duty vehicle business is very different and with different commercial needs, also for the light-commercial vehicle business that sits somewhat in the middle. Any future EU regulations must be fit for purpose for all vehicles and their business needs.
The auto industry is a global business and the applied emission control technology on new vehicles is becoming similar, especially in the key global markets. Therefore, any action taken at EU level must take into account the benefits of global harmonisation of proportional regulations – this would be highly beneficial to the EU industry operating in many global markets.
Any justified action taken at EU level should address regulatory simplification and regulatory clarity and any justified action taken at EU level should lay out a clear roadmap with clear industry lead-time from when all parts of EU regulations are complete. In this period of uncertainty for all, the Commission should now make it clear that the technical content of the current Euro 6 and Euro VI regulations are fixed – so industry can get on with delivering cleaner vehicles into the EU fleet.
ACEA’s comments to the Commission's inception impact assessment consultation, which are complementary to this position paper, are available here on the Commission consultation webpage.