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Amendments to emissions type approval testing procedures of light-duty vehicles (WLTP and RDE)

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Public consultation

ID: 13483

Lobbying Activity

11 responses

Transport & Environment demands stricter plug-in hybrid emission tests

Transport and Environment (European Federation for Transport and Environment), 17 Jun 2022

T&E recommends bringing the 2027 emission calculation updates forward to 2025 to fully close the performance gap. They also call for a biannual review of hybrid technology performance to reflect real-world values.
Stricter testing would accelerate the transition to zero-emission cars and improve energy security.
Car manufacturers would lose the ability to meet CO2 targets using misleadingly low emission ratings.

BEUC demands real-world data for hybrid vehicle emissions

Bureau Européen des Unions de Consommateurs, 20 Jun 2022

BEUC calls for using on-board fuel meters to adjust vehicle utility factors by 2024. They want testing to include company car data to reflect real-world driving conditions.
Accurate data helps consumers avoid unexpected fuel costs and choose better vehicle deals.
Car manufacturers would lose the ability to use misleading hybrid ratings for climate targets.

ACEA Proposes Technical Adjustments to EU Vehicle Emission Rules

Association des Constructeurs Européens d'Automobiles, 20 Jun 2022

ACEA recommends lowering hybrid utility factor values to reflect actual driving. They request using PEMS margins terminology and protecting sensitive engine documentation. The industry also seeks early voluntary compliance options for smoother transitions.
This provides stable carbon compliance planning and prevents unnecessary vehicle recalls.
Market surveillance authorities would lose access to sensitive base engine data.

CLEPA urges better data and lead time for emissions testing

European Association Automotive Suppliers, 20 Jun 2022

The association supports revising the Utility Factor but argues the 2027 value should not be set prematurely. They request standardization for emission flags and sufficient lead time for software development.
Standardization avoids costly manufacturer-specific solutions and provides realistic timelines for complex software development.
Users and third-party testers lose transparency if emission data lacks a standardized format.

Consultation response

Deutsche Umwelthilfe e.V., 20 Jun 2022

Deutsche Umwelthilfe (Environmental Action Germany) sees urgent need for action at EU level to adjust the utility factor (UF) for PHEVs In times of climate change and energy crisis, driven by Russia's invasion of Ukraine, we need even more a reduction of energy consumption and CO2 emissions in the…

ADAC urges single-step Euro 7 to prevent consumer confusion

Allgemeiner Deutscher Automobil-Club e.V., 14 Jun 2022

The group opposes more sub-stages, preferring a single shift to new standards. They recommend identical limits for all fuels and removing redundant vehicle testing requirements.
Reducing redundant testing would lower the high administrative costs faced by car manufacturers.
Environmental monitoring agencies lose oversight if production checks and specific temperature tests are abolished.

Emissions industry warns Euro 6e could delay Euro 7

AECC, 20 Jun 2022

The organization requests that Euro 6e implementation does not delay Euro 7. They urge for the swift adoption of ambitious real-world emission standards.
Swift adoption ensures research and employment in the European emissions industry.
European citizens lose out on better air quality and health protections.

ICCT Urges Stricter Real-World Emission Testing for Hybrid Vehicles

International Council on Clean Transportation, 17 Jun 2022

The ICCT recommends adjusting the utility factor for plug-in hybrids by 2023 to reflect real-world usage accurately. They also advocate for extending on-board energy monitoring to battery electric vehicles and making transparency databases public.
Enhanced data transparency allows independent researchers to accurately verify manufacturers' emission and energy efficiency claims.
Automobile manufacturers lose the ability to exploit regulatory loopholes and must meet more stringent reporting deadlines.

ZERO urges faster update to hybrid car emission rules

ZERO - ASSOCIAÇÃO SISTEMA TERRESTRE SUSTENTÁVEL, 17 Jun 2022

ZERO recommends moving the 2027 utility factor targets to 2025. They also want corporate car data included and biennial reviews of emissions legislation.
This change would support their mission to protect the climate and air quality.
Automakers lose the ability to meet CO2 targets using misleadingly low values.

JAMA Urges Two-Year Lead Time for Emission Testing Rules

Japan Automobile Manufacturers Association, Inc. European Office, 20 Jun 2022

JAMA requests a minimum two-year lead time for technical standards to ensure stable product planning. They also advocate for promoting charging infrastructure rather than just modifying emissions calculation factors for hybrids.
This would ensure regulatory certainty and protect the industry's ability to meet CO2 compliance targets.
Environmental advocates lose if delayed rule changes allow plug-in hybrids to continue emitting more than officially recorded.

Consultation response

Clean Air Action Group (Levegő Munkacsoport), 20 Jun 2022

It seems to be in time for the review of utility factors for the calculation of plug-in hybrid (PHEV) CO2 emissions. We needed some practical information about its usability in the transformation of road mobility to the era of Zero-emission vehicles. But the latest data from the International…