31.3.2009   

EN

Official Journal of the European Union

C 77/1

1.1

In its various opinions on the subject of cutting CO2 emissions, the Committee has always strongly supported the Commission's legislative initiatives aimed at reaching specific visible targets on cutting greenhouse gas emissions as a key contribution to the fight against climate change.

1.2

The Committee agrees with the objectives of the proposed regulation, which is aimed at steadily reducing CO2 emissions so as to meet the proposed target of 130 g/km by 2012, by means of improvements in vehicle motor technology.

1.3

Moreover, the Committee calls for the commitment of all stakeholders to meeting the target of 120 g/km by 2012, through an integrated approach, as set out in the Commission communication of 7 February 2007, and calls on the Council and European Parliament to swiftly adopt all pending legislation aimed at curbing climate change.

1.3.1

The Committee recommends that the Commission set long-term targets, as advocated by the European Parliament: bolder solutions will need to be found for 2020.

1.4

Specifically, the Committee calls for the speedy adoption of the proposed Directive on passenger-car related taxes (COM(2005) 261 final) and the enhancement of Directive 1999/94/EEC on CO2-emissions labelling. It also calls on the Commission to propose and coordinate initiatives on motor vehicle advertising and marketing aimed at promoting more fuel-efficient vehicles.

1.5

Specific legislation for the car industry seems warranted, given the need to move on from the phase of voluntary industry commitments, which, although beneficial in terms of the important progress made on passenger car emissions performance, have proved insufficient to achieve the targets set.

1.6

While endorsing the strategy and proposed approach, the Committee would call for measures that are genuinely feasible, insofar as they strike the right balance between achieving crucial environmental progress on the one hand, and, on the other, the need to safeguard jobs in an industry that employs 13 million workers and to fully maintain the competitiveness of European manufacturers in an undoubtedly strategic sector for the EU's economy.

1.7

The Committee agrees that a regulation is the appropriate legal instrument as it will ensure immediate compliance and thus prevent any distortions of competition. The timeframes and specific details of the proposed measures must be carefully thought out in a more consensual manner, so as to maintain and strengthen the competitiveness of EU manufacturers in a global market and to prevent the emergence of artificial advantages amongst the various segments within the sector.

1.8

To this end, the Committee proposes that the Commission consider the possibility of replacing the current system of defining emission limit values solely based on vehicle mass (as used in Japan), and giving more consideration to other parameters such as vehicle footprint (wheelbase by track width), which is already used as the basis for goods vehicles in the USA.

1.9

The Committee calls for further consideration of the linear function inclination (i.e. the % slope), given its direct influence on the way in which the burden is shared amongst manufacturers. The Commission itself, in its Executive summary of the impact assessment [SEC(2007) 1724] says that ‘The application of these criteria would, on the basis of initial analysis, suggest that in order to strike a balance between them, a range between 50 % and 80 % should be considered further at this stage’, thus implicitly acknowledging the need for a much better impact assessment on such a sensitive issue. Opting for a 60 % slope leaves problems unresolved and could provoke a dispute with manufacturers that consider the decision unfair and imbalanced. The Committee recommends that the impact of the final decision, following all necessary further consideration, be neither beneficial nor detrimental.

1.10

Another aspect that requires careful consideration is the introduction of penalties, under Article 7 of the regulation. While the Committee agrees with this dissuasive approach, it believes that their highly progressive nature will not allow EU manufacturers to adapt their production chains to the new limits within the planned timescale. The measures seem out of kilter with those envisaged for other sectors, while creating an inherent imbalance between manufacturers of small and medium-sized vehicles and those of large vehicles, having a much greater impact on the former.

1.11

The Committee thinks that these are hefty, spiralling penalties and that they may be passed on into consumer prices, placing the burden on the purchaser and possibly distorting competition, while slowing the pace of vehicle fleet replacement. It calls on the Commission to ensure that any funds deriving from this measure remain within the car industry, providing incentives for the trade-in of more polluting cars and campaigns to increase awareness of CO2 emissions as a factor when purchasing, as well as contributing to the huge resources needed for research and development.

1.12

The Committee considers that scientific research is crucial to the degree of progress that can be achieved by the industry. While results can be achieved in the initial phase using existing technologies, it is a reasonable assumption that the future will require ‘a technological break from the present’ through the introduction of more advanced technology.

1.13

In the Committee's view, taking the research route requires huge resources and firm commitment, beginning with the need to ensure coordination of ongoing initiatives in the Member States, universities and technological centres of excellence at all levels, while encouraging the direct participation of manufacturers.

1.14

To this end, the Committee thinks that establishing a dedicated Joint Technological Initiative (JTI) for the car industry could help mobilise the scientific community.

1.15

The Committee thinks that the impact assessment does not go far enough, as highlighted by the Impact Assessment Board itself. In document SEC(2007) 1725 the Board calls for clarification of the possible effects on attaining the targets, and for an explanation of any differences between results from TREMOVE and ex-ante analysis. It adds that further analysis is needed of certain sensitive variables such as fuel prices and autonomous weight increase (AWI). There should also be further assessment of the regional impact, particularly on employment, the automotive supplier industry and competitiveness on external markets.

1.16

In the Committee's view, if such a far-reaching strategy is to succeed, suitable measures are needed to support and protect the industrial structure that exists in Europe, with a view to safeguarding or indeed raising the current level of competitiveness, while maintaining quality jobs in the industry. The Committee advocates a phasing-in approach that would require at least 80 % of the final target to be reached by 2012, the ultimate target then being reached incrementally by 2015.

1.17

A key factor in reaching the environmental targets and safeguarding competitiveness is applying the emissions limits stringently to all non-EU-manufactured vehicles sold in Europe. These limits will apply to imported vehicles.

1.18

Considering that this proposal is only the beginning of a process aimed at tackling environmental problems across the whole transport sector, the Committee calls on the Commission to quickly draw up new legislation to limit CO2 emissions from light goods vehicles, heavy-duty and two-wheel vehicles, collating all the relevant data on their emissions.

1.19

The Committee believes that while sectoral policy for the car industry is of real importance, it does not represent the sum total of our wider commitment to general transport policy. Nevertheless, it is an important token of that commitment, helping to guide the entire industry towards the environmental targets already being pursued by other sectors of EU industry.

1.20

The Committee hopes that the proposed sector-specific measures will be flanked by action focusing on transport demand. It is vital to pursue a rigorous policy aimed at an ever greater shift of transport from the roads onto other means generating fewer greenhouse gas emissions such as rail, inland waterway and public transport (very-low-emitting, where possible).

1.21

The Committee does not agree with the temporary derogation under Article 9 of the Regulation as currently being proposed, given that this clearly means unequal treatment of manufacturers. In the Committee's view it is crucial to avoid enshrining any regulatory advantage that could distort competition.

1.22

The Committee recommends devising a model for calculating CO2 that factors in all emissions deriving from car manufacturing. The carbon footprint should be taken into account with regard to the entire lifecycle of vehicles.

1.23

To achieve this aim, we need to launch a debate on lifestyles — an issue on which the Committee has recently drawn up specific opinions. It is a widely-held belief that if the number and size of private vehicles continue to grow, and if goods vehicles that generate high levels of greenhouse gas emissions and NOx continue to receive preference, the goal of cutting CO2 by 20 % will not be achieved. This cannot and must not be accepted.

2.1

The United Nations Framework Convention on Climate Change, which was approved on behalf of the European Community by Council Decision 94/69/EC of 15 December 1993, requires all parties to formulate and implement programmes to mitigate climate change.

2.2

The Commission responded by gradually developing a series of legislative measures which culminated in January 2007 in the EU proposing in the context of international negotiations a 30 % reduction in greenhouse gas emissions by developed countries (compared to 1990 levels) and a 20 % reduction by 2020. These targets were subsequently endorsed by the Council and the European Parliament.

2.3

An analysis of individual sectors shows that, while overall emissions of greenhouse gases fell by approximately 5 % in the period 1990-2004, CO2 emissions from the road transport sector increased in the same period by 26 %.

2.4

In view of this, there is a need for specific legislation to bring the road transport sector back in line with the overall downward trend in greenhouse gas emissions. More particularly, action is urgently needed on passenger cars, given that they account for 12 % of overall EU emissions of carbon dioxide (CO2), the main greenhouse gas.

2.5

Although significant technological progress has been made in the car industry, leading to a 12.4 % cut in CO2 emissions between 1995 and 2004 by increasing fuel efficiency, the steady growth in demand for transport and constant increase in vehicle size have completely offset this saving, and indeed led to an increase in overall emissions of greenhouse gases by the transport sector.

2.6

The result is that, without specific initiatives, the EU is highly unlikely to be able to meet its target of average emissions from the new car fleet of 120 g CO2/km.

3.1

The Community strategy for reducing CO2 emissions began to take shape in 1995. It was based on three elements:

3.2

In 1998, the European Automobile Manufacturers Association (ACEA) adopted a commitment to reduce average emissions from new cars to 140g CO2/km by 2008, and the Japanese and Korean Automobile Manufacturers Associations (JAMA and KAMA) adopted a similar commitment to reduce average emissions by 2009.

3.3

The Commission recognised these commitments by issuing Recommendation 1999/125/EC (on the ACEA voluntary agreement), Recommendation 2000/303/EC (on the KAMA voluntary agreement) and Recommendation 2000/304/EC (on the JAMA voluntary agreement). On the subject of monitoring emissions the EU adopted Decision 1753/2000/EC of the European Parliament and of the Council establishing a scheme to monitor average emissions of CO2 from new passenger cars.

3.4

On 7 February 2007, the Commission adopted two parallel communications for the automobile sector:

3.5

These communications reported progress towards meeting the target of 140 g CO2/km by 2008-2009, but concluded that without other measures it would be impossible to meet the target of 120 g CO2/km for the new car fleet.

3.6

Both communications called for an integrated approach along two lines:

3.7

The Commission stated in these communications that the average target for the new car fleet should take the following factors into account:

3.8

The framework proposed and endorsed by both the Competitiveness Council and the Transport Council relies on all car manufacturers stepping up their efforts to produce more ecological cars, while at the same time pursuing maximum cost efficiency.

3.9

This means that the reduction in CO2 emissions has to be achieved through an integrated approach that involves all parties. A legislative proposal is thus needed that will meet the targets while maintaining the global competitiveness of the automobile industry.

4.1

The aim of the proposed Regulation (COM(2007) 856) is to ‘reduce CO2 emissions from light-duty vehicles’ and to take steps to achieve the target of 130 g/km by 2012. It applies to motor vehicles of category M1 as defined in Annex II to Directive 2007/46/EC and to vehicles to which type-approval is extended in accordance with Article 2(2) of Regulation (EC) No 715/2007 which are registered in the Community for the first time and which have not previously been registered outside the Community.

4.2

The proposal is part of an integrated approach to be rounded off by measures delivering an additional 10g CO2/km reduction in order to meet the Community's final objective of 120 g CO2/km as set out in COM(2007) 19 final.

4.3

When setting the levels of CO2 emissions, the regulation takes into account:

4.4

The proposed Regulation also seeks to:

4.5

The Commission states that the regulation is consistent with the EU's other objectives and policies and is the result of extensive consultation and input from a working group specially set up under the European Climate Change Programme (the CARS 21 group) with the direct involvement of all stakeholders.

4.6

Legal basis. Article 95 of the EC Treaty is regarded as the appropriate legal basis to ensure a level playing field for all economic actors and provide a high level of protection of health and the environment.

4.7

Subsidiarity and proportionality. The proposal complies with the principles of subsidiarity and proportionality in that, even though it does not fall under the exclusive competence of the Community, it prevents the emergence of barriers to the single market, and the adoption of legislative measures at Community level simplifies action to achieve a harmonised reduction in the climate change impact of passenger cars.

4.8

Choice of legislative instrument. In the Commission's view a regulation is the most appropriate instrument to ensure immediate compliance with the provisions adopted, avoiding distortions of competition which could have repercussions for the internal market.

4.9

Monitoring. Information on emissions of carbon dioxide from new passenger cars, measured on a harmonised basis according to the methodology laid down in Regulation (EC) No 715/2007, must be collected by the individual Member States and reported to the Commission under the procedure laid down in Article 6.

4.10

Certificate of conformity. Manufacturers are required under Directive 2007/46/EC to issue a certificate of conformity which must accompany each new passenger car. Member States will permit the registration and entry into service of a new passenger car only on presentation of such a certificate (with the exception of the derogations provided for in Article 9 of the Regulation).

4.11

Excess emissions premium. Under Article 7 of the proposed regulation, an excess emissions premium will be imposed from 2012 on manufacturers or, in the case of a pool, pool managers, whose emissions exceed the specific target. The amount of the premium will increase significantly in the years after 2012 and the sums collected will be considered as revenue for the EU budget.

5.1

In its resolution adopted on 24 October 2007, the European Parliament welcomed the Commission's strategy but proposed that emission targets be implemented from 2011 onwards in order to reach 125 g CO2/km in 2015 by technical improvements to vehicles alone. The Parliament laid stress on the second step to be taken in view of the longer-term target: reaching 95 g CO2/km by 2020 and possibly 70 g CO2/km by 2025, subject to a confirmation or review no later than 2016.

6.1

Consumer behaviour is of particular importance in successfully cutting CO2 emissions from cars. The Commission has thus begun preparatory work on amending Directive 1999/94/EC on consumer information regarding the conformity of new vehicles to the emissions targets and their fuel economy, aimed at increasing the contribution of car users to achieving the objectives set.

7.1

As in previous opinions regarding Commission proposals on cutting CO2 emissions, the Committee reaffirms its support for all EU initiatives aimed at reaching specific targets on cutting greenhouse gas emissions, as a key aspect of the fight against climate change.

7.2

The Committee concurs with the objectives of this proposed regulation subject to the comments set out below. It calls on the Council and European Parliament to swiftly adopt all pending legislation aimed at curbing climate change.

7.3

The Committee calls for the speedy adoption by the EU institutions of Directive COM(2005) 261 on passenger-car related taxes, which would help accelerate the process of reaching the target, encouraging companies to make greater efforts. It also calls on the institutions to undertake a swift improvement on Directive 1999/94/EC on CO2-emissions labelling and for initiatives to be proposed and coordinated on motor vehicle advertising and marketing. These should include measures to promote more fuel-efficient vehicles and to ban the advertising of the most polluting vehicles.

7.4

The Committee supports the choice of Article 95 of the EC Treaty as the legal basis for the proposed regulation, as this is well-suited to ensuring a level playing field for all actors and a high level of protection of health and the environment.

7.5

The Committee agrees that a regulation is the appropriate legal instrument as it will ensure immediate compliance and prevent any distortions of competition. This choice seems necessary as voluntary commitments entered into by the industry, although beneficial in terms of the results achieved on passenger car emissions performance, have proved insufficient to achieve the targets set.

7.6

The Committee approves the proposal to limit emissions to 130 g CO2/km by means of improvements in vehicle motor technology, though regretting that it appears no longer to be practicable to aim for the tighter target of 120 g CO2/km originally envisaged for 2012. It recognises that the Commission now proposes to achieve the 120 g/km in a different way through an integrated approach, including improved standards for tyres, promotion of consumer awareness, incentives for eco-driving (1) and particularly through greater use of biofuels. But given the growing doubts about the feasibility and desirability of the target for use of biofuels in the transport sector, the Committee does not regard this as a satisfactory alternative.

7.7

The Committee therefore recommends that the Commission should set out now further targets for the car industry to improve the carbon performance of vehicles in subsequent years. We believe that establishing now a sequence of progressively tighter targets for future years would give a clear signal of the standards that will apply in those years, enabling European industry to adjust its production plans accordingly.

7.8

The Committee thinks that achieving this target would represent an important contribution by the motor industry to the fight against greenhouse gas emissions from the transport sector, as over that period it would result in a 400-million-tonne cut in CO2 emissions.

7.9

The Committee believes that a key factor in achieving both the current and longer-term objectives is significant investment in research and development. This must be designed to tie in and coordinate with ongoing initiatives in the individual Member States, universities and all industry-related technological centres of excellence and involve the direct participation of manufacturers.

7.9.1

The Committee would draw the attention of the Commission and the Member States to the need for income support measures to be introduced — inter alia via tax incentives — for large families obliged to use large vehicles. Consideration should also be given to the situation in Eastern European markets where the average fleet lifespan is very high and where more highly polluting second and third-hand cars are sold. Ways should be found of incentivising trade-ins in these countries, by means of specific provisions. Clearly, countries with lower per capita income will not be able to benefit from a general cut in emissions, as people there will be unable to purchase the new, more efficient vehicles, which will most likely be more expensive.

7.10

It seems clear that while over the next few years reasonable results can be achieved using existing technologies, there will be a need in future to consider ‘a technological break from the present’ by introducing more advanced technology.

7.11

To this end, the Committee thinks that establishing a Joint Technological Initiative (JTI) could help mobilise the scientific community. This could be co-funded by a sizeable EU budget allocation, matched by funding from the manufacturers, as recently proposed in important sectors such as hydrogen and fuel cells, aeronautics and air transport, innovative medicines, IT systems and nanoelectronics.

7.12

The Committee supports the introduction of penalties from 2012 for failure to meet the targets, as laid down under Article 7 of the regulation, agreeing with this dissuasive approach, but thinks that these penalties should be earmarked for motor industry-related measures, such as:

7.13

The Committee believes that these measures and their highly progressive nature may not be compatible with the capacity of EU manufacturers to adapt their production chains to the new limits. The penalties, which most likely will be passed on into consumer prices, seem particularly high, and could distort competition and effectively penalise the sector in relation to other industries. A solution will need to be found that harmonises the burden, taking account of the average cost borne by the other sectors of industry involved in curbing CO2 emissions.

7.14

The Committee proposes that the Commission consider the possibility of replacing the current system of defining emission limit values based on vehicle mass, with one based on other parameters, such as vehicle footprint (a car's footprint is calculated by multiplying its wheelbase by its track width).

7.15

The inclination of the linear function (i.e. % slope) will influence the way in which the burden is shared amongst manufacturers and the certainty of the environmental outcome. The nearer the slope is to 100, the lighter the burden to be borne by heavier-car manufacturers. Conversely, the nearer the slope is to zero the heavier the burden imposed to meet the targets (an 80 % slope allows a 6 g emission surplus, a 20 % slope allows only a 1.5 g emission surplus). The Commission has indicated a 60 % slope (4.6 g surplus). The Committee calls on the Commission to reflect further on this proposal, to make absolutely sure that the regulation cannot benefit or disadvantage any EU business.

7.16

If the Commission does decide to retain this mass-based approach, it would not make much sense to review the slope in 2010, while the mass increase should be considered from 2013.

7.17

The Committee calls on the Commission to quickly draw up new legislation to limit CO2 emissions from light goods vehicles, heavy-duty and two-wheel vehicles, for which reliable verified data on actual emissions are needed.

7.18

Besides the crucial issue of environmental protection, the Committee calls on the Commission to give due consideration to the potential effects of this complex process on the 13 million workers currently employed across the motor industry. With rising oil prices and consumer demand for fuel economy, European car manufacturers could gain a competitive advantage by producing more efficient vehicles, which could favour employment in the EU.

7.19

In the Committee's view, suitable and practical measures for research into new, innovative and efficient technologies are needed, in order to maintain or indeed increase the European car industry's competitiveness and the quality of the jobs it provides.

7.20

The Committee believes that an important element in this process is applying the emissions limits, fully and stringently, to all non-EU-manufactured vehicles sold in Europe. These limits will be calculated on the basis of imports.

7.21

The Committee thinks that the progress report to be drawn up in 2010 represents a key opportunity to assess the entire strategy. It therefore asks to be involved in these periodic assessments and thus for an opportunity to give its opinion.

7.22

The Committee thinks that the impact assessment does not go far enough. The Impact Assessment Board's opinion called for certain crucial points to be clarified, given the importance of this issue.

7.23

The Board's recommendations, set out in document SEC(2007) 1725, are as follows: to clarify the impact on fleet composition and the effect this may have on attaining the targets, and explain possible differences between results from TREMOVE (2) and ex-ante analysis; to undertake a sensitivity analysis of certain variables such as fuel prices or autonomous weight increase (AWI); to assess the regional impact, particularly regarding employment; and to consider the effects on the automotive supplier industry, and on competitiveness on external markets. The Committee agrees with these suggestions and hopes that the impact analysis will be broadened accordingly.

7.24

Alongside the proposed measures, the Committee stresses the need to step up policies aimed at reducing transport demand, through an ever greater shift of transport from the roads onto other means generating fewer greenhouse gas emissions, such as rail, inland waterway, or public transport.

7.25

The Committee disagrees with the proposed temporary derogation under Article 9 of the Regulation. As currently worded, it goes against the principle of treating companies equally, effectively distorting competition in this particular market segment as regards similar products with similar characteristics. The Committee considers that the derogation should be granted to all manufacturers (regardless of whether or not they are connected to another manufacturer) competing in the same market segment, which in any case is just 0.2 %.

7.26

The Committee recommends that the Commission set long-term targets, as advocated by the European Parliament: bolder solutions will need to be found for 2020, with particular emphasis on their feasibility. It is crucial to continue cutting emissions, giving a clear signal of our intent to persevere along this road.

7.27

The Committee recommends devising a model for calculating CO2 that factors in all emissions deriving from car manufacturing. In certain countries, for example, many car parts are brought in from very far afield, thus increasing the total emissions per car manufactured, before the cars even hit the road. The carbon footprint should be taken into account with regard to the entire lifecycle of vehicles, including the CO2 needed for scrapping.

7.28

In several recent opinions, the Committee has urged the Commission to launch a debate on lifestyles. While agreeing with the proposed targets, the Committee points out that if current levels of growth continue in the number of private vehicles, road transport vehicles and other modes of transport that generate high levels of greenhouse gas emissions and NOx, and if the Commission's growth projections are borne out, it will be impossible to achieve the goal of cutting CO2 by 20 %, as set out in recent Commission proposals.