Euro 5 emission limits for light vehicles - summary of contributions
Stakeholder consultation on Euro 5 emission limits for light duty vehicles - Summary of the results
The Commission has formulated a draft proposal for a Regulation which would set new emission limits for cars and light commercial vehicles, known as the Euro 5 standards. In line with this proposal an internet consultation process was carried out in order to allow for comment to be made by all interested parties.
A total of 50 replies were received to the request for comment. Of these the breakdown by source is as follows:
- Government 11
- Industry 23
- NGO 13
- Individuals 3
The following provides a summary of the main issues which were raised by the correspondents:
Diesel Emission Limits
- NOx emission limits for diesel vehicles
There were a number of stakeholders who considered that the proposed NOx emission limit of 200 mg/km was too high and that lower limits of between 75 to 150 mg/km should be adopted instead.
- Euro 6 emissions limit
A number of stakeholders considered it important to provide a longer term perspective as to how emission limits would develop in the future. A particular issue related to NOx emissions from diesel cars and the need to indicate future emission limits in order to provide long term signals to industry and facilitate the development of NOx reduction technologies in diesel vehicles.
- NO2 limit for diesel vehicles
A number of stakeholders suggested that in addition to regulating total NOx emissions from vehicles, there should be restrictions on the total proportion of NOx that could comprise NO2. There were concerns that even with lower emission limits for NOx the amount of NO2 that diesel vehicles were emitting was increasing, due partly to the nature of aftertreatment technology.
- Particle emission limits from diesel vehicles
There were a number of comments that the 5 mg/km emissions limit was too high and that a lower limit of 2.5 mg/km would be appropriate. In addition it was observed that the proposed limits for Light Commercial Vehicles (Class 2 and Class 3) were too high to ensure that particulate filters would be fitted.
- PM mass measurement and number standard
A number of industry stakeholders commented that a change in measurement procedure was an unnecessary expense. In addition they considered that the introduction of a number standard was unnecessary due to a correlation between number counts and mass emissions. Furthermore it was considered by some that the use of the new measurement procedure would require the adoption of a large correlation study before it could be adopted.
Petrol Emissions Limits
- Petrol NOx limit
A number of stakeholders commented that reducing NOx levels for petrol would be problematic for direct injection vehicles, or would prevent future standards being developed that were fuel neutral. However, other stakeholders considered that petrol NOx emission limits should be reduced further so they aligned to standards used in the United States.
- Spark ignition engine HC standards and gas vehicles
A few consultation responses suggested the proposed hydrocarbon standards for spark ignition engines should be redefined as this would cause issues for vehicles which used CNG and LPG. Such engines emit higher levels of methane than those fuelled on petrol so meeting a lower emission limit based on Total Hydrocarbons (THC) would be difficult. A shift to an emission limit based on Non-Methane Hydrocarbons (NMHC) was proposed.
- PM limit for lean burn direct injection gasoline engines
A number of stakeholders were concerned that the PM limit was set too high and should be further reduced to 2.5 mg/km. On the other hand others said that it should be removed in totality as it would require particulate filters to be fitted.
- Other emission limits
In addition to the reduction in the main tailpipe emission limits, some stakeholders also requested reductions in the emission limits for evaporative emissions and also the cold start tests for HC and CO. Furthermore, updating and review of the crankcase gases test procedure was requested.
- Date of entry into force date for the regulation
Some stakeholders wanted the Regulation to come into effect in 2010. Others said that a 2008 implementation date was necessary for air quality reasons. If a rolling implementation date were to be introduced, many industry stakeholders considered that application of the regulation should come into effect either 24 or 36 months after entry into force, rather than the 18 months currently proposed.
- The time limit between entry into force for new type approvals and all new types
There was not much support for the proposed 18 month gap between the regulation applying to new type approvals and then all types, with a preference being expressed for a 12 month gap.
- Dates of entry into force for light commercial vehicles
A 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 (N1, Class 2 and 3) and heavy passenger cars (M1 vehicles over 2.5 tonnes). It was pointed out that bringing the dates forward as set in the draft regulation reduced product cycles from 5 years to 3 years for these vehicles.
- Removal of the exemption that enabled heavy passenger cars to be type approved as light commercial vehicles.
Industry stakeholders proposed that the exemption for vehicles over 2.5 tonnes weight should be replaced with new exemptions for off-road vehicles, those with 7 or more seats and special purpose vehicles such as motor caravans.
- Changes in durability and in-use compliance provisions
Some stakeholders mentioned that changes in durability limits were not justified as they could be an additional burden on industry, and that further details of the requirements was necessary. Other stakeholders requested that durability requirements and in-use compliance requirements should both be increased to 200,000 km in line with similar provisions in the United States. A number of stakeholders also requested an update of the In Use Compliance provisions and procedures.
- Access to OBD information
Some stakeholders felt that the provisions relating to access to OBD service information in the draft Directive duplicated those in the Block Exemption Regulation and thus were not necessary, whilst others considered that the draft was far too weak and needed to be supplemented. In particular, the associations representing repairers argued that the provisions relating to access to repair information should be made more precise by referring to the OASIS standard.
- Changes to test procedures
It was highlighted by some stakeholders that the test procedures used to regulate emissions should be updated to better reflect real world driving conditions. The suggestion was that air quality had not improved at the rate that would be expected from the emission reductions that had occurred in the past, due to limitations in the European test cycle. Test procedures should be amended to ensure off-cycle emissions are better controlled.
- Transitional issues in the repeal of Directive 70/220
It was suggested that there would need to be careful consideration of how the transition from a Directive to a Regulation should be handled. In particular there were questions raised as to how In Use Compliance arrangements would operate for vehicles type approved under the Euro 4 regulations.
- Clarification of scope
There were requests for further clarification of the application of the Regulation to certain types of vehicles. For example, it was asked how the Regulation applied to gas vehicles as the limits referred to 'Petrol' and 'Diesel' vehicles, rather than spark ignition and compression ignition. Also it was questioned whether separate standards should be developed for vehicles running biodiesel or bioethanol. In addition clarification was sought as to whether the regulation applied to more than M1 and N1 vehicles with spark ignition engines.