TCMV and TAAEG Replies

A 013320 20.12.2016

Committee of Inquiry into Emission Measurements in the Automotive Sector

EMIS hearing on 21 June 2016

Replies to the Questionnaire to Commission Representatives on TCMV and TAAEG

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TCMV 1. Is there a difference between the RDE-LDV expert The Real Driving Emission-Light Duty Vehicle (RDE-LDV) working group is the main group group, the RDE-LDV working group and the RDE set up in January 2011 with the objective to support the development, by the Commission, taskforce? What are these groups exactly, to which of a complementary test procedure that ensures that the emissions of regulated pollutants organisation do they report, who participated in these are appropriately controlled under normal conditions of vehicle use. Two expert groups groups and what role did they play in the process? were set up as sub-groups of the RDE-LDV WG (the so-called "RDE-LDV expert groups") to Could you please provide us with a detailed discuss and develop specific aspects: (1) the Task Force on Data Evaluation set up in composition per grouping, and any of its subgroups November 2013 with the mandate to assess the potential data evaluation methods and to (exact number of members with detailed specification further fine-tune them; and (2) the PEMS procedure drafting group set up in June 2014 per organisation represented)? with the mandate to collect expertise on instrumentation and testing and, based on the initial draft prepared by the JRC, to support the development of the structure of the procedure. The role of these groups is to provide specific advice and expertise to the Commission services with regard to the specific tasks allocated to them. The outcome of the two expert groups is discussed in the RDE-LDV working group. The proposals of the later are then discussed at TCMV level. The group is open for participation to everyone interested in its work and, in fact, experts representing NGOs, academia, equipment manufacturers and automotive industry associations, as well as Member States' authorities and Commission representatives are participating and contributing to its work. The Composition of the participants is balanced and at the same time reflects the specific tasks of the group and the type of expertise required for completing these tasks. All the representatives are participating on equal footing and a no voting system is applied. 1

All the drafts prepared by the two sub-groups are submitted and discussed in the RDE-LDV working group and the results are made public via CIRCABC. There is only one section in the group library to which access is restricted, i.e. the one covering the work of the Task Force on Data Evaluation. Due to the sensitivity of some of the data in this section, access is only given by request and has been provided to various stakeholder groups who are contributing to its work. These include industry, Member States, academia and NGOs. Detailed information on the RDE-LDV working group and its sub-groups is provided in Annex I. All the information concerning the profile of each organisation represented in the RDE-LDV Working Group is publicly available and can be found on the respective organisation's website. 2. At the Commission level the car industry is actively The Commission acts in the general European interest, not in the interests of any specific participating in the work of various "expert groups" group or stakeholder. Stakeholder consultations are integral to well-informed decision- providing "expertise" and technical advice. While it is making and serve to improve the quality of EU law making. In this context, it is natural that clear that the car industry has a lot of useful expertise the Commission closely interacts with a wide range of stakeholders and seeks their views on the subject, which clearly should be taken advantage on how to best design the regulatory framework. This has also been the case in the course of, the influence the industry has on the final version of of preparation of the RDE regulation, where the Commission services regularly consulted proposed legislative measures is rather worrying. Do industry, Member States, research institutions and NGOs. you see any conflict of interest that occurs when those However, stakeholders' input only represents a fraction of the information being assessed being regulated have vital influence on the regulation by the Commission when preparing a legislative proposal, which includes scientific and itself? Should representatives from the car industry only technical publications, results from EU funded research projects, JRC studies, etc. Hence, be consulted at an initial consultative stage of the consulting stakeholders does not prevent the Commission from taking its decisions process and further on any contact should be independently and autonomously. The Commission therefore does not consider prohibited? stakeholder consultation as a potential conflict of interest or as a threat to its integrity. An example of how industry suggestions were treated by the Commission services in the preparation of the RDE is provided in the table attached to Annex I. It shows how the Commission dealt with comments from the European Automobile Manufacturers' Association (ACEA), the main representative of car manufacturers at European level, with regard to key elements of the 2nd Regulation on Real Driving Emissions (RDE), namely the trip definition, boundary conditions and the transfer functions. None of the suggestions to weaken the draft Regulation were taken on board. All the discussions were taking place at

the RDE-LDV working group and were led by evidence-based arguments. 3. During the work of the TCMV committee, ACEA made During the deliberations within TCMV, any views, suggestions and recommendations from different several demands which were aimed at weakening the sources (including industry and/or independent experts), can be brought to the attention of the more stringent and therefore more-difficult-to-comply- Committee by any Member State and/or the Commission that are the only members of the TCMV with testing conditions, which, ACEA claimed had unlike the industry which is not represented in the Committee. In addition, Member States are free to request additional technical or scientific expertise from the Commission or any other relevant nothing to do with realistic car use. For instance less external stakeholder, where deemed necessary. time spent testing in towns or on motorways, narrower boundary conditions, exclusion of cold start emissions An example of how the Commission dealt with ACEA comments in the broader context of in the first package, emissions after prolonged stops not the TCMV's work is provided in the response to Question 2 above. counted, no high-speed tests etc. How does the TCMV work when faced with such demands? Do you bring independent experts that can present scientific and technical facts? Or is the work of the technical committee more political than technical?

4. We understand that on 31 January 2011 DG Enterprise The Euro 5 requirements apply from September 2009 to new types of vehicles and from organised the kick-off meeting of the RDE-LDV working January 2011 to all newly produced vehicles. The Euro 6 requirements apply from group whose objective was to develop a September 2014 to new types of vehicles and from September 2015 to all newly produced complementary test procedure that ensures that the vehicles. The provisions of Article 14 of Regulation (EC) 715/2007 make the emission test emissions of regulated pollutants are appropriately procedures conditional to a review of the emissions of Euro 5/6 vehicles. However, an controlled under normal conditions of vehicle use. This assessment could only be completed once a significant number of Euro 5 vehicles were available on the market. In this regard, the outcome of the first study delivered by the JRC took place four years after the adoption of the 2007 in 2011 was needed to provide the necessary scientific evidence and testing data for the Euro 5/6 Regulation, which mandated the Commission development of real driving emission test procedures. to keep the test cycle under review. The RDE-LDV working group looked into four potential approaches to improve the future We understand that between the beginning of 31 real driving emission (RDE) test procedures in the context of type-approval (multi-cycle January 2011 and the end 2012 four candidate testing like in the US, emissions modelling, random driving cycles and on-road emissions procedures were initially discussed in the RDE-LDV testing with PEMS). working group: Approach (i) was very much favoured and claimed to be effective by industry. It was 3

i. multi-cycle test approach like in the US, considered to assess and test an "honest" (i.e. realistic) environment since it would in principle require the optimisation of emission control over a large area of the engine map. ii. emissions modelling, However, it would still leave the possibility for the use of "defeat devices", i.e. cycle sensing iii. random driving cycles, and subsequent adaptation of NOx control. This approach was rejected by the Commission iv. on-road emissions testing with Portable Emissions and national regulators due to the serious concerns regarding the possible use of defeat Measurement Systems (PEMS). devices. An example for this doubt is that it would have been possible for car manufacturers to reduce the level of emission control at temperatures below the lab test After that, only the two latter options were taken temperature or at driving patterns not corresponding to a regulatory cycle. forward for further consideration. Only in October 2013 the work continued with a dedicated RDE task force Approach (ii) was not followed up further because at that time it was not considered as focusing on the last option. Why did you need two technically feasible. years, from the beginning of 2011 until the end of 2012, Approach (iii) would have offered widely randomised cycle conditions and hence it would in order to narrow down four options to two options? be more difficult for car manufacturers to identify and predict these cycles. In principle, this would have reduced the risk of defeat devices. Nevertheless, the possibility of cycle sensing could not be totally excluded and hence it was not further pursued. Approach (iv), i.e. the measurement of emissions on the road, was overall considered as the most robust approach and was hence retained. However, it was necessary to define a complex structure of boundary conditions to ensure unbiased driving (see Annex I). Instead of calculating boundary conditions, the Commission also considered the possibility of supplementing the RDE test procedure with random cycle testing, since this random cycle testing would have been calculated automatically, without any human interventions. However, in light of the identified disadvantages outlined above, this approach was abandoned. It should be noted that by early 2012, the Commission had narrowed down the four options to two options (on road testing/PEMS + random test cycle), despite heavy criticism of the industry which favoured the US approach (multi-cycle testing). Once this decision was taken, several options of combining these two methods for the different stages of the type approval were discussed (e.g. use random test cycle for the initial type approval test and PEMS testing for the validation testing; or use the random test cycle for PN testing and PEMS for NOx testing) in the course of the year 2012 until early 2013. In the end, for reasons of simplicity and regulatory trust, only the on-road testing with PEMS technology

was retained. 5. When exactly did the Commission begin to examine Regulation (EC) No 715/2007 requires the Commission to keep under review the whether the New European Driving Cycle was still representativeness of the test cycles and test procedures. The need for a new more realistic contemporary or needed readjustments? test procedure became apparent already from the entry into force of that Regulation and the Commission therefore immediately supported the work that was initiated in 2008 at the United Nations Economic Commission for Europe (UN/ECE) in developing a new more representative laboratory test procedure – the World Harmonised Light Vehicle Test Procedure. The WLTP was agreed at UNECE level in March 2014 and the Commission is now proposing to replace the New European Drive Cycle (NEDC) and introduce the WLTP for the

purpose of CO2 and fuel consumption testing from 1 September 2017.

The WLTP is expected to significantly reduce the difference between the CO2 emissions measured in the laboratory and those measured under real driving conditions. It will provide a drive cycle that is more representative of EU driving conditions and a test procedure that is more strictly defined, minimising the use of tolerances and reducing the difference in technology performance between the test and real-world conditions. The Commission has also commissioned several studies to better understand the gaps

between the CO2 emissions measured NEDC and real-world emissions and these results have fed into the development of the WLTP. The results will also be of importance to understand how to ensure that the new procedure continues to reflect real driving conditions over time.

6. Was the Commission already aware of the No. The Commission was not aware of any instances of use of defeat devices. temperature-sensing software that reduces the Please also refer to the written reply to Question 3a of the EMIS Committee questionnaire efficiency of emission reduction systems in cars, or the 1 provided by DG JRC prior to the hearing on 19 April 2016. use as defeat devices, as well as other devices with the same function? If they were, since when and what was known? Has the Commission been in contact with the manufacturers regarding this matter? If that is the case, when was this topic first discussed in the working groups with inclusion of the member states?

1 Question 3a: In 2013, two years before the Volkswagen scandal, you had warned EU officials of the dangers of defeat devices. What was the basis for your reference to the possible use of defeat devices by car manufactures in your 2013 report?

Response: The 2013 report had the objective to assess random cycles and on-road testing with PEMS as two RDE candidate procedures. The assessment was based on emissions tests conducted at the JRC and expert judgement. The on-road emission measurements reported by JRC did not allow to establish whether the elevated NOx emissions were due to insufficient emission control, just "negligent" calibration thereof, or an intentional manipulation of vehicles. The JRC did not have any concrete information that car manufacturers applied illegal defeat strategies at any point in time. Specific search for defeat devices was not in the scope of the JRC work; testing for the existence of illegal defeat devices according to the legal definition would have required a much deeper and more sophisticated analysis, for which resources (e.g. special IT knowledge) were not available.

The JRC was aware of the possibility that defeat devices could, in principle, be applied. In 1998, US-EPA accused several US heavy-duty vehicle manufacturers of violating the Clean Air Act by installing illegal defeat devices. As part of the resulting settlement with the EPA, these manufacturers received heavy fines and were subjected to new emissions standards which included on-road testing. A subsequent law suit in 2001 was settled in 2003 with a general agreement between heavy-duty vehicle manufacturers and EPA on provisions of on-road emissions testing with PEMS. In Europe, Regulation 715/2007 explicitly prohibits defeat devices, thus implicitly deducing that such devices could also be applied in light-duty vehicles, in particular with vehicle control software becoming increasingly sophisticated. Against this background, the 2013 report by the JRC concluded that random cycle testing in the laboratory may be less robust than on-road testing with respect to the application of defeat strategies. This conclusion, alongside the explanations in Box 2 of the 2013 JRC Report, is derived from Regulation 715/2007, past experiences and a risk assessment based on expert judgement and deductive reasoning.

7. According to your knowledge, why were car Manufacturers have the obligation to respect the law and EU Member States have the manufacturers not obliged to disclose if they have used standing obligation to enforce it. This also applies to the ban on the use of defeat devices. the exemptions for defeat devices provided for in Article 5(2) of Regulation (EC) 715/2007? In Regulation (EC) 715/2007, there is no explicit requirement for manufacturers to disclose relevant information on whether they make use of the exemptions under Article 5(2). After the VW revelations, the Commission provided in the 2nd RDE Regulation (EU) 646/2016 for the obligation of the car manufacturers to declare their emission reduction strategy. 8. Did the TCMV discuss the public reports regarding the The 2011 and 2013 studies of the JRC have been made publicly available and their content significant and increasing discrepancies observed in was discussed with Member States and stakeholders when developing the RDE test PEMS tests in real world riving as regards NOx procedure in the RDE-LDV Working Group (2011-2013) and in the TCMV (2014-2015). Neither the Commission services nor the Member States' representatives in the TCMV had, emissions compared to the legal limits? Did the at the time, expressed any specific intention to pursue (or not) compliance actions due to Commission or representatives of Member States’ NOx exceedances, since the type-approval framework which both the Commission and the authorities express their intention to pursue with national authorities of the Member States are implementing and ensuring compliance with compliance action, or was there perhaps a coordinated requires the NOx limits to be met in the laboratory tests set out in Union law. Commission view not to pursue the evidence of NOx exceedances? services were of the opinion (as concluded in the 2013 JRC study) that the best way to Did the Commission present a legal or other advice on minimize high real driving emissions was through the development of RDE procedure. High what type of compliance action should be taken? on-road emissions due to potential illegal defeat devices, as described in Union law, therefore remained very much in focus. In 2012 the Commission sent letters to all Member States stressing the need to enhance market surveillance mechanisms and to ensure that Member States had the necessary structures and resources in place to identify and take corrective actions in relation to vehicles that either did not comply with the relevant EU type-approval requirements, or were representing a serious risk to safety and the environment. 9. So-called on-board-diagnostic-systems (OBD) are OBD provides information and data stored and displayed in individual vehicles. Their main necessary for precise monitoring of in-use emissions. purpose is to alert the driver in case of technical failures and deterioration of components Does the Commission receive dimensional results from leading to a failure of emission control with respect to the level of a "new" vehicle. These data are not collected systematically or centrally, therefore neither the Commission nor the OBD-systems? Who else has access to those national authorities are in possession of comprehensive OBD data. Manufacturers may of results? Do the dimensional results indicate deviations course collect OBD data, e.g. during regular technical maintenance or periodic inspections. of the exhaust emissions even when the emissions Contrary to the US there is no obligation in Europe to communicate such data to authorities

exceed the set limits? Does the Commission have in- in a systematic manner (the only exemption being in-use-performance ratios (IUPR), which depth knowledge of the involved software (source provide some information about the statistical functioning of OBD in real traffic, but not on codes) and the measuring parameters? actually identified failures). It should be noted that OBD systems in most cases do not measure emissions directly, they rather measure other parameters (e.g. the pressure loss at a particle filter) allowing conclusions to be drawn on the malfunctioning of these components with respect to their proper state on the basis of modelling. By their very definition, OBD systems are not suitable for monitoring real emissions, their purpose is different. A "new" vehicle with emission control systems installed, as intended by the manufacturer, would never produce OBD alerts, even if the emissions of this vehicle were very high in real driving. The Commission does not receive sufficient information from manufacturers to acquire in- depth knowledge about OBD software. 10. The ICCT has recently published initial results of the The Commission does not have any more information on the French testing than what was diesel emissions screening campaign conducted by the made publicly available. While the Commission has repeatedly asked relevant Member French, UK and German governments (links below). Can States authorities for full access to the results of their investigations, none of them has you provide us with more details on the French testing provided it with technical information beyond that in publicly available reports. where the results were anonymized? Especially which The Commission is currently analysing all reports and data received and we intend to cars were tested and with which results? Can you provide a separate report at the end of the investigation period, when all the data from elaborate on whether and why the same car models national investigations are available. scored differently in each test? http://www.theicct.org/blogs/staff/first-look-results- post-vw-diesel-vehicle-testing-france-uk http://www.theicct.org/blogs/staff/first-look-results- german-transport-ministrys-post-vw-vehicle-testing 11. What exactly happened in the meeting of 28 October In view of the vote on the 2nd RDE Regulation, Commission services prepared an analysis of 2015 when the conformity factor (i.e. the multiplier the future regulatory RDE conformity factors (CF), details of which could be explained in a used to calculate the allowable emissions during the on- separate document. The most challenging part of the analysis consisted in taking into road test with respect to the Euro 6 limit) was raised account several sources of error, in particular statistical errors of the test procedure2 and of

2 A conformity factor (CF) defines an upper limit for the emissions during a PEMS trip, while the regulatory emission limit roughly corresponds to the average emissions of all PEMS trips. 8

from 1.6 to 2.1 for the first stage of application of the the measurement equipment. It has to be understood that due to these sources of regulation, and from 1.2 to 1.5 for the second phase? uncertainty one may not assume that the emission limit defined in Regulation (EC) The original lower CFs proposed by the Commission 715/2007 for normal conditions of use of a vehicle would imply a CF equal to 1. On the indicate that it is technically feasible to have lower basis of this technical analysis, possible ranges for the CF were identified. factors. In fact, already at this early stage in the work of The initial Commission draft was very ambitious as it was based on CFs identified at the the EMIS committee we had several speakers lower end of identified ranges and thus corresponded to the strongest environmental confirming that the European car manufacturers can objectives. This draft had to be modified towards higher CFs, within the limits of the deliver clean cars respecting EU legal NOx limits in real identified ranges, in order to obtain a qualified majority in support of the proposal by EU world driving without any necessary adjustments Member States during the TCMV meeting. The agreed CFs remain within the initial ranges (conformity factors) as introduced in the new RDE test. st identified by the Commission (between 1,6 and 2,2 for the 1 step and a margin between How is the aim of a high level of environmental nd 0,2 and 0,6 for the 2 step). The Regulation adopted by the Commission was afterwards protection in the Euro 6 regulation now being subjected to the right of scrutiny by the European Parliament and the Council, neither of implemented? which opposed to it. According to the Commission, are the agreed There will be an annual review of the portable measurement technology that will be used conformity factors, in the light of technical expertise for potentially reducing the value of the margin in the definition of the CF. In its statement presented by several organisations, justifiable? Why the "Towards comprehensive and efficient emission testing in the EU", the Commission technical committee's decision concerning RDE does committed to make use of this revision clause to reduce the second conformity factor not reflect scientific facts? already in 2017 and on an annual basis. The respective legal obligation for performing this review is explicitly included in the 2nd RDE Regulation.

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TAAEG

1. What are the differences between national authorities type- Technical services are designated by Type-approval authorities (TAA) to carry approval (e.g. extent to which the testing is done by private out tests on their behalf. The national administrative organisation of Member companies and whether their links with the automobile industry States, as such, has not been discussed in the Type-approval Authorities Expert are somehow monitored; whether it was aware of the use of Group (TAAEG). Its work focuses on technical questions. defeat devices and whether and how they had been justified by TAAEG was set up in 2010 by the Commission in the form of a consultative body auto manufacturers)? composed of representatives of the national type-approval authorities to assist Was TAAE aware of that the different practices between national the Commission and Member States in implementing harmonised practices authorities could lead to strategic selection of approval-sites (e.g. across the internal market. Therefore, TAAEG is aware of possible different How it would account for the fact that the auto industry would interpretations of the law. Questions in TAAEG are raised by the Commission or not authorize its vehicles where they would be sold or produced, by Member States, usually after having been discussed in the so-called Type but where lower standards were the norm). Could the TAAE Approval Authorities Meetings "TAAM" where only Member States are present. define those practices ("golden cars", defeat devices, testing TAAEG operates in an informal setting and thus cannot take any binding temperatures etc.) that could most likely be used to deviate decisions. Its purpose lies not in decision taking at all, but rather in an exchange testing results from real driving emissions, and to what extent of information. they were used by company/by country? The use of "golden cars" has not been discussed in TAAEG. Neither were defeat device and cycle beating before the VW revelations. Differences between laboratory test results and on-road test results have been /are being addressed through the introduction of a more representative test cycle (WLTP) and of a real driving emissions (RDE) testing. 2. Please explain from your point of view why many manufacturers Information on the number of type-approvals granted by Member States during are requesting type-approvals be carried out in Luxembourg or 2009-2014 can be found in the impact assessment of the recent proposal for a Malta - countries without any car production? What could be the Regulation on type approval of motor vehicles and market surveillance3. During

3 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52016SC0009 Please note, there is a typo on the dates as the reference period covered is 2009-2014 and not 2009-2011 as indicated in the impact assessment.

reasons for that? How many vehicle types have been certified in this period, 1002 approvals were issued by Luxembourg (2nd biggest figure in these countries in the last five years? the EU after Germany with 1209 approvals granted) and 344 approvals were granted by Malta (6th biggest figure in the EU). The impact assessment points out that the distribution of the numbers of approvals granted by each Member State "simply indicate that the technical and administrative capacity to carry out verification testing and to issue type- approvals is unevenly distributed in the EU and not always focussed in the main producer countries. However, it could also be related to differences in the stringency that type-approval authorities and their technical services apply, which could induce applicants to selectively apply for type-approval with those approval authorities who are likely to be the most lenient. Therefore, it is important, to ensure that the observed pattern is not the result of unfair competition between national type-approval authorities and their technical services. In order to be able to better verify this in the future, more data from an improved monitoring of these bodies would be highly useful." 3. Which concrete results has the Type-Approval Authorities Expert The work of TAAEG usually results in a reply to a particular question or Group so far delivered with regard to a more harmonised highlights the need for the Commission to clarify the legislation via future interpretation and application of the current rules? When exactly amendments. Several concrete results can be found in the TAAEG minutes (publicly available) where the Commission reminded Member States of the and in which form has the Commission reminded the Member requirements under the EU legislation, e.g. concerning the harmonized States and/or their type-approval authorities of their standing application of Regulation (EC) 661/2009 on vehicle general safety and the obligations and recalled the need to establish effective market implementation of Directive 2006/40/EC (MAC). surveillance mechanisms at their territories? Please list the respective results, the Commission's reminders as well as reactions of the Member States. 4. Which measures have been adopted by the Commission to verify The Commission is entrusted with legislative initiative and supervision of the that national authorities granted type approval reflecting real implementation of EU law in the Member States. The existing EU legislation on driving conditions? Could you explain the role of the Commission type approval does not provide a role for the Commission during the actual in ensuring that car manufacturers got type approval on vehicles type approval process. As a consequence, the Commission cannot directly verify fully reflecting those that will be then placed on the market? that vehicles approved by national authorities and placed on the market comply According to your knowledge, has the Commission ever checked with their approved type, including as regards their real driving emissions. The

whether the cars receiving clearance for type approval were Commission can only take indirect actions, by launching infringement exactly the same as the ones placed on the market and driven in proceedings against the relevant Member States when it has court proof real world conditions? Which measures in general were adopted evidence that they fail to act against non-compliant products. One example of by the Commission to verify the correct implementation of the such an (on-going) infringement procedure in the automotive sector concerns law with respect to emissions limits? the alleged failure of Germany to ensure the effective implementation of the Directive 2006/40/EC on Mobile Air Conditioning (MAC). The Commission's recent proposal for a Regulation on the type approval of motor vehicles and market surveillance would, if adopted as proposed, significantly change the current situation by entitling the Commission services to carry out checks on vehicles placed on the market and to directly impose penalties in case of non-compliance. 5. What kind of relationship do car manufacturers, type approval The Commission has no concrete indications of a direct conflict of interests or authorities, technical services and laboratories have with each collusion between car manufacturers and technical services. It is common other? Is there a possible conflict of interests between the car practice in most of the regulated product sectors that the manufacturer pays for the compliance costs for authorising its products for placing on the market. manufacturers and technical services? If there is, was the Currently, manufacturers pay a fee directly to the technical services for the type Commission aware of any instances and was this issue ever raised approval testing that these technical services carry out for them. Technical in the Expert Group? For example, sometimes car companies services are dependent on these revenues and compete for this work. operate as technical services. The UK's Vehicle Certification However, given the potential conflict of interest arising from the possible Agency (VCA) has accredited a facility called JLR Product financial links between technical services and manufacturers, and to preserve Compliance Centre Emission Test Laboratory. This shares its the independence of testing, the Commission proposed to modify the existing address with the car manufacturing plant of Jaguar Land Rover remuneration system in its proposal for a Regulation on the type-approval and (JLR). Do you know if the JLR test lab also tests Jaguar or Land market surveillance. The proposal was, inter alia, presented to TAAEG for Rover cars for type approval? Do you believe this would consultation and comments. constitute a conflict of interest? If a car company also owns and Under the new rules, technical services would no longer receive direct runs accredited technical services, is this within the current type payments from manufacturers but instead all fees would be collected by the approval rules? Will this be allowed under the new rules Member States. Member States would have to establish a comprehensive proposed by the Commission in their proposal for a new type national fee structure. This would cover the costs of testing and inspections carried out by the technical services they have designated, as well as to cover approval framework? How will the new proposal ensure there the costs of the certification, market surveillance activities and conformity of are no conflicts of interest? Who oversees self-testing by car production review assessments. The proposal also foresees more stringent 12

manufacturers? Why wasn't the independence of technical tests performance criteria for technical services. They will be regularly and strengthened earlier at a European level? independently audited to obtain and maintain their designation. The reference to JLR is not accurate. JLR was notified by the UK as a technical service for individual approvals, not for type-approvals. Individual approval is a procedure used to certify a vehicle by a particular person. Self-testing is allowed for a limited number of simple issues (e.g. space for the registration plate) by the current framework as well as by the new text (see list of Annex XV). It does not concern emissions. It is normally not applicable to large volume manufacturers because it is too costly and lengthy in time. So it is not about self-testing but to provide testing facilities close to home for citizens. Testing on the premises of the manufacturer for practical reasons (lack of test houses), is also allowed by both the current and the proposed framework; however, these tests are performed or supervised by a 'real technical service'. 6. It has been a common knowledge that car industry uses practices Since Regulation (EU) 715/2007 entered into force, the Commission has not that, whilst not against the law, are certainly not in the spirit of received a single request from Member States' authorities or industry the law (for instance preparing 'golden cars' for tests or use of representatives pointing to the need to clarify its provisions. The Regulation defeat devices).The new Regulation on type-approval does not already contains a definition and rules for defeat devices that provide sufficient clarify the issue of defeat devices, which are being widely legal clarity, even if the implementation faces certain factual/technical misused by manufacturers due to a lack of clarity over how a challenges. In order to ensure a coherent/ uniformly effective implementation defeat device is defined. Could you please explain why the final of this ban of defeat devices across all Member States, the Commission has text does not include a concrete definition of what constitutes a provided for an obligation for car manufacturers to disclose and justify the defeat device including obligations for car manufacturers to installation of devices under Article 5(2) in the 2nd RDE Regulation (EU) disclose and justify the installation of any auxiliary devices, which 646/2016. change the normal functioning of a vehicle? Could you please explain why the final text does not include any provisions The issue of "golden cars" is different from the use of defeat devices. The prohibiting too flexible interpretation of the Regulation by the practice of using "golden cars" for type approval is addressed through the manufacturers and thus making the use of 'golden cars' illegal? introduction of RDE and WLTP.

7. Which type-approval authorities of the Member States are Checks on cars already in circulation are carried out in accordance with 4 5 already now executing regular ex post checks of cars in Directive 2009/40/EC , repealed by Directive 2014/45/EU from 20 May 2018, circulation? Which are the Member States with effective and which requires each Member State to ensure that vehicles registered in its territory are periodically tested by testing centres authorised by the Member sufficient market surveillance to control the conformity of cars State in which those vehicles are registered. Roadworthiness tests may be already in use? carried out by a public body entrusted with the task by the Member State or by bodies or establishments designated and supervised by that Member State, including authorised private bodies. Testing of exhaust emissions is included in the list of minimum requirements to be checked within the roadworthiness tests. As regards vehicles placed on the market, the market surveillance authorities of the Member States are responsible for ensuring that those vehicles are in conformity with their approved type. Market surveillance is organised at national level and Member States are required to ensure an appropriate set of infrastructures for that purpose and to prepare national market surveillance programmes. The responsibilities of the national market surveillance authorities include the tasks of keeping citizens informed about potential risks and ensuring that corrective measures (including bans, withdrawals, recalls or any other measures that ensure that conformity is re-established) are taken against non-compliant products. The level of the sanctions is also determined at national level. In 2012, the Commission reminded the Member States of their obligation to establish on their territories effective market surveillance systems and to ensure that the necessary structures and resources are put in place to identify and take corrective actions in relation to vehicles that either do not comply with the relevant EU type-approval requirements, or represent a serious risk to safety and the environment.

4 OJ L 141, 6.6.2009, p. 12.

5 OJ L127, 29/4.2014, p. 51.

8. The Commission describes the task of your expert group on its The Commission was not aware of any instances of use of defeat devices before website as to "monitor the development of national policies and the outbreak of the VW scandal. the enforcement of EU legislation by national authorities". Did The statement that the JRC reports from 2011 and 2013 indicated that such you monitor the enforcement of the Commission's regulation devices were being used is factually wrong. In fact, the 2011 report only

from the year 2007 prohibiting defeat devices after your in-house concludes that "the results indicate that NOX emissions of light-duty diesel colleagues from the Joint Research Centre pointed out in 2011 vehicles substantially exceed the Euro 3-5 emission limits: by a factor of 4-7 as and 2013 that such devices were being used? averages over entire test routes and up to a factor of 14 for individual averaging windows. The increasing stringency of European emission limits has, thus, not

resulted in an equivalent reduction of on-road NOX emissions of light-duty diesel vehicles." Further on, the 2013 Report points out that "PEMS appears to be more effective in preventing the detection of emissions tests by vehicles and thus the use of defeat strategies under normal conditions of vehicle use", however, it does not suggest or provide any evidence that defeat devices might have been used on the tested vehicles. 9. Could you please provide an overview for the 15 most sold diesel The Commission does not have the information requested by the European models in the European Union in 2011, 2012, 2013, 2014 and Parliament. Member States are not obliged to provide such information under 2015 providing information on where and by which organisation the current legislation. In the new Regulation for type-approval of motor the emissions, emissions-related technologies and the engines of vehicles and market surveillance it is proposed that Member States make the models were tested (the relevant test organisations) and type available to the Commission all data related to the type-approval by approved (the relevant type approval authorities for pre- establishing a database. production type approval)? General information on the most sold models of vehicles in Europe is however

available on the Internet. 10. Could you also indicate which Conformity of Production (CoP) These questions need to be addressed to the respective TAA who approved the checks and In-service conformity (ISC) checks were carried out for vehicles concerned. The Commission is not in the position to provide this these models, and by which organisation? Were for these models information. supplementary checks carried out by the national authorities (independent from the check by car manufacturers)? If yes, which national authority and when? 11. Did the TAA Expert group discuss the public reports regarding the No, these issues were not discussed in the TAAEG meetings before the significant and increasing discrepancies observed in PEMS tests in outbreak of the VW scandal, as they were discussed with Member States in the

real world driving as regards NOx emissions compared to the context of other platforms (for example the TCMV). legal limits? Did the Commission or representatives of Member States’ authorities express their intention to pursue with compliance action, or was there perhaps a coordinated view not to pursue the evidence of NOx exceedances? Did the Commission present legal or other advice on what type of compliance action should be taken?

Annex I Explanatory note on RDE-LDV Working Group and its expert sub-groups

The European Commission has the standing obligation to carry out broad consultations with interested parties in order to ensure that the Union's actions are coherent and transparent (Article 11(3) of TFEU). Moreover, the consultation mechanisms form part of its activities throughout the whole legislative process, from policy-shaping prior to a Commission proposal to final adoption of a measure by legislators and implementation. Depending on the issues at stake, consultation is intended to provide opportunities for input from representatives of undertakings and associations of undertakings, NGOs, academics, national authorities, technical experts and other interested parties.

In this context, the RDE-LDV Working Group and its sub-groups were established to support the development process of a procedure specifically assessing the real driving emissions of light duty vehicles in a robust manner with a view to its regulatory implementation. In particular, the RDE- LDV WG was set up with the aim to provide technical advice and a platform for exchange of information and contributions of stakeholders to accompany and support the process of development of the RDE test procedure by the JRC. Therefore, the work of the Group is focussed on technical issues only, while all policy and legal elements remain outside the scope of its activities (they are handled by the Commission within its internal procedures).

In the RDE case, the need to collaborate and consult with stakeholders prior to (or in parallel with) the preparation of the draft legal act stems from the very technical and pioneering nature of the issues at stake which requires access to important inside expertise, knowledge and data available to those stakeholders. Such an approach is fully in line with the principles of Better Regulation. Evidence-based legislation can only be achieved in discussions with those who have the practical expertise. In addition, the role of the Group to provide specific advice and expertise to Commission services on a given subject and in light of a specific mandate fully corresponds to the key principles for the creation and functioning of Commission expert groups (as indicated in the Commission Decision establishing horizontal rules on the creation and operation of Commission expert groups (COM(2016)3301)).

From an organisational point of view, DG ENTR/GROW is supervising the activities of the Group and drafted its Terms of Reference (the final ToRs are provided separately). The Group started its work at the beginning of 2011.

The Group is open for participation to everyone interested in its work. A wide spectrum of experts representing NGOs, academia, equipment manufacturers and automotive industry associations, as well as Member States' authorities and Commission representatives, have been participating and contributing to its work (the list of the participants is provided separately). The composition of the participants is balanced, yet reflects the specific tasks of the Group and the type of expertise required for completing these tasks. All the representatives are participating on equal footing and a no voting system applies.

Meetings of the Group aim at consulting the representatives based on the specific expertise and information they have and at gathering their views on the work-in-progress. However, this does not commit the Commission to reflect these views in the final draft of the legal acts. All the technical considerations which resulted from the work of the RDE-LDV WG were carefully assessed by the Commission in the process of drafting the RDE package and in the following inter-service consultations. In addition, the consultations of stakeholders need to be distinguished from the process in the Technical Committee – Motor Vehicles (TCMV), where Member State representatives are consulted on the draft of the legal act. The Commission may only take the decision of adopting the final legal act following a positive opinion of the Committee (Article 5 of Decision 1999/468 as amended by Decision 2006/512 and recital (21) to Regulation 182/2011).

In order to further support the RDE-LDV WG, two expert groups were set up as sub-groups to discuss and develop specific aspects:  The “Task Force on Data Evaluation" has been mandated to assess candidate data evaluation methods and to further develop/fine-tune them. The data evaluation methods discussed in the "task force" can be found in Appendices 5 and 6 of the Regulation.  The “PEMS1 procedure drafting group”, whose mandate has been to collect expertise on instrumentation and testing and, based on the initial proposal made by JRC, to support the development of the structure of the procedures that can be found in Appendices 1 to 4 of the Regulation. All the proposals made by the two sub-groups were submitted and discussed in the RDE-LDV WG and the results were made public via the CIRCABC group "New light duty test procedures: WLTP, MAC, ...". Access to the group is open to all and does not require any membership or registration with the CIRCABC system. There is only one section in the CIRCA group Library to which access is restricted, i.e. the one covering the work of the Task Force on Data Evaluation. Due to the sensitivity of some of the data in this section, access is only given on request. Access to the section has been provided to various stakeholder groups who are contributing to the work of the Task Force. These include industry, Member States, academia and NGOs.

Meetings of the RDE-LDV WG are convened on a regular basis taking into account the Commission's need for expertise. Usually, they take place in the Commission's premises, but also frequently via audio/web or video conferences. DG ENTR/GROW managed the organization (uploading invitations and documents in CIRCABC) and chaired the meetings.

Though some minutes of the meetings are available, they were not drafted systematically for each and every meeting of the Group due to the following reasons:  a substantial part of the documents were in the form of presentations that are self- explanatory and were as such made available in CIRCABC;  confidential arrangements, for instance, the Task Force on Data Evaluation that was set up under the rules of confidentiality because of the sensitivity of the data;  in-case executive summaries (the discussions' quintessence) were prepared. Examples:

In order to demonstrate how the above process materialises in practice, some examples concerning three key elements of the RDE package, namely the trip definition, boundary conditions and the transfer functions, are given below. The examples focus on comments from the European Automobile Manufacturers' Association (ACEA), which is the main representative of car manufacturers at European level.

Trip definitions

1 Portable Emission Measurement System (PEMS)

2 When the conditions of a PEMS trip are defined, a number of parameters must be specified (e.g. maximum speed, ambient temperatures, altitudes etc.). The table in the Annex explains how the Commission handled ACEA's comments.

Boundary conditions (provided for in the 2nd regulatory RDE act)

Due to their very nature, the driving conditions of PEMS trips show a certain variation (this is actually the main feature rendering the conditions of a PEMS test non-predictable, which is also the main feature for beating defeat devices). As a consequence, without any further requirements, in a regulatory environment, PEMS trips risk to be driven in a biased manner, too aggressive or too soft.

Therefore complementary boundary conditions relating to the dynamics of PEMS trips had to be included to prevent such biased driving. These boundary conditions had to be chosen is such a manner that they include a wide range of driving conditions (i.e. it was agreed to cover at least 95% of all PEMS trips, which can be constructed from statistical real driving data). For timing reasons this development was not finalised for the 1st regulatory RDE act (not a problem since complementary boundary conditions are not of particular importance if PEMS testing is done without binding limits - monitoring phase).

For the 2nd regulatory RDE act boundary conditions were developed in the RDE-LDV (sub-group data evaluation task force), ensuring on the one hand that PEMS trips are driven with sufficiently high dynamics (addressing so-to-say the "regulator's risk", e.g. preventing driving with constant speeds only) and on the other hand not with unnaturally high dynamics (addressing the "manufacturer's risk" that a vehicle is challenged by a third party not because of its bad emission performance but because of a biased execution of the test).

There was a wide consensus among experts present at RDE LDV WG meetings about the way/method of defining complementary boundary conditions, i.e. using upper limits for the 95%- tile of the second-by-second values of the value (velocity x acceleration) and minimum values for the RPA. During the discussions on numerical values of these upper limits, ACEA strongly encouraged the choice of lower values leading to more lenient test conditions. The Commission services nonetheless decided to use the WLTP2 driving database for deriving values with sufficient statistical evidence, even increasing them further.

Following the opinion of the TCMV on the 2nd regulatory RDE act delivered on 28 October 2015, ACEA suggested further additions to the complementary boundary conditions for light commercial vehicles (category N1). They claimed that due to their relatively low power/mass ratio the dynamics of these vehicles at a regulatory PEMS trip should be further constrained. In February 2016, ACEA was informed in bilateral discussions with Commission services that:  The matter is complex and will only be considered (if at all) at the 4th regulatory RDE act, since it is only relevant for independent testing by 3rd parties:  Clear statistical evidence from real driving data has to be provided in order to justify a special treatment of vehicles with a low power/mass ratio;  The criterion for any special treatment must be an objective technical one, e.g. the power/mass ratio, rather than a formal one (belonging to a specific vehicles' category).

2 World-wide Harmonised Light-Duty Test Procedure (WLTP)

3 Transfer functions

Transfer functions are a concept, by which different conformity factors are attributed to PEMS trips, depending on the severity of the trip. ACEA suggested introducing transfer functions for the 2nd regulatory RDE act for the first time in July 2015 (after TCMV delivered its opinion on the 1st regulatory RDE act). ACEA's initial suggestion was that transfer functions would only attribute higher conformity factors than the ones published in the legislation if a trip is considered severe, arguing that such approach would allow a positive public perception of the legislation while limiting the burden to industry.

It has to be understood that the concept of transfer functions, if applied correctly, offers in principle the possibility of achieving the same overall emission level at lower costs or a more demanding emission level for the same costs. So transfer functions are in principle a valid concept, and this explains why ACEA wanted to draw the Commission’s attention to them. However, for the Commission it was also clear that transfer functions could only be applied in an environmentally balanced manner. This means that for some "easy" PEMS trips the regulatory conformity factor would have to be lower than a "central" value agreed in the legislation, if for "severe" trips a higher conformity factor should be allowed. The global effect of the transfer functions on the emissions would at least have to be neutral, to be demonstrated by empirical statistical driving data.

However, an environmental assessment being very complex, transfer functions were not considered a mature concept for the 2nd regulatory RDE act, though it was eventually agreed by Member States at the TCMV to include a placeholder for possible future inclusion, subject to strict conditions. The concept of transfer functions may be investigated at the 4th regulatory RDE act under the condition of an environmentally neutral implementation.

Trip definitions (different positions of ACEA and the Commission services of November 2014)

Reference Current proposal ACEA position Remark

Annex IIIA, 5.1; Vehicle may be PEMS 5.1.3 Moderate Current proposal reflects vehicle payload test with up to 90% vehicle test mass well the requirement of of the maximum load conditions: The compliance with regulatory vehicle test mass shall emission limits under all not exceed the lowest normal conditions of use of: a) vehicle unladen and is well supported by mass excluding driver most Member State experts +200Kg b) 90 % of in the RDE-LDV group. GVW or c) 2840Kg The ACEA position would be 5.1.4 Extended very complicated to vehicle test mass implement. In addition it conditions: The would make PEMS testing vehicle test mass shall at type approval for not exceed the lower moderate conditions quite of: a) 90% of GVW or difficult (i.e. driver + witness b) 2840Kg + PEMS equipment < 200 kg)

Annex IIIA, 5.2.4. Moderate 5.2.4. Moderate Current proposal 5.2.4 and 5.2.5, temperature temperature constitutes already a PEMS ambient conditions: greater conditions: greater compromise with respect to test than or equal to 273K than or equal to 282K the requirement of temperature (0°C) and lower than (9ºC) and lower than compliance with regulatory or equal to 303K or equal to 303K emission limits under all (30°C) (30°C). (Note: 3 ºC to normal conditions of use be introduced in a (i.e. basically the 5.2.5. Extended second phase 5 years temperature range should temperature after RDE-Regulation be wider). It is based on the conditions: greater was published within analysis of metrological than or equal to 266 OJ) data and well supported by K (-7°C) and lower most Member State experts than 273 K (0°C) or 5.2.5. Extended in the RDE-LDV group. greater than 303 K temperature (30°C) and lower conditions: greater The ACEA proposal would than or equal to 308 than or equal to 276 K leave a large area of real K (35°C) (3ºC) and lower than driving conditions in the 282 K (9°C) and lower autumn/winter and in than or equal to 303K middle and northern Europe (30°C). (Note: -7ºC uncontrolled.

5 may be introduced It should also be noted that after a cost- PEMS currently only relates effectiveness analysis to driving conditions with a considering a low warm engine since the cold temperature CF in a start is excluded. There is second phase 5 years no technical reason why the after RDE-Regulation emission performance of was published within vehicles with a warm engine OJ) should be worse when the ambient temperature is lower. If ACEA is concerned about the handling of the cold start at lower ambient temperatures (the cold start should be included into the PEMS procedure at some point), these concerns could be addressed by a recital.

Annex IIIA, 6.7, The vehicle shall never The Commission services The vehicle shall maximum exceed 145 km/h on are of the opinion that a normally not exceed vehicle velocity open public roads. particular limit for the a velocity of 145 maximum velocity for PEMS km/h. However, for The speed range of testing is not necessary, due practical reasons this the motorway driving to the application of a velocity may be shall properly cover a normalisation process at exceeded by a range between 90 and the data evaluation. After tolerance of 15 km/h at least 110 km/h. The discussions at the RDE-LDV for not more than 3% vehicle's velocity the Commission services of the driven should be above 100 have nonetheless agreed to distance during km/h for at least 5 a maximum velocity for motorway driving. minutes. PEMS testing of 160 km/h.

The vehicle's velocity After further comments above 130 km/h may from various Member be driven for a States at the last TCMV the maximum of 5 % of Commission services have the distance driven on lowered this value to 145 the motorway if the km/h. legal situations allows The suggested marginal it. exceedance of this value is necessary to allow for PEMS testing "very close" to 145 km/h under practical conditions (otherwise a very short, marginal exceedance of this maximum velocity

6 would invalidate the entire PEMS test). In addition, with respect to the previous proposal, the high speed test for "fast" vehicles has been removed on request of ACEA.

It should be noted that the current Commission service and ACEA proposals are very close.

Annex IIIA, 6.8, 6.8. The average 6.8. The average The Commission service average urban speed (including speed (including proposal is supported by driving velocity stops) of the urban stopsidling) of the urban driving data. The at PEMS test driving part of the urban driving part of upper limit for the average trip should be the trip should be velocity of urban driving of between 15 and 30 between 25 and 45 45 km/h (including stops) km/h. The vehicle's km/h. The vehicle's suggested by ACEA does not speed should be less speed should be less seem to be appropriate, than 1 km/h for at than 1 km/h for at given that there is a urban least 10 % of the least 10 % of the time. speed limit of 50 km/h in time. most Member States. - For practical reasons with experience from more than 100 of PEMS-Trips the minimum average speed should not be lower than 25 km/h. In addition to that, 80 % of distance weighted in urban EU- WLTP is larger than 25 km/h speed.

If the Commission wants to avoid constant driving a separate paragraph could make this possible.

EUROPEAN COMMISSION ENTERPRISE AND INDUSTRY DIRECTORATE-GENERAL

Industrial Innovation and Mobility Industries Automotive industry

Brussels, 26 January 2011 ENTR.F1/xx D(2011)

Working group for the development of a real driving emissions test procedure for light-duty vehicles (RDE-LDV): scope mandate

(DRAFT !)

1. BACKGROUND

At the workshop on the "future approach to automotive emissions" of 23 November 2010 the Commission (JRC) and some Member States have presented data demon- strating that Euro 5 vehicles currently being on the market do not comply with regulatory emissions limits under real driving conditions. These Euro 5 data confirm similar data collected previously on Euro 3 and Euro 4 vehicles, which show that e.g. real driving NOx emissions of light duty diesel vehicles did not change much, if at all, over the last decade, despite ever more stringent regulatory limit values.

As a consequence Article 14(3) of the Euro 5/6 Regulation 715/2007/EC requires the Commission to adapt type approval procedures such that they reflect real driving emissions of regulated pollutants (currently CO, HC, NOx, PM/PN). In this context Recital (15) makes explicit reference to the use of "portable emission measurement systems" (PEMS) and "not-to-exceed" regulatory concepts.

The development of procedures specifically assessing the real driving emissions of regulated pollutants has been excluded from phase 1 of the World Light duty Test Procedure (WLTP) at UNECE in June 2009. Basically real driving emissions could be addressed in phase 2 of this process, which runs from 2014 – 2022 (still to be confirmed by contracting parties). Given the massive air quality problems in the Eu- ropean Union and the regulatory provisions of Euro 5/6 Regulation 715/207/EC, supported by the Communication on the application and future development of Community legislation concerning vehicle emissions from light-duty vehicles (…) (2008/C 182/08) of 19 July 2008, it is obvious that such a time frame is not accepta- ble from a European perspective.

Therefore the development of a "RDE-LDV" procedure, which should assess real driving emissions of light duty vehicles in a robust manner with a view to its regulatory implementation at the mandatory Euro 6 dates, is launched at a European level. It should be emphasised that at the current stage no final decision about the method-

Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) 299 11 11. Office: BREY 10/000. Telephone: direct line (32-2) 29xxxxx. Fax: (32-2) 29xxxxx.

E-mail: @ec.europa.eu ology of his procedure has been taken, e.g. whether a “PEMS-like” test or other tests should be used.

The Commission will of course support the consideration of the developed Europe- an RDE-LDV for a respective globally harmonised procedure in phase 2 of the WLTP process.

2. MANDATE OF THE RDE-LDV GROUP

The RDE-LDV working group is open to stakeholder experts and should accompany the development of a RDE-LDV test procedure by the JRC. In particular, the group should provide technical advice and a platform for the exchange of information and contributions of stakeholders that will be discussed and agreed during the process.

The group should focus on technical issues of the RDE-LDV test procedure. Politi- cal elements, e.g. the question of legal implementation for Euro 6 vehicles, will have to be decided elsewhere.

3. ORGANISATIONAL MATTERS

RDE-LDV working group will meet regularly, according to demand, either face-to- face or via audio/web or video conferences. A web-based extranet (Circa) will be established for the exchange of documents.

Stakeholders will have to provide their own travel costs if they do not receive an explicit promise of the Commission for coverage of these costs in exceptional cases.

2 http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=1295

Working Group on Motor Vehicles (E01295)

Subgroup: Real Driving Emissions - Light Duty Vehicles

Organisation

Countries/Areas Organisation Name Organisation Type Membership Status represented

ACEA - European Automobile Manufacturers' Association European Member Association

AECC - Association for Emissions Control by Association European Member Catalyst

AEGPL - European LPG Association European Member Association

ANEC - European Consumer Voice in NGO European Member Standardisation

BEE - European NGO European Member Environmental Bureau

BEUC - European NGO European Member Consumers Organisation

CEC - European Fuels and Lubricants Performance Association European Member Test Development Organistion

CENCENELEC Association European Member

CLEPA - European Association of Automotive Association European Member Suppliers

DOW Automotive Systems Association International Member

FIA - Fédération Internationale de NGO European Member l'Automobile

INTA - Instituto Nacional Research Institute European Member de Técnica Aeroespacial

JAMA - Japan Automobile Association Japan Member Manufacturers Association

NGVA Europe Association European Member

T & E - Transport & NGO European Member Environment

TNO - Nederlandse Organisatie voor Toegepast Research Institute European Member Natuurwetenschappelijk Onderzoek

TRL - Technical Research Corporate United Kingdom Member Laboratory

TüV Nord (Technischer Überwachungsverein - Association European Member Technical Inspection Association)

National administrations

Country Public Authority Membership Status

Department of Transport,Permanent

United Kingdom Member Representation UK

Sweden Permanent Representation SV,Vägverket Member

Ministerie van VROM,Permanent

Netherlands Representation NL,Rijksdienst voor het Member Wegverkeer

Bundesumweltministerium,Permanent

Germany Member Representation DE,Verkehrsministerium