EUROPEAN COMMISSION

Brussels, 24.4.2025

SWD(2025) 96 final

Roadworthiness package

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT REPORT

on the revision of the Directives of the Roadworthiness package

Accompanying the documents

Proposal for a Directive of the European Parliament and of the Council amending Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers, and amending Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union

Proposal for a Directive of the European Parliament and of the Council on the registration documents for vehicles and vehicle registration data recorded in national vehicle registers, and repealing Council Directive 1999/37/EC

{COM(2025) 179 final} - {SEC(2025) 119 final} - {SWD(2025) 97 final} - {SWD(2025) 98 final} - {SWD(2025) 99 final}

Table of contents

1.Introduction: Political and legal context

2.Problem definition7

2.1.What is/are the problems?7

2.2.What are the problem drivers?14

2.3.How likely is the problem to persist?19

3.Why should the EU act?21

3.1.Legal basis21

3.2.Subsidiarity: Necessity of EU action21

3.3.Subsidiarity: Added value of EU action21

4.Objectives: What is to be achieved?22

4.1.General objectives22

4.2.Specific objectives22

5.What are the available policy options?23

5.1.What is the baseline from which options are assessed?23

5.2.Description of the policy options26

6.What are the impacts of the policy options?31

6.1.Economic impacts31

6.2.Social impacts56

6.3.Environmental impacts59

7.How do the options compare?62

7.1.Effectiveness62

7.2.Efficiency63

7.3.Coherence65

7.4.Subsidiarity and proportionality66

8.Preferred option67

8.1.Identification of the preferred policy options and stakeholder views70

8.2.REFIT (simplification and improved efficiency)72

8.3.Application of the ‘one in, one out’ approach73

9.How will actual impacts be monitored and evaluated?74

Annex 1: Procedural information75

Annex 2: Stakeholder consultation (Synopsis report)80

Annex 3: Who is affected and how?100

Annex 4: Analytical methods108

Annex 5: Competitiveness check262

Annex 6: Background on roadworthiness legislation and PTI organisation in Member States265

Annex 7: Detailed description of the retained policy measures271

Annex 8: Discarded policy measures287

Annex 9: Comparison of policy options in terms of meeting the objectives290

Annex 10: SME test295

Annex 11: Links between the conclusions of the ex-post evaluation and the impact assessment298

Annex 12: Impacts on fundamental rights300

Annex 13: Impacts on the functioning of the internal market and competition302

Annex 14: Coherence, Subsidiarity and proportionality (detailed analysis)304

Annex 15: Monitoring308

Annex 16: Synergies with other policy instruments310

Annex 17: Evaluation report (separate document)313

Glossary

1.Introduction: Political and legal context

This Impact Assessment accompanies legislative proposals for the revision of three Directives, collectively called the Roadworthiness Package (hereinafter the “RWP”):

·Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers (hereinafter the "Periodic Technical Inspection” or “PTI” Directive) 1 ;

·Council Directive 1999/37/EC on the registration documents for vehicles as amended by Directive 2014/46/EU (hereinafter the "Vehicle Registration Documents” or “VRD” Directive) 2 ;

·Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles (hereinafter the “Technical Roadside Inspection” or “RSI” Directive) 3 .

Road transport plays a vital role in connecting businesses and consumers across the EU, facilitating trade, and supporting economic growth and employment. It facilitates mobility of people and supports many industries, such as manufacturing, construction and retail, by providing the means for the transport of goods. It also plays a critical role in emergency response. In 2021, road freight transport represented 54.3% (1,863 billion tonne-kilometres) of all the goods transported within the EU and was responsible for 87% (4,174 billion passenger-kilometres) of the total passenger transport activity 4 . The road transport sector employs more than 5 million people in the EU, of which 3.3 million work in freight and 1.8 million in passenger transport. At the same time, it is a source of certain negative impacts that are addressed by various EU and national transport policies, among which the Roadworthiness Package is a key building block.

Safe vehicles are part of the so-called “Safe System approach”, as presented in the EU Road Safety Policy Framework 2021-2030 – Next steps towards “Vision Zero” ( 5 ). In this road safety strategy, the Commission proposed new interim targets of reducing the number of road deaths by 50% between 2020 and 2030 as well as reducing the number of serious injuries by 50% over the same period. The UN Global Plan for the Decade of Action ( 6 ) released in October 2021, also applying the “Safe System approach”, promotes the same reduction targets already in place at EU level.

The Safe System approach considers death and serious injury in road collisions as being largely preventable, while acknowledging that collisions will continue to occur. It takes as a point of departure the fact that people make mistakes and aims to ensure that such mistakes do not cause fatalities or serious injuries by acting on five pillars: safe roads and roadsides, safe speeds, safe road users, safe vehicles, and fast and effective post-crash care, which all contribute to reducing the impact of crashes. The Roadworthiness Package focuses on the safe vehicle part of this system.

Road crashes 9  represent one of the most significant negative impacts of road transport. The external cost of crashes represents almost EUR 250 billion per year, i.e., roughly 2% of GDP 10 . There were around 20,600 fatal crashes in the EU in 2022, a 3% increase on 2021 as traffic levels recovered after the pandemic. This represents however 2,200 fewer fatalities (-10%) compared with the pre-pandemic year 2019 (see Figure 1 ). The EU and UN target is to halve the number of road deaths by 2030 11 . The main causes of road crashes are speeding, alcohol/drugs, distracted driving, and various driver errors (such as errors of interpretation or fatigue). Other causes include the inadequate state or design of infrastructure (slippery surface, insufficient markings, poor maintenance), and vehicle defects. In the EU, thanks to gradually improving vehicle technology through EU type-approval rules and a well-developed system of technical inspections to ascertain vehicle safety over the entire lifetime, the share of vehicle defects among the causes of road crashes is now limited to just a few percent 12 . However, this also means that avoidable crashes caused by vehicle defects are still taking place. The Safe System approach requires acting on all these fronts, recognising that the parts of the entire system – including users, vehicles, infrastructure and emergency response – work together as an entity 13 .

Figure 1: Road fatalities in the EU (2001-2022 and the EU 2030 target)

Air pollutant emissions from road transport have been decreasing ever since the introduction of the first Euro emission standard over 30 years ago. Although subsequent emission standards gradually reduced the limits and extended the scope of air pollutants measured, real-life emissions were significantly above the type-approval limits until recently (i.e. when RDE limits were introduced) 14 . Recent remote sensing campaigns indicate that even some of the newest vehicles exceed legal emission limits 15 . According to the European Environment Agency (EEA), despite some improvement, air pollution remains the largest environmental health risk in Europe. Exposure to fine particulate matter (PM) and nitrogen dioxide (NO2) levels caused just under 300,000 premature deaths in 2020. Road transport is the principal source of nitrogen oxides, responsible for 35.5% of emissions in 2022, and accounts for a significant share of PM emissions (8.1% of the PM2.5 and 9.5% of the PM10 emissions) 16 . In 2022, the Commission proposed 17 to revise the Ambient Air Quality Directives 18 which aims to put the EU on a path to achieve zero pollution for air at the latest by 2050 and sets interim 2030 ambient air quality standards aligned more closely with the updated air quality guidelines issued by the World Health Organization (WHO) 19 for key air pollutants, requiring enhanced measures to reduce emissions at source.

For noise emissions, EEA indicates that road transport plays the most significant role 20 , with 70% of the EU population living in urban areas and 25% of the population living outside urban areas being exposed to road traffic noise with an equivalent sound pressure level exceeding 55 dB(A) during daytime 21 , 22 . While a large part of this can be attributed to the volume of traffic and a few other factors, noise emission levels of individual vehicles play a key role, too. The permissible sound level of various road vehicles is regulated by UNECE and EU type-approval legislation 23 . However, here again, regulatory limits are not necessarily respected in real life 24 .

Legal context

To address the safety- and nuisance-related defects of vehicles, roadworthiness testing has been in place in Europe for decades and subject to gradual harmonisation in the Union, with the first set of common rules adopted in 1976 25 and last revised in 2014 as part of the RWP. Consecutive revisions gradually extended the scope of vehicles to be tested, as well as the scope of harmonised rules, including requirements on roadside inspections and vehicle registration documents to improve enforcement. They further specified and updated the required test methods, procedures and related documents to reflect technological progress 26 .

Today, the PTI Directive requires that Member States carry out periodic technical inspections (PTI) on most of the vehicles registered in their territory. This covers cars (M1), vans (N1), lorries (N2-N3), buses (M2-M3), as well as heavy trailers (O3-O4) and high-speed tractors (T with design speed over 40 km/h). It also covers heavy motorcycles, including tricycles and quadricycles (L3e, L4e, L5e and L7e), equipped with a combustion engine above 125 cm3, with certain possibilities for exemptions. The Directive sets out the minimum content 27 and frequency of testing for each vehicle category, except for motorcycles, where Member States have a larger room for manoeuvre. Any deficiency found on a vehicle must be categorised as minor, major or dangerous, with the latter two leading to the suspension of the vehicle’s authorisation to be used in road traffic. The Directive also sets out minimum requirements as regards the independence of testing centres and training of inspectors, testing equipment, and the content of the roadworthiness (PTI) certificate. The validity of that certificate, as well as any other proof of test, must be recognised by Member States for the purposes of free circulation and re-registration of a vehicle already registered in another Member State. 

The RSI Directive complements the PTI Directive by requiring Member States to carry out roadside inspections (RSI) on heavy commercial vehicles, i.e., buses, lorries, and their trailers (above 3.5t), with a target of 5% of the fleet each year. Those inspections must include an initial roadside inspection and, if deemed necessary by the inspector, a more detailed technical roadside inspection. The scope of those detailed inspections are the items tested at PTI and it may also include the inspection of cargo securing. When a major or dangerous deficiency is found during a RSI, the Member State where the inspection took place must notify the Member State of registration, in order to enforce the repair of the vehicle that has been suspended from traffic.

Vehicle registration itself is a national competence. The VRD Directive specifies that Member States must issue registration certificates for vehicles that are subject to registration under their national legislation. It requires that those certificates be issued in either paper or smart card format. The certificates must contain a minimum set of mandatory data elements, may contain certain optional data elements, and must be recognised among Member States for the purpose of re-registration. The Directive requires certain vehicle data to be registered electronically, including the suspension from traffic following a failed PTI, and the cancellation of registration where a vehicle has been treated as an end-of-life vehicle in accordance with Directive 2000/53/EC 28 .

The most recent act adopted by the Commission in the area of roadworthiness testing is a recommendation on particle number (PN) measurement at the periodic technical inspection of diesel vehicles 29 . Although non-binding, the recommendation aims at harmonising the methods of such measurements and the corresponding pass/fail limit instead of the introduction of various methods at national and regional level. Similar Commission recommendations on the assessment of defects during roadworthiness testing have served as basis for the minimum requirements concerning the contents and recommended methods of testing under the current PTI Directive 30 .

Political context

Although the PTI and RSI Directives were marginally amended through delegated acts 31 , to align them with updated vehicle categories in type-approval legislation 32 and introduce the testing of eCall 33 at PTI, the main rules remained the same since 2014. Due to rapid technological progress, some of these rules are however already outdated. For this reason, the Sustainable and Smart Mobility Strategy 34 called for adjustments to the roadworthiness legislative framework to ensure lifetime compliance of vehicles with emission and safety standards, thereby contributing to the EU Road Safety policy framework 2021 - 2030 35 and supporting the European Green Deal’s objectives.

Roadworthiness inspections of vehicles are fundamental to road safety and to ensure the environmental performance of vehicles during their lifetime. As a result of stricter safety and emission legislation, vehicles in the EU have become technically ever more complex. To keep pace with this trend, certain adaptations to how vehicles are inspected are necessary. In addition, enhanced and more effective EU-wide exchange of roadworthiness-relevant vehicle data would help better enforcement of the rules, improving the functioning of the internal market and protecting citizens from fraudulent malpractices, such as odometer tampering 36 .

During the last five years, the European Parliament published a number of related reports and studies, including a resolution on the implementation of the Roadworthiness package in general 37 and on the specific issue of odometer fraud 38 . In these documents, the Parliament pointed at the insufficient decrease in road fatalities and a massive divergence between Member States, highlighting the importance of independent inspections in the wake of emission scandal, the issue of odometer tampering, especially cross-border, as well as the need for further harmonisation of test methods and updates required by the introduction of advanced driver assistance systems and automated driving features. The Parliament called on the Commission to consider tightening the test regime by introducing the obligation of additional checks after reaching a specified mileage for cars used as a taxi or ambulance and for vans, ending the exemption of motorcycles from PTI and introducing mandatory testing of powered two- and three-wheelers with an engine below 125 cm3 and light trailers. In the resolution on the specific issue of odometer fraud, the Parliament drew the attention to the economic and legal significance of odometer fraud in the EU and requested the Commission to submit a proposal for a legislative framework to prevent odometer fraud.

Synergies with other EU policy instruments

Roadworthiness testing relies on the technical specifications of the vehicles that are harmonised at EU level and beyond (UNECE 39 ). Vehicle registration remains a national competence, although it relies on the Certificate of Conformity also defined in type-approval legislation 40 . The most recent and relevant safety- and emissions-related type-approval regulations are the General Safety Regulation (GSR) 41 and the Euro 7 Regulation (EU) 2024/1257 42 . The GSR requires that, from July 2022, new types of motor vehicles are equipped with advanced driver assistant systems aimed at reducing the number of fatalities and serious injuries; these will also be used in automated vehicles. At the time of preparing this impact assessment, it was expected that the co-legislators would adopt the Euro 7 standards replacing existing emission rules for cars and vans (Euro 6) and lorries and buses (Euro VI), thus ensuring that new vehicles are cleaner in real driving conditions and that they remain clean for longer than required by the existing (durability) rules. However, the actual gains in emissions reduction are likely to be significantly reduced due to the final text adopted by Council and by the European Parliament. In line with the Council position, the new rules keep the Euro 6 standard for cars and vans as regards exhaust emissions 43 , 44 . This means that the expected baseline emission reductions will not materialise, thus increasing the potential impact of roadworthiness testing in general, and this initiative in particular.

The focus of the RWP is different from the market surveillance legislation mentioned above. Whereas market surveillance provisions aim to ensure that vehicles continue to meet their type-approval requirements when placed on the market and for a limited period thereafter, and so are effectively focusing on the responsibilities of the manufacturer, the RWP focuses on ensuring that minimum standards are maintained by owners throughout the lifetime of the vehicle. Also, while market surveillance requires testing a limited number of vehicles per model, PTI applies to almost all registered vehicles. Thus, the RWP complements the market surveillance legislation in ensuring road safety and the environmental performance of vehicles during their lifetime. Applying the best available test methods will also help Member States reach the stricter air quality standards (limit values for the protection of human health) set by the revised Ambient Air Quality Directive 45 , notably as regards fine particulate matter and nitrogen oxides.

The Commission is also currently working on an initiative on fair and non-discriminatory access to in-vehicle data 46 , which is crucial for technical inspection centres to be able to carry out their daily tasks. That initiative will include provisions on access to functions and resources, essential for the provision of data-dependent services in the automotive sector. It will standardise the relevant datasets and ensure effective non-discriminatory and secure access for aftermarket and mobility services. A range of automotive service providers, including vehicle repair and inspection companies and authorities have called for an ambitious Commission proposal, to ensure a level-playing field and unhindered access to the relevant in-vehicle data 47 . The revision of the PTI Directive could complement the access to in-vehicle data proposal, through specific provisions facilitating access to the data necessary for technical inspections. More details on synergies with other EU policy instruments are provided in Annex 16.

Evaluation of the Roadworthiness Package

The Commission conducted an evaluation of the RWP ‘back-to-back’ with this impact assessment. The evaluation concluded that the RWP was partially successful in achieving its objectives, contributing to increased road safety, and helping reducing air pollutant emissions from road transport. Defective vehicles may still not always be detected, as some categories of vehicles are not subject to PTI or RSI in some Member States, or the frequency or scope of the testing is not adapted to their higher safety and environmental risk. The identified weaknesses in the current RWP require the Directives to be adapted, to address not only current needs but also future challenges. The links between the main conclusions of the ex-post evaluation and the impact assessment are summarised in Annex 11. The evaluation of the RWP is annexed to this impact assessment report (Annex 17).

Sustainable Development Goals

The initiative contributes to Sustainable Development Goal (SDG) 3 (Ensure healthy lives and promote well-being for all at all ages), including targets 3.6 (halving the number of deaths and injuries from road traffic accidents) and 3.9 (substantially reduce the number of deaths and illnesses from hazardous chemicals and air, water and soil pollution and contamination).

2.Problem definition

The problems, underlying problem drivers and consequences that are relevant for the revision of the Roadworthiness Package are presented in Figure 2. The evidence underlying the problems and their drivers is based on the best available evidence, including multiple studies involving scientific research, as well as thorough consultation with experts.

Figure 2: Problem tree

2.1.What is/are the problems?

2.1.1.Presence of unsafe vehicles on EU roads

Although EU roads are the safest in the world and road safety has improved significantly over the last decades, casualties of road crashes continue to represent high costs to society. Despite the improvement in vehicle technology, including active safety and intelligent driver assistance systems in new vehicles, unsafe vehicles still contribute to crashes, either as the main cause or as a contributing factor. A part of unsafe vehicles is identified at PTI or RSI (i.e., vehicles with major or dangerous deficiencies). Others may not be detected either because PTI cannot detect them or because they are not subject to testing. These include vehicles with safety-related tampering and vehicles with incorrectly secured cargo.

Comparable PTI data on vehicles with major and dangerous deficiencies are only available for ten Member States. 

Table   1  shows the share of those vehicles by vehicle type and Member State, as well as the median by vehicle type. There is great variability between the PTI results of Member States for each vehicle type, which points to the need to interpret these data with care. A high share of vehicles with major and dangerous defects may also reflect variation in the stringency with which testing is applied in a particular country and not necessarily that vehicles are less roadworthy in that country. What is however clear is that the share of unsafe vehicles is significant in all Member States and for all vehicle types where such data is available.  

Table 1: Share of vehicles with major and dangerous defects in the vehicle fleet, by vehicle type - averages over 2018-2022

Source: Ricardo et al. (2023), Impact assessment support study

While not even a well-developed roadworthiness testing system can detect every defective vehicle through PTI or RSI, not all defective vehicles will cause a crash either. Various studies 48 indicate that their share as a contributing factor of the cause of crashes is between 3 and 19%, depending on the scope and methodology of the study; for motorcycles, it is 5% to 12% of crashes 49 . Since PTI has been in place in Europe for a long time, there are very few recent studies covering EU Member States 50 . There are similar studies from other parts of the world 51 , the most relevant of them being a recent US study 52 that looked at the difference in crash rates between states with and without PTI. It shows that states with a safety inspection, even if only a very simple one for light vehicles, have 5.5% fewer fatalities on average. 

Naturally, older vehicles are prone to more frequent breakdowns, and studies have shown that older vehicles with defects contribute more to the causes of crashes 53 . The situation is not expected to improve by itself as the contribution of older vehicles is becoming an increasing concern with the gradual ageing of the vehicle fleet 54 . Since cars are responsible for by far the largest share of fatalities (see collision matrix 55 in Figure 3 below), and even if technical defects only represent a relatively small share among the causes of accidents, early detection of those defects can make a significant difference, especially in terms of road safety.

Figure 3: Road traffic fatalities in the EU by road user and (other) ‘main vehicle’ involved in the crash

Source: CARE database

Since there is an element of uncertainty in the actual contribution of vehicle defects to road crashes, a sensitivity analysis was justified. 56 The shares used in this impact assessment (4% for cars, vans, HDVs and 6% for motorcycles) are relatively conservative, e.g., compared to the range based on the literature review presented above. This approach was used to avoid overestimating the benefits.

Secondly, there is an issue related to safety-related tampering, which includes the manipulation of engine performance, torque, maximum speed and improved acceleration, representing an obvious safety risk. According to experts, the chip-tuning of electric vehicles is as easy as in the case of those equipped with internal combustion engines, with the added risk of an overheated battery, which can cause fire e.g., in the case of faster charging or faster discharging (higher performance). According to others, while the share of tampered cars in the entire fleet remains relatively low, their share is higher among those involved in crashes. Due to the nature of the problem, available data on it is rather limited. The European Transport Safety Council, among other stakeholders, has highlighted the issue of safety-related tampering, notably in the case of powered two- and three-wheelers 57 . A survey carried out for the Austrian Ministry of Climate Protection, based on police inspections, found that roughly every second moped was manipulated (tuned) in Austria 58 . 

In addition, incorrectly stowed or secured cargo can slide, roll, tip over and fall off a vehicle, potentially causing it to overturn and lead to crashes with other vehicles 59 . To address this problem, the 2014 revision of the RSI Directive introduced detailed provisions on the inspection of cargo securing, including its principles, applicable standards, and the assessment of specific deficiencies (as an optional measure). This was complemented by best practice guidelines 60 prepared by a Commission expert group to provide practical advice to anyone involved in loading/unloading and securing cargo, as well as to enforcers. The guidelines and the corresponding provision of the Directive are non-binding, however. In spite of existing rules, according to a major operation of Roadpol in Italy in 2019, 22% of the 40,500 inspected heavy goods vehicles (HGVs) did not comply with cargo securing requirements 61 .

The problem of unsafe vehicles affects not only the owners/users of the defective or tampered vehicles, but also other road users, especially vulnerable ones. Such example of vulnerable road users are motorcyclists and while several factors play a role in motorcycle crashes, such as motorcycles’ and other vehicles’ design (motorcyclists are often overlooked in traffic) and road environment shortcomings (poor road surfaces, poor road alignment, obstacles, limited line of sight),  motorcycle design elements such as tyres, brakes, frame, suspensions are nonetheless very relevant for the safety of motorcyclists, and regular control of their technical condition is considered important for their road safety 62 .

Society as a whole is affected by the external cost of crashes through human and medical costs, production losses, the cost of police, emergency services, congestion, etc. 63

More systematic and targeted testing of vehicles, using improved and updated test methods, could reduce the number of such avoidable crashes. 54 out of the 65 stakeholders who replied to the targeted survey agreed with the problem identified, while only 6 disagreed and 5 were neutral. In the OPC, 78% of respondents (123 out of 158) agreed that the issue of vehicles circulating on the roads with defects or tampered components needs to be addressed.

2.1.2.Insufficient control of vehicle air pollutant and noise emissions 64

Air pollution remains an important cause of poor health in Europe and contributes in particular to respiratory and cardiovascular diseases. 65  

Road transport has significantly reduced its pollutant emissions since 1990, with the exception of compounds NH3 and N2O. Their recent increase is mainly due to new catalytic systems for the reduction of NOx in diesel engines and the use of enriched fuel mixtures to control NOx at high load in petrol engines. While a significant reduction can be seen for both PM10 and PM2.5, the non-exhaust fraction of these emissions (i.e. from brake and tyre wear or road abrasion) is increasing 66 .

 The development of sophisticated emission control technologies has allowed to gradually reduce air pollutant emissions from road vehicles well (orders of magnitude) below pre-Euro standard levels. However, overall emissions from road transport are still too high – they alone are responsible for approximately 40.6% of the total NOx and 10.5% of PM2.5 emitted in Europe 67 , and this has serious implications on human health, the natural environment, and affects the lives of millions, especially in urban areas. Various studies have shown that real-world NOx emissions of modern vehicles were above type-approval limits 68 . Such exceedances can in some instances (due to tampering, for example) be as high as older Euro Standards or even pre-Euro NOx emission levels 69 . Other studies have shown that in the absence of the appropriate emission reducing technology (selective catalytic reduction (SCR) and diesel particulate filter (DPF)) on Euro VI HDVs, vehicles can emit up to a factor of 100 more NOx, CO, and PM than the legal requirements 70 .

The findings of the RWP evaluation show that some of the tests used in PTI are no longer sufficiently sensitive to detect emission failures and the current testing procedures are not fit to meet the EU policy goals as regards air pollution. Modern vehicle engines and exhaust gas systems have critical detection criteria that are not covered by the currently prescribed test methods, and current PTI tools are not able to measure PN and NOx. Considering these shortcomings, the current RWP’s contribution to reducing the number of vehicles in circulation with high emissions has become less relevant. The measurement of nitrogen oxide emissions or PM/PN values for new cars are still not covered by the current RWP and there are currently no EU provisions for testing vehicles for NOx manipulation/defect or manipulation/defect of diesel particulate filters. The share of vehicles found with defective emission control equipment or exhaust emissions above the limits specified in the PTI and RSI Directives ranges from around 1-3% to up to 45% depending on the Member State and the way checks are conducted. Targeted inspections identify higher shares of over-emitting vehicles. Periodic testing has demonstrated that older vehicles can be much more polluting than newer ones, as the effectiveness of emissions reduction systems declines with age. Since some of the defective vehicles emit multiple times over the regulatory limit, even a relatively limited share of such vehicles can be responsible for a large part of overall road transport emissions. This has been demonstrated by various studies 71 .

In addition, there is evidence 72 that the emission control equipment of a non-negligible number of modern vehicles are tampered with, either to avoid immediate replacement of filters or the cost of consumables, such as diesel exhaust fluid (DEF) 73  required for the proper functioning of SCR 74 . Various tampering techniques have been developed to alter on-board diagnostic information and to avoid that the vehicle automatically switches to low-power (or limp) mode, e.g., after it has run out of DEF for a long time. This is consistent with the observation that a small number of “high emitters” are generally responsible for a disproportionate fraction of the overall emissions (e.g., a TNO study 75  indicates that 6% of vehicles defective emission control systems caused 36% of road transport NOx emissions). A recent study involving remote sensing technology screening a large number of vehicles in Flanders, Belgium showed similar results for particle emissions due to DPF failures 76 .

As regards the impacts of the problems on pollutant emissions, the links between cause and effect are more straightforward than in the case of road safety. Even though in the absence of accurate emission testing available on a wide scale, the share of high-emitting vehicles and their contribution to total emissions can only be estimated, the available studies applying portable emission measurement systems (PEMS), recent remote sensing campaigns and the first results of newly introduced particle number (PN) testing in three Member States provide a high level of confidence as regards the scale of the problem, and the calculations of the impacts. 77

As outlined in section 1, road transport is by far the largest source of noise pollution in Europe and is the second most harmful environmental stressor after air pollution 78 . Modified or defective exhaust systems can also contribute to noise pollution. The threshold of noise above which it is considered a nuisance can vary. In the OPC, 91 out of 149 respondents expressed the view that it is very important to address the problem of noise-related tampering/non-compliance in vehicles and 13 had no opinion. Most respondents to the survey and interviews conducted as part of the evaluation believed that technological and market developments had had a low impact on reducing the number of vehicles with tampered or defective noise control systems (46 of 75 respondents; 15 did not know or did not respond). Representatives of the automobile as well as motorcycle manufacturers (ACEA and ACEM) agree that illegal modifications leading to single-event noise peaks need to be addressed through consistent control 79 .

While these vehicles are supposed to be repaired or taken out of circulation, there are still many vehicles with defective or tampered emission control systems that go undetected and continue to cause avoidable damage. Noise tampering mainly affects powered two-wheelers, which are not subject to roadworthiness testing in every Member State. The problem of air pollution and noise generated by vehicles mainly affects people living in the vicinity of major roads, in particular in urban areas, and especially the most vulnerable. Lower income groups tend to be exposed to higher levels of air pollution, while older people, children, adolescents, and those with pre-existing health conditions are more susceptible to negative effects of air pollution 80 . 56 out of the 67 stakeholders who replied to the targeted survey agreed with the problem identified, while only 4 disagreed and 7 were neutral.

2.1.3.Roadworthiness Directives are not effective in enforcing rules in EU cross-border traffic and trade of vehicles

One of the objectives of the RWP was to facilitate free movement for EU citizens and ensure the smooth functioning of the internal market 81 . This is reflected in different elements of the RWP, including the mutual recognition of roadworthiness certificates among EU Member States (as part of the PTI Directive), in combination with the provisions of the VRD Directive aiming to ensure the authenticity, accuracy, and mutual recognition of vehicle registration documents across EU Member States. Brought together, these should facilitate the enforcement of the rules, efficient cross-border transport, and prevention of fraudulent practices, eventually contributing to better road safety and less polluting vehicles on the roads.

According to the findings of the evaluation, communication between authorities across national borders improved following the adoption of the RWP. The PTI and RSI Directives established contact points through which information can be more swiftly exchanged between Member States. However, the evaluation also highlighted that Member States still report difficulties in effectively enforcing road safety measures in EU cross-border traffic and vehicle trade. These have their origin in: (a) Member States registering different sets of vehicle data, and (b) difficulties for competent authorities in accessing vehicle register data and other safety-relevant information of vehicles, notably when these are registered in another Member State. These difficulties make the re-registration of vehicles less efficient and more cumbersome for citizens 82 . Related to cross-border trade of vehicles, the evaluation of the RWP found some incoherencies between the VRD Directive and Regulation (EU) 2018/858 on type-approval requirements 83 : in some cases, in the VRD Directive, definitions of the vehicle registration data and terminology do not correspond to those in the type-approval legislation. This leads to confusion and potential errors in recording vehicle information at the time of re-registration. Furthermore, difficulties in the cross-border exchange of information between Member States’ authorities can also negatively impact the fight against the widespread malpractice of odometer tampering which, by itself, can negatively affect road safety and the environment (due to poorer maintenance). It is also directly affecting consumers given that mileage is an important determinant of used vehicles’ market value.

Odometer tampering rates were estimated at 20 to 40% for cars imported in EU15 countries and 30 to 80% in EU12, according to a study commissioned by the European Parliament 84 , while other studies indicate the share of tampered vehicles to be between 5 and 12% of used cars in national sales and much more, between 30 and 50%, of cross-border sales 85 . According to the support study of the European Parliament’s 2018 resolution on odometer manipulation in motor vehicles in the EU, the total economic costs of odometer fraud in second-hand cars traded cross-border in the EU could be estimated at around EUR 8.77 billion per year 86 . This was found mainly due to the lack of effective cooperation between Member States' authorities and an insufficient exchange of information on mileage readings of odometers in vehicles traded across the Member States' borders. More recent estimates provided by CarVertical 87 , based on analysis of vehicle history reports, suggest overall lower odometer fraud rates for most of the countries reported that those in the European Parliament study. Drawing on CarVertical and other assumptions, the impact assessment support study 88 shows however that fraud rates are still estimated to be significant (i.e., 2.2 to 10% of used cars in national sales and 4.4 to 25.7% of cross-border sales) 89 .

Even though odometer manipulation is a punishable offence under the PTI Directive, the fact that odometer readings are recorded only at PTI does not prevent fraud since most cars and vans are not tested before they are four years old and, in most Member States, only every two years thereafter. Furthermore, the evaluation of the RWP also reported that regarding the obligation to introduce effective and dissuasive penalties when an odometer is found to have been manipulated, the national measures appear in many cases rather generic, not specifically aimed at odometer fraud. 39 out of the 60 stakeholders who replied to the targeted survey agreed with the problem identified, while only 5 disagreed and 16 were neutral.

2.2.What are the problem drivers?

2.2.1.PTI-methods not available to test electric vehicles, electronic safety & driver assistance systems (PD1)

This problem driver links to problem 1 (Presence of unsafe vehicles on EU roads). The existing rules on roadworthiness testing were designed more than 10 years ago, with the Commission’s proposal made in 2012. At the time, the share and expected development of the electric vehicle (EV) market was significantly lower than today 90 , which explains why there are no EV-specific requirements in the PTI Directive. The same applies to electronic safety and driver assistance systems.

The General Safety Regulation 91 requires that, from 6 July 2022, new vehicle types are equipped with certain advanced driver assistance systems (ADAS), including intelligent speed assistance, reversing detection with camera or sensors, attention warning in case of driver drowsiness or distraction, event data recorders, an emergency stop signal (in all road vehicles), as well as lane keeping systems and automated braking in cars and vans. These features will be mandatory on all vehicles registered from 7 July 2024 onwards. Thanks to the requirements of the GSR, new car and van models sold since July 2022 and every new vehicle sold from July 2024 will be due for PTI between 2026 and 2028. Trucks and buses featuring technologies helping to recognise blind spots, warnings to prevent collisions with pedestrians or cyclists and tyre pressure monitoring systems will have to undergo their first roadworthiness tests even earlier (usually one year after the first registration). 

The RWP evaluation found that systems introduced by the revision of the GSR increases the relevance of vehicle roadworthiness testing to verifying the operation of these mandated electronic systems. These systems may malfunction, require software updates to ensure intended performance, and they could be the target of tampering. In terms of keeping up of the RWP with the technological and scientific progress, most of the stakeholders interviewed in the context of the evaluation considered that it is essential to update the directives to include the functioning of ADAS and advanced lighting, which have been fitted in cars for around a decade but are not tested by standard PTIs. Similarly, the survey respondents, especially ministries, road safety authorities and PTI bodies, considered that the current RWP directives and their objectives follow technological advancement only to a limited extent. The technology used in vehicles has surpassed what the current directives cover and new rules for inspection of new safety systems, such as ADAS, are needed. Although both EVs and ADAS bring about significant benefits by reducing emissions and improving road safety, they also come with new risks to be mitigated. In the case of EVs, including plug-in hybrids, the high voltage systems can be a source of such risks, which, if damaged, can overheat and cause fire. While a few Member States have introduced national requirements (e.g., FR, NL) in relation to the inspection of EVs, these are not generally applied in the EU. For ADAS, it is the possible malfunctioning of the systems themselves that may create safety hazards. However, none of these are currently tested during periodic technical inspections.

Next to the research and development efforts needed to define the appropriate test methods, an important barrier to their application is the difficulty for inspection centres to access the necessary in-vehicle data. Although the Commission Implementing Regulation (EU) 2019/621 requires that manufacturers make certain vehicle data available to facilitate PTI tests, it does not apply to the data related to items/components that are not part of the current minimum requirements on items to be tested. According to the findings of the evaluation, there is data incoherence between the RWP and relevant type-approval legislation due to divergence of safety-relevant vehicle data. The interview respondents considered there was a common problem with the RWP regarding the limited direct access to in-vehicle data and functions for authorised inspection service providers. For example, even two models of the same manufacturer can require different file formats, which makes the use of reference data very difficult and time-consuming. 74% of the OPC responses (116 out of 156) were in favour of the need to address this problem driver; a similar percentage of support was expressed by industry representatives during the targeted survey (58 out of 76 responses).

2.2.2.Current PTI & RSI-methods not suited to measuring the emission performance of modern vehicles (PD2)

This problem driver affects problem 2 (Insufficient control of vehicle air pollutant and noise emissions). The existing Directives require exhaust gas emission testing of diesel vehicles using opacity measurement, or, in the case of Euro 5/V and Euro 6/VI vehicles, by reading the vehicle’s on-board diagnostic (OBD) system. While exhaust gas opacity testing may detect a defective emission control system without a particle filter in an older vehicle (pre-Euro 5/V) and has thus been considered sufficient to test the compliance of those vehicles, multiple laboratory tests 92 have proved that it cannot detect a malfunctioning or even tampered diesel particle filter (DPF). DPFs were introduced to comply with significantly stricter limits than before Euro 5/V and the emissions without a DPF could be about an order of magnitude (or two) higher 93 . Even in a Euro 4 vehicle equipped with a defective DPF, the exhaust’s opacity may be lower than the instruments’ resolution. Studies have also shown that even when high smoke emissions are measured, in most cases the OBD does not indicate any failure.

Furthermore, while the newly developed method of particle number (PN) counting 94 has demonstrated high levels of particle emissions in vehicles with defective DPFs, e.g., close to 10% of Euro 5 and 6 vehicles tested in Belgium in 2022, the OBD showed malfunctioning in only 0.72% of the cases 95 . This illustrates the extent to which the current emission test requirements of the PTI and RSI Directives are obsolete and inadequate concerning modern diesel vehicles. Concerns about the ineffectiveness of smoke opacity tests were also expressed by stakeholders surveyed during the evaluation. The applicability of PN measurement has not yet been sufficiently tested for vehicles equipped with positive ignition engines, but relevant research is ongoing. To address the issue of high NOx emissions, various methods have been studied to measure them 96 . However, while NOx emission limits are set by type-approval, and RDE (Real Driving Emissions) tests have significantly tightened the requirements on new vehicles, the monitoring of NOx emissions from road vehicles is currently not part of PTI.

2.2.3.Limited technical possibilities to detect vehicles with defective or tampered components (PD3)

This problem driver is linked to all three problems. Firstly, together with PD1 (PTI-methods not available to test electric vehicles, electronic safety & driver assistance systems), it is one of the reasons why there are still, and will continue to be, unsafe vehicles on the roads. While new vehicle technology may require new ways of testing (PD1), there are vehicles on the roads today with defects that carry a potential safety risk and that PTI cannot detect, notably due to the limited vehicle data available to testing centres (or repair shops). For example, where a windscreen of a vehicle equipped with cameras is replaced, precise calibration requires not only the manufacturer’s specifications, but also the vehicle’s relevant data history (which for some vehicles can provide details of the last time the vehicle underwent a recalibration). Such information is currently not available to PTI.

Similarly, unauthorised modifications to the vehicle’s engine management system to increase its power may not be detected without access to the relevant in-vehicle data 97 . Such tampering is relatively easy, and devices are widely available, for internal combustion engines as well as for electric vehicles (a simple web search would deliver multiple results). The situation is similar in the case of motorcycles 98 . The ongoing electrification of powered two-wheelers, especially mopeds, has apparently led to an increase in the same kind of tampering of those vehicles, with multiple tutorials available online. Since manipulation is so easy in the case of these vehicles, it is difficult to detect it even where such vehicles are subject to periodic testing as the modifications can also be easily reversed. These vehicles represent an increased safety risk, in particular in urban areas.

Secondly, tampering with emission control systems is equally easy with various solutions offered online 99 , even explaining why it is “good” for the user to disable the selective catalytic reduction (SCR) system, which requires diesel exhaust fluid (DEF, or AdBlue). While DEF is a necessary consumable for the SCR to significantly reduce the amount of NOx emissions, since running out of DEF may cause the vehicle not to start, it is a convenient (and often significantly cheaper) solution to deactivate the entire system. It can be especially viable in the case of commercial vehicles, where entire fleets may be tampered to decrease repair and maintenance costs 100 . Together with PD2 (Current PTI & RSI-methods not suited to measuring the emission performance of modern vehicles), this contributes to the insufficient control of vehicle air pollutant and noise emissions. Noise-related tampering, i.e., removing the exhaust silencer (or dB killer) of a motorcycle is similarly easy with abundant instructions available online. According to ACEM and some experts in vehicle testing, PTI is not sufficiently effective when it comes to such tampering.

Thirdly, tampering with odometers is also a lucrative business and detecting it has been a challenge across the EU, which negatively affects the effectiveness of the RWP in enforcing rules in EU cross-border traffic and trade of vehicles. Recording odometer readings at PTI may have somewhat improved the traceability of odometer history, or helped detect fraud (likely too late, when the vehicle is due for PTI with its new owner). However, with PTI being a pre-announced inspection, it is not difficult to readjust the mileage of the vehicle just before or after. Thus, in the absence of a better way to trace odometer history, mileage tampering remains largely possible in most Member States, and especially across borders 101 .

2.2.4.Vehicle identification & status data not sufficiently available to, and recognised among, enforcing authorities (PD4)

This problem driver links to problem 3 (Roadworthiness Directives are not effective in enforcing rules in EU cross-border traffic and trade of vehicles). In addition to the issues mentioned under PD3, the inefficient exchange of information among Member States further contributes to limiting the effectiveness of the Directives. While most stakeholders consider that the RWP has contributed to facilitating communication among Member States, they agree that vehicle identification and status data are still not sufficiently available to enforcing authorities. As mentioned in Section 2.1.3 , there are sometimes significant differences in the data elements recorded in national vehicle registers, largely due to the high number of optional data elements, including those that are not even specified in the VRD Directive. Table 2 summarises the diversity in the registration of various data elements. 224 data elements are stored by only some of the Member States (i.e., not by all, and not by any of them).

Table 2: Summary of the registration of various data elements

Source: EReg/EUCARIS 102

In addition to the regulatory framework provided by the VRD Directive, EReg, the Association of European Vehicle and Driver Registration Authorities, has worked on the voluntary harmonisation of registration procedures and data quality, including on the scope of data that should be stored in vehicle registers to facilitate cross-border trade (re-registrations) and issued various reports on the topic 103 . 

Although the VRD Directive requires Member States to assist one another in the implementation of the Directive, it merely allows exchange of information and only hints at the possibility that this could be done electronically. This has led to a situation where several Member States use EUCARIS 104 for the exchange of vehicle registration data, mileage data, PTI data or roadside inspection (RSI) reports. However, while many Member States use EUCARIS for various services, not all of them use it systematically for the relevant exchange of data. The lack of clear rules as regards the exchange of vehicle related information among Member States therefore further complicates smooth communication between authorities.

To implement requirements of the RSI Directive to notify the Member State of registration of any major or dangerous deficiencies found at RSI, since June 2020, the notifications must be sent using the RSI system 105 , built on the functionalities of the European Register of Road Transport Undertakings (ERRU). ERRU and RSI messaging system, as well as several other road transport-related applications are hosted by the Commission and use a central hub (MOVEHUB) to interconnect national registers. While certain EU legislation requires the use of EUCARIS 106 , and others, including the RSI Directive, refer to the MOVEHUB for data exchange, there is no legal requirement to use such systems to facilitate the re-registration of vehicles and the implementation of the PTI and VRD Directives. The inability to effectively exchange a real-time data on the vehicle (de)registration status, including the information on cases when a vehicle is temporary de-registered or its ownership has changed, contribute to the problem of a low traceability of vehicles across the EU. Such administrative and regulatory failures hinder the uncovering of illegal activities such as the illegal trade or illegal dismantling of vehicles, leading to the problem known as “missing vehicles” 107 .

Certain optional data registered in one Member State are not recognised by another EU country for re-registration. The reason is that the second Member State registers a different set of data. This may concern data related to the owner, the mass, the category, or the exhaust emissions of the vehicle. Moreover, even though there is significant level of harmonisation in roadworthiness testing, there are very few cases where the Member State of registration recognises the validity of a PTI certificate issued in another Member State (one example is the Netherlands accepting PTI conducted in certain PTI centres in Spain). Such lack of recognition of registration data and PTI reports lead to inefficiencies in administrative processes and cause avoidable administrative burden for vehicle owners.

Stakeholders consulted during the evaluation emphasised in their interviews that digital data exchange and harmonisation of vehicle documents is needed for streamlining the vehicle re-registration process since standardising the content and format of vehicle files would facilitate the digital transfer of registration information between national databases and reduce the administrative burden and costs associated with the process. The interviewees stressed the need for a legal framework to support this exchange of data and digital services for efficient re-registration process. 67% of the OPC responses (100 out of 149) were in favour of the need to address this problem driver; a similar percentage of support was expressed by industry representatives during the targeted survey (47 out of 72 responses).

2.2.5.Certain vehicles are not (sufficiently) tested for their roadworthiness (PD5)

Problem driver 5 relates to the fact that certain vehicle categories are not covered by or not necessarily tested under the PTI/RSI Directives and, as a result, PTI/RSI is only required for such vehicles in a few Member States. Furthermore, frequency or scope of testing of certain vehicles is not adapted to the higher safety and environmental risk associated with them (very frequent use or vehicle age). This directly affects the first two problems, i.e., the presence of unsafe vehicles on EU roads and insufficient control of air pollutant and noise emissions. Indirectly, it also has an influence on the third problem, in that testing light vehicles annually from the date of their first registration (as is the case for HDVs), and at the roadside, could also increase the effectiveness of the directives, notably in preventing odometer fraud.

In 2014, the scope of the PTI Directive was extended to faster tractors (design speed >40km/h) and larger two- and three-wheel vehicles and quadricycles (equipped with internal combustion engines >125cm3), effective from January 2022. However, the Directive allows for exempting motorcycles, tricycles and heavy quadricycles (L3e, L4e, L5e and L7e) from PTI “where the Member State has put in place effective alternative road safety measures” and on condition that the Commission is notified. At the end of 2023, eight Member States 108  made use of this possibility. France introduced PTI for powered two- and three-wheelers and quadricycles in April 2024. As such, the scale of the problem is expected to reduce significantly, especially thanks to the introduction of PTI in France.

Agriculture and forestry tractors may also be exempted. Since they are not covered by the PTI Directive, mopeds are only subject to periodic roadworthiness testing in some Member States (e.g., Austria, Croatia, Spain). Although not in the scope of the PTI Directive, more than half of the EU Member States (16) have provisions for mandatory PTI for light trailers (3 Member States have provided this only for the larger O2-category, i.e., with maximum mass above 750 kg and up to 3500 kg), while others exempt them under certain characteristics or conditions of operation 109 .

With regards to the RSI Directive, the requirements on technical roadside inspections currently only apply to commercial vehicles of more than 3.5 tonnes, while vehicles below this weight and their trailers are exempted from inspections in most Member States.

Finally, and most importantly, only 16 Member States apply more frequent (yearly) roadworthiness tests to older cars (>10 years) 110 , that is, eleven, including the Member States with the largest fleets 111 , do not, which represent an increased safety and environmental risk. Since the car and van fleets of these Member States represent roughly half of the EU fleet, and the vehicles older than 10 years among them are about half of that, annual testing of vehicles older than 10 years would affect around 25% of the EU light duty vehicle fleet. 112

2.2.6.Interlinkages between the problem drivers

Some of the problem drivers are interlinked with each other. This is the case in particular with PD3 (Limited possibilities to detect vehicles with defective or tampered components), which is influencing or influenced by all the other problem drivers. EVs and ADAS represent new technologies and test methods for such systems are very recent or just being developed and are not widely used yet (PD1). The lack of legal requirement to test such systems during PTI and RSI for their potential defects may also present a safety risk. PD3 is also linked to PD2 (Current PTI & RSI-methods not suited to measuring the emission performance of modern vehicles) in a similar way as to PD1. Emission control systems have also evolved considerably and developing adequate test methods to verify their functioning in a PTI-environment (i.e., requiring a quick, simple, and cheap method) has taken some time, which partly explains why the current PTI and RSI emission test requirements are outdated. While for the purpose of detecting tampered vehicles, RSI has the advantage of the drivers not knowing that they would be tested, it has the limitation that it is only organised in campaigns and can therefore only screen a small subset of the vehicle fleet. PD3 is linked to PD4 (Vehicle identification & status data not sufficiently available to, and recognised among, enforcing authorities) in that in most Member States it is currently not possible to verify whether the odometer reading of a vehicle is correct or not. Finally, it is linked to PD5 (Certain vehicles are not (sufficiently) tested for their roadworthiness) since it is not possible to detect defective or tampered vehicles that are not tested.

2.3.How likely is the problem to persist?

Problem 1 - Presence of unsafe vehicles on EU roads. While technological development is likely to further improve vehicle safety, the uptake of new technologies in the EU vehicle fleet would take some time, and some of the new features may also bring about new risks. Similarly, while tampering may be made more difficult by technical solutions, it is unlikely that it would disappear without enabling vehicle testing to detect illegal modifications, notably of the engine management software e.g., through securing better access to in-vehicle data. Thus, in the absence of EU level intervention, the problem is likely to persist. Member States may take unilateral measures (e.g., introducing PTI for specific vehicle categories, specific methods for the testing of EVs or ADAS). However, these measures cannot replace the coordinating and harmonising effect of the three Directives, with the risk of possible distortions of the internal market and only partially addressing the problem.

Problem 2 - Insufficient control of vehicle air pollutant and noise emissions. The problem of insufficient control of vehicle air pollutant emissions would persist as long as vehicles equipped with internal combustion engines (ICE) are on the roads. Although with stricter emission standards and gradual electrification the number of vehicles generating tailpipe emissions will decrease, they will still be circulating in the EU decades from now. While the proposed Euro 7 standard should address tampering and durability more effectively than its predecessors, vehicle aging and defects are unlikely to be completely overcome and vehicle inspection will continue to be key. Without updating the current emission test requirements at EU level however, Member States may not introduce the most effective and efficient test methods already available based on Commission recommendations. Similarly, while more Member States may start experimenting with roadside noise testing e.g., as mentioned in section 1, it is unlikely that the problem of noise vehicles would reduce significantly without a more systematic and coordinated approach.

Problem 3 - Roadworthiness Directives are not effective in enforcing rules in EU cross-border traffic and trade of vehicles. Without EU level intervention, certain Member States may take unilateral or bilateral measures, such as systematic recording (and possibly exchanging) of odometer readings, or develop agreements to recognise each other’s roadworthiness certificates. However, the systemic problem of insufficient and inefficient exchange of roadworthiness-related vehicle data would remain, hindering effective implementation and enforcement of existing rules.

Foresight tools. The analysis incorporates throughout all its dimensions relevant foresight tools. It does so to anticipate trends and issues that may affect the initiative and build a robust, future-proof evidence base for its likely impact. The megatrend “Accelerating technological change and hyperconnectivity” will have a significant impact on the road transport sector and is relevant for the problems related to the presence of unsafe vehicles on EU roads and the insufficient control of vehicle air pollutant and noise emissions. However, as explained above, technological change on its own would not be able to address these problems, or at least not for decades from now. The 2022 Strategic Foresight Report 113 points to the potential of digitalisation and artificial intelligence to boost the emergence of more efficient mobility solutions, with a new generation of digital technologies enabling a major shift towards more sustainable mobility for passengers as well as heavy-duty freight transport. This trend will have an impact on all three problems mentioned above. For example, while digital solutions play a crucial role in innovative safety features and highly sophisticated emission control systems, the trend has also led to new tampering techniques in both areas. The trend will also play a key role in addressing the third problem, however, in itself, it will not be sufficient to resolve regulatory failures. The megatrend “climate change and environmental degradation” 114 is directly related to the insufficient control of vehicle emissions, identified as one of the main issues to be addressed in line with the air quality legislation referred to in section 1. The same foresight report identified “enabling a greener transport sector with digital technologies” as one of the areas where the twinning of the green and digital transitions is expected to have a major effect. As regards the expected transformation of the vehicle fleet over the next decade, certain automakers (e.g., Volvo) plan to sell only EVs as of 2030. Those cars will also be connected and featuring the ADAS required by the General Safety Regulation.

3.Why should the EU act?

3.1.Legal basis

The legal basis giving the EU the right to act is Article 91 of the Treaty on the Functioning of the European Union (TFEU. In particular, Article 91(1)(c) provides that the Union has competence in the field of transport to lay down measures to improve transport safety.

3.2.Subsidiarity: Necessity of EU action

In the absence of the EU level intervention, Member States would continue to carry out periodic and roadside inspections, but it is very unlikely that test methods and the scope of inspections required by the EU acquis (e.g. testing brakes, suspension and emissions reduction equipment, etc.) would be applied in a harmonised or coordinated manner. Different and piecemeal solutions would be applied, which would lead to even larger differences in the safety and environmental performance of vehicles than today, with the risk of distorting the internal market, and creating further barriers to free movement. The initiative therefore addresses safety and environmental protection needs with “Union relevance”.

Road transport, especially freight, is an international sector, with vehicle approval regulated at the EU and international (UNECE) level. Therefore, it has by nature a strong cross-border dimension. According to the evaluation and the various targeted stakeholder consultations carried out as part of the revision process, the RWP has been considered to have contributed to road safety and environmental protection in the EU and has even had positive spill-over effects in neighbouring countries.

The identified problems apply across the entire Union and have the same underlying causes. At the same time, there is widespread agreement among national authorities and industry experts that the current Directives are no longer aligned with the latest regulatory and technological developments in vehicle safety and emission control. In the absence of EU action, EU Member States may implement national solutions and will work in an uncoordinated and non-harmonised way. This could undermine the harmonised safety and emission standards.

3.3.Subsidiarity: Added value of EU action

As road transport and the automotive industry are international sectors, it is much more efficient and effective to address the issues at the EU level than at the level of Member States. While national practices differ historically, a certain minimum level of harmonisation in vehicle testing and commonly agreed solutions to exchange vehicle data between Member States is more effective than multiple uncoordinated national solutions. With common rules applied to testing modern vehicle technologies (EVs, ADAS, and the most recent emission control equipment), Member States will realise economies of scale and testing equipment manufacturers can operate on a more homogenous market. The functioning of the internal market would also be improved by vehicles being subject to similar tests under similar conditions, and transport operators facing similar costs. Coordinating the conditions of access and exchange of vehicle data at the EU level will not only be more efficient than bilateral agreements and negotiations with individual manufacturers, but also level the playing field among Member States and put them, collectively, in a stronger position vis-à-vis the automotive industry.

4.Objectives: What is to be achieved?

4.1.General objectives

To address the problems identified in section  2 and in line with the overall logic of the Roadworthiness Package on the one hand, and with the Commission’s strategic priorities on the other hand (‘Vision Zero’ road safety policy framework, the European Green Deal, the Sustainable and Smart Mobility Strategy, the Zero Pollution Action Plan) and Treaty principles, the general objectives of this revision are to: (i) improve road safety in the EU; (ii) contribute to sustainable mobility; and (iii) facilitate the free movement of persons and goods in the EU. Stakeholders were consulted on these objectives as part of public as well as targeted consultations, including through the Roadworthiness Committee and the Expert Group representing Member States and industry experts, and a large majority of them agreed with the identified general and specific objectives (see Annex 2). Improving road safety in the EU and contributing to sustainable mobility are in line with UN Sustainable Development Goal (SDG) 3 (Ensure healthy lives and promote well-being for all at all ages), including targets 3.6 (halving the number of deaths and injuries from road traffic accidents) and 3.9 (by 2030, substantially reduce the number of deaths and illnesses from hazardous chemicals and air, water and soil pollution and contamination), notably through specific objectives 1 and 2 mentioned below.

4.2.Specific objectives

The specific objectives of the initiative are designed to address the problems and problem drivers described above ( Figure 4 ). As each of the specific objectives address two or three problem drivers, they complement each other to help achieve the general objectives. Both SO1 and SO3 contribute to SO2, while there are no trade-offs between them.

Figure 4: Correspondence between problem drivers and the objectives

SO1: Ensure the adequacy, consistency, objectivity, and quality of roadworthiness testing of today's and tomorrow's vehicles. This objective aims to address the challenges presented by the need to test the latest and emerging vehicle technologies in a coherent manner. More specifically, the testing of EVs and ADAS must be ensured before most of the new vehicles equipped with such systems are due for their first PTI (PD1) 115 . To correct for the inability of existing emission tests to identify high-emitting vehicles (PD2), newly developed test methods need to be incorporated in the minimum requirements. Similarly, measures need to be taken to improve the detection rate of defective or tampered, thus polluting, excessively noisy and potentially dangerous vehicles (PD3). Some of those vehicles are not tested today, or not frequently enough to detect those deficiencies (PD5). The majority of stakeholders participating in the targeted consultation (64 out of 67) agreed with this specific objective. Adapting testing to today's and tomorrow's vehicles (SO1) will also help achieve SO2.

SO2: Significantly reduce fraud and tampering, and improve the detection of defective vehicles. This objective aims to significantly reduce tampering and improve the detection of vehicles with deficiencies, to allow for the detection of defective/tampered safety and emission (i.e., air pollution and noise emission) control systems, as well as of odometer fraud, by improving the suitability of emission testing (PD2), providing for better tools to detect safety-related modifications, notably of vehicle software (PD3), and by more and targeted inspections (PD5). Most stakeholders participating in the targeted consultation (60 out of 66) agreed with this specific objective.

SO3: Improve electronic storage and exchange of relevant vehicle identification and status data. This objective aims at improving electronic storage and exchange of specific vehicle data, therefore addressing the problem of insufficient availability of such data and mutual recognition by enforcing authorities (registration, PTI, RSI) (PD4). More accurate status data (such as mileage) and efficient exchange of information among Member States will also help identify vehicles with tampered odometer (PD3). As such, SO3 also complements SO2. The majority of stakeholders participating in the targeted consultation (54 out of 61) agreed with this specific objective.

5.What are the available policy options?

5.1.What is the baseline from which options are assessed?

The EU Reference scenario 2020 is the starting point for the impact assessment of this initiative. The REF2020 takes into account the impacts of the COVID-19 pandemic that had a significant impact on the transport sector. More detailed information about the preparation process, assumptions, and results are included in the Reference scenario publication 116 . Building on REF2020, the baseline has been designed to include the initiatives of the ‘Fit for 55’ package proposed by the Commission on 14 July 2021 117 and the initiatives of the RePowerEU package proposed by the Commission on 18 May 2022 118 . The baseline scenario factors in the revision of the HDV CO2 standards Regulation 119 and the new Euro 7 standards 120 , the proposed end-of-life vehicles (ELV) Regulation 121  and the forthcoming initiative on fair and non-discriminatory access to in-vehicle data 122 , as well as other initiatives part of the Road Safety package 123 and the Greening Freight package 124 .

The baseline scenario assumes no further EU level intervention beyond the current Roadworthiness Package (i.e., the PTI and the RSI Directives as amended by the delegated Regulations to align with the evolution of type-approval legislation 125 and to introduce the testing of eCall at PTI 126 , and the VRD Directive as last amended by the revision of the Eurovignette Directive 127 ). As some of the provisions of the RWP allowed for a very long transition period 128 , certain Member States are still notifying transposition measures to the Commission. The baseline scenario assumes full transposition of the current Roadworthiness Package. In addition, the baseline reflects the introduction of PN measurement by three Member States 129 .

The baseline also incorporates foresight megatrends and developments captured in the 2022 Strategic Foresight Report 130 , as explained in section 2.3. Among others, it captures the trend of increasing demand for transport as population and living standards grow, as well as the links between the digital and green transition, and the accelerating technological change and hyperconnectivity. In particular, the projected transport activity draws on the long-term population projections from Eurostat and GDP growth from the Ageing Report 2021 131  by the Directorate General for Economic and Financial Affairs. 

In the baseline scenario, EU transport activity is projected to grow post-2020, following the recovery from the COVID-19 pandemic. Road transport would maintain its dominant role within the EU by 2050. Road passenger transport activity (expressed in passenger-kilometres) 132 is projected to grow by 10% between 2015 and 2030 (27% for 2015-2050), while road freight transport activity (expressed in tonne-kilometres) 133 by 27% during 2015-2030 (52% for 2015-2050). Rail transport activity is projected to grow significantly faster than for road, driven in particular by the completion of the TEN-T core network by 2030 and of the comprehensive network by 2050, supported by the CEF, Cohesion Fund and ERDF funding, but also by measures of the ‘Fit for 55’ package 134 and the Greening Freight package. Passenger rail activity is projected to go up by 37% by 2030 relative to 2015 (86% for 2015-2050). Freight rail traffic would increase by 50% by 2030 relative to 2015 (107% for 2015-2050).

The share of zero-emission vehicles in the light duty vehicle fleet (passenger cars and light commercial vehicles) is projected at 15% in 2030, going up to 95% in 2050 in the baseline scenario, while for heavy duty vehicle fleet (buses and coaches, and heavy goods vehicles) at 6% in 2030 and 72% in 2050. These developments are driven by the CO2 standards Regulations, supported by the Alternative Fuels Infrastructure Regulation. The current limitations of the emission testing methods applied under the PTI and RSI Directives are expected to persist in the baseline scenario, with the shares of high-emitting vehicles 135 in the Euro 5/V and Euro 6/VI fleet remaining largely the same. On the other hand, the share of high-emitting vehicles in the Euro 7 fleet is expected to be lower than for Euro 5/V and Euro 6/VI. The uptake of zero-emission vehicles, the penetration of Euro 7 vehicles in the fleet and the related introduction of on-board emissions monitoring systems 136 , combined, are expected to result in significant reductions of air pollution emissions from road transport in the baseline scenario. NOx emissions are projected to reduce by 52% in 2030 relative to 2015 (98% reduction for 2015-2050), while particulate matter (PM2.5) emissions would decrease by 43% in 2030 relative to 2015 (98% reduction for 2015-2050). CO2 emissions from road transport are projected to decrease by 32% by 2030 relative to 2015, and be close to zero by 2050, thanks to the large-scale uptake of zero-emission vehicles and some use of renewable and low-emission fuels.

In the baseline scenario, the number of fatalities is projected to decrease by 24% by 2030 relative to 2015 and by 31% by 2050 relative to 2015 137 . The number of serious and slight injuries is projected to decrease by 19% between 2015 and 2030 and by 26% for 2015-2050. This is despite the increase in traffic over time. Relative to 2019, the number of fatalities would decrease by 15% by 2030 and 23% by 2050, and the number of serious injuries by 10% by 2030 and 18% by 2050. Thus, the targets of the EU Road Safety Policy Framework 2021-2030 – Next steps towards “Vision Zero”, of reducing the number of road deaths and the number of serious injuries by 50% between 2019 and 2030, would not be met. In addition, this is still far from the goal of the Sustainable and Smart Mobility Strategy of a close to zero death toll for all modes of transport in the EU by 2050. The external costs of noise emissions are projected to increase by 7% by 2030 relative to 2015 and to remain relatively stable post-2030. The uptake of zero-emission vehicles compensates to some extent the increase in noise due to the higher traffic 138 .

In the baseline scenario, the number of periodic technical inspections (PTI) for cars, vans, buses, trucks and motorcycles is projected to increase from 151.5 million in 2015 to 168.9 million in 2030 and 192.3 million in 2050 139 . For O1 and O2 vehicles the number of inspections is projected at 7.9 million in 2030 and 8.7 million in 2050. Most of the technologies required for more advanced testing included in the policy measures are available and part of the baseline; however certain test methods need to be developed. More detailed explanations are provided in Annex 4 (section 8).  

The number of national second-hand vehicle sales with mileage fraud at EU level is projected at 1.71 million in 2030 and 1.90 million in 2050, and that of cross border vehicle sales with mileage fraud at 3.35 million in 2030 and 3.64 million in 2050. The national and cross-border odometer fraud is estimated to lead to damages for European consumers estimated at EUR 10.7 billion in 2030 and EUR 11.7 billion in 2050 140 . Expressed as present value over 2026-2050 this amounts to EUR 194.6 billion. More details on the baseline scenario are provided in Annex 4 (section 2).

5.2.Description of the policy options

As a first step, a comprehensive list of possible policy measures was established after extensive consultations with stakeholders, expert meetings, and independent research in the context of the impact assessment support study and the Commission’s own analysis. This list was subsequently screened based on the likely effectiveness, efficiency and proportionality of the proposed measures in relation to the given objectives, as well as their legal, political and technical feasibility.

Discarded policy measures and policy options

The possibility to adopt further recommendations or a communication from the Commission was discarded at early stage as non-regulatory measures could not be sufficiently effective in addressing the problems identified and would have limited effect on harmonisation. Most stakeholders, including public authorities participating in the open public consultation, agree that a legislative review of the RWP would be more effective (see Annex 2). Out of the more than 40 policy measures discussed at five meetings with the Expert Group on Roadworthiness and vehicle registration documents (RWEG), 13 measures have been discarded. A more detailed list with all discarded measures can be found in Annex 8.

Retained policy measures and policy options

A list of 26 policy measures has been retained. Table 3  presents an overview of the policy measures included in the policy options and their links with the specific objectives. A detailed description of the policy measures is provided in Annex 7. 

The policy options offer choices with focus on different aspects such as means of testing (e.g., PTI vs roadside inspections, tailpipe testing only vs its combination with remote sensing) or different levels of harmonisation in the exchange of vehicle data, the scope and methods of testing and the mutual recognition of PTI certificates.

Four policy options have been identified (PO1a, PO1b, PO2 and PO3), and each of the four policy options includes a set of policy measures that are common for all options, as well as additional measures that are included in one or more options. The common set of policy measures (from PMC1 to PMC9) are considered as the minimum necessary to correct the shortcomings of the existing RWP Directives and to adapt to technological and regulatory developments over the last ten years, and are supported by most stakeholders. Beyond the common measures, PO1a and PO1b differ in their focus, while compared to them PO2 and PO3 represent an increasing level of ambition and harmonisation. This reflects the preferences of various stakeholder groups and genuine options for more or less convergence in the areas covered by the three Directives.

Table 3: Policy measures and policy options

Adapting PTI to EVs (PMC1) and including new test items through the ePTI (PMC2, including the testing of software integrity of safety- and emission-relevant systems) will help align the PTI rules with technological and regulatory developments and hence contribute to SO1 (Ensure the adequacy, consistency, objectivity, and quality of roadworthiness testing of today's and tomorrow's vehicles). Similarly, new emission test methods for both particles and NOx (PMC3 and PMC4) are necessary to adapt to more recent emission control technologies (contributing to SO1) and to capture high emitting vehicles, including tampered ones (contributing to SO2). PMC5 will also contribute to SO2 (Significantly reduce fraud and tampering, and improve the detection of defective vehicles) by requiring that vehicles undergo a roadworthiness test following any significant modification involving e.g., the change of the propulsion system or the emission class. PMC6, PMC7 and PMC8 contribute to SO3 (Improve electronic storage and facilitating exchange of relevant vehicle identification and status data) through digitalisation of the roadworthiness certificate, linking national vehicle registers and extending the set of harmonised vehicle data in those registers. PMC9 introduces a requirement for Member States to record odometer readings in national databases and make those records available to other Member States in the case of re-registration. Garages (including car manufacturers), tyre and other repair services, in addition to PTI bodies would have to provide such readings for cars and vans following every visit. PMC9 contributes to SO2 and SO3.

Reasoning behind the packaging of options

PO1a and PO1b are designed rather conservatively as regards the scope of vehicles to be tested and are limited to the measures that are indispensable to address each of the problem drivers and to meet all specific objectives, while each of these two options has a specific focus: PO1a focuses primarily on enhancing the exchange of vehicle data and enhancing digitisation. PO1b on the other hand focuses more on improving the testing of vehicles and introducing additional and more ambitious measures regarding emission testing and recognition of PTI.

PO2 is designed to provide a more integrated approach. It builds on the measures already included in PO1a and PO1b and adds more ambition with additional measures such as the extension of roadside inspections to vans. It also improves access to relevant technical and registration data through specific measures, such as better access to vehicle data necessary for testing notably modern electronic safety systems.

PO3 builds on PO2 and takes its integrated approach, but compared to PO2 it further extends the scope of vehicles and items to be tested. It further extends the scope of PTIs to cover light trailers and motorcycles with smaller engine size, combined with mandatory roadside inspection for motorcycles. It also provides a wider recognition of PTI inspections taking place in other Member States. Overall, it represents the most ambitious option.

Policy option 1a (PO1a)

This policy option aims primarily at more efficient use of vehicle (registration and status) data, further focusing on addressing SO3. In addition to the common measures, PO1a would require adding certain new data elements to national vehicle registers, notably related to the registration and roadworthiness status of the vehicle, thus facilitating the implementation and enforcement of the RWP as well as that of the ELV legislation (PM17). Issuing registration certificates in digital format (PM16) will further enhance the efficiency of data exchange. Furthermore, PO1a would allow Member States to sign bilateral agreements to enable the cross-border recognition of PTIs and thus facilitate the free movement of people and goods (PM9). PM9, PM16 and PM17 contribute to addressing SO3.

Beyond the common measures, PO1a applies a relatively light touch approach to addressing SO2. To reduce the number of tampered and defective motorcycles due to their lack of testing, it would require those Member State which exempt these vehicles from PTI to apply as alternative measure, testing a share of them at the roadside (PM1). Most stakeholders, including Member States authorities and especially EReg/EUCARIS support this policy option, while the PTI sector (CITA and others) and motorcycle manufacturers (ACEM) would prefer stricter PTI and RSI requirements.

Policy option 1b (PO1b)

Beyond the common measures, PO1b further focuses on addressing SO2 through more effective technical inspections. The most important measure in this respect is the use of remote sensing technology 141 (PM12), which allows targeted and thus much more effective and efficient emission testing at the roadside. Remote sensing, using laser technology (LiDAR) to detect critical pollutants, has been demonstrated to be an effective method to screen very large numbers of vehicles at relatively low cost 142 . This measure will allow monitoring the emissions of virtually the entire vehicle fleet, including older vehicles, depending on the scale of its implementation. Remote sensing using microphones is able to single out unusually noisy vehicles even in dense traffic 143 . This allows the identification of potentially high-emitting vehicles that can be either inspected at a subsequent roadside check immediately after being identified or invited to a roadworthiness centre for an emission test. 

In addition, to address specific groups of vehicles that are more prone to tampering or defects than the average, PO1b introduces specific measures: it would remove the possibility to exempt motorcycles from PTI (PM2) and require yearly emission testing of light commercial vehicles (PM5). Furthermore, it would introduce mandatory annual PTIs for vehicles older than 10 years (PM6), an improved noise test for motorcycles based on type-approval requirements (PM10) and make the inspection of cargo securing mandatory (PM13). As such, all these measures go further in addressing SO2 (beyond the common measures included in all options). PO1b would further facilitate the free movement of people, and further address SO3, by requiring that the Member State of registration recognises the PTI certificate issued by another Member State for a period of up to six months, provided that the next PTI is conducted in the Member State of registration (PM8). This policy option enjoys the support of the PTI industry (CITA, FSD and others) as well as automobile manufacturers (ACEA), testing equipment (EGEA) and motorcycle manufacturers (ACEM), while certain Member States and motorcycle users find it too demanding. Stricter cargo securing requirements are strongly supported by the logistics industry (in particular by EUMOS).

Policy option 2 (PO2)

PO2 combines most of the measures of PO1a and PO1b. As regards the testing of motorcycles, PO2 includes a measure of PO1a (PM1), while for the recognition of PTIs conducted in another Member State, it uses PM8 (temporary recognition), like in PO1b. To further improve the consistency and quality of testing of modern vehicles (SO1) and the availability of relevant technical data to testing centres (SO3), it includes an additional measure on data governance (PM11), aiming to define the procedures and the means of access to vehicle technical information (including in-vehicle data). The measure would complement an existing Implementing Regulation 144 and build on the upcoming proposal on access to in-vehicle data 145 .

To further reduce the number of tampered and defective vehicles and contribute towards SO2, in addition to the measures of PO1b and PO1a, it would also introduce roadside inspections for light commercial vehicles (PM14). RSI complements PTI and is arguably better suited to detect and reduce fraud thanks to the vehicle users having no prior notice of roadside tests, in comparison to pre-planned periodical technical inspections, where pre- and post-tempering of vehicles cannot be excluded. In addition to being a combination of PO1a and PO1b, PM11 on data governance makes this policy option more favoured by the PTI industry (CITA, FSD and others) as well as FIA, testing equipment (EGEA) and motorcycle manufacturers (ACEM). It is supported also by some Member States, notably those that rely on thousands of smaller roadworthiness testing centres. On the other hand, the issue of access to vehicle data is considered less important by automobile manufacturers. Stricter cargo securing requirements included in this option are strongly supported by the logistics industry (EUMOS).

Policy option 3 (PO3)

PO3 goes further on harmonising the scope and methods of roadworthiness testing and the mutual recognition of PTI certificates. As such, it aims to further address SO2, as well as SO1 and contributes to facilitating the free movement of people and goods more comprehensively than the other options also further addresses SO3. To the measures of PO2, PO3 adds further extension of scope of PTI to cover all motorcycles without exception (PM3) and light trailers (PM4), and it extends RSI to motorcycles (PM15). All these measures further contribute to addressing SO2. PO3 is the only option to include PM7, a requirement that PTI certificates issued in any other EU Member States are recognised by the Member State of registration without limitations, further addressing SO1 and SO3. This necessitates further harmonisation of test methods where the PTI Directive currently offers various options. It would thus mean less room for manoeuvre for Member States, and fewer choices for inspection centres. This being the most ambitious option, it is mainly supported by the PTI sector, including equipment manufacturers as well as by ACEM and a few Member States that apply stricter requirements than the current RWP Directives.

6.What are the impacts of the policy options?

This section summarises the main expected economic, social and environmental impacts of each policy option (PO) 146 . The proposed measures are assumed to be implemented from 2026 onwards, so the assessment has been undertaken for the 2026-2050 period and refers to EU27. Costs and benefits are expressed as present value over the 2026-2050 period, using a 3% discount rate, in constant prices of the year 2022. Further details on the methodological approach are provided in Annex 4. The evidence underlying the assessment of impacts is based on the best available evidence, including multiple studies involving scientific research, as well as thorough consultation with experts.

6.1.Economic impacts

This section focuses on the economic impacts of the policy options on national public authorities, businesses and citizens. It also provides an assessment of impacts on competitiveness, on innovation and technological developments, on small and medium enterprises (SMEs), on the functioning of the internal market and competition, and looks at territorial impacts and digital by default. The assessment of economic impacts draws on multiple data sources, including the targeted stakeholders’ consultation (interviews and survey) and OPC, and findings from desk research in the context of the impact assessment support study. The costs and benefits of each policy measure by stakeholder group are described in detail in Annex 4 (sections 3 and 4), including the assumptions used to estimate them. In addition, the cost-benefit analysis for some key policy measures is provided in Annex 4 (section 6).

6.1.1.Impacts on national public authorities

All policy options are expected to result in adjustment and administrative costs for national public authorities, while PO1b and PO3 would also lead to additional enforcement costs. At the same time, all policy options are expected to result in significant administrative costs savings for the national authorities (see Table 4 to Table   6 ). The costs and costs savings by policy option are discussed below, while the detailed calculations by policy measure are provided in Annex 4 (section 3). 

Adjustment costs. All policy options include adjustment costs related to three common measures (PMC2, PMC3 and PMC4). They cover one-off adjustment costs (see Table   6 ) for: the acquisition of on-board diagnostic (OBD) scanning tools for RSI and the training of inspectors to use the OBD tools 147  (PMC2), estimated at EUR 0.2 million in 2026 relative to the baseline; the purchase of PN measurement devices for RIS and the training of inspectors to use them 148 (PMC3), estimated at EUR 0.7 million in 2026; and, the acquisition of NOx measurement devices for RIS and the training of inspectors 149 (PMC4), amounting to EUR 2 million. In addition, recurrent adjustment costs (i.e., maintenance and calibration costs) for the PN and NOx measurement devices are assumed at 5% of the capital costs, based on stakeholders’ feedback, and are estimated at EUR 32,750 per year from 2026 onwards in PMC3 and at EUR 98,250 per year in PMC4 (see Table 5 ). Expressed as present value over 2026-2050, the total one-off and recurrent adjustment costs are estimated at EUR 0.2 million for PMC2, EUR 1.3 million for PMC3 and EUR 3.8 million for PMC4 (see Table 4 ). Thus, the adjustment costs due to the common set of measures (PMC2, PMC3 and PMC4) are estimated at around EUR 5.2 million, of which EUR 2.9 million one-off costs. In addition to the common measures, the most significant one-off adjustment costs in PO1a are due to PM9, concerning the recognition of PTIs conducted in another Member State than that of registration based on bilateral agreements. National authorities are expected to incur expenses for establishing bilateral agreements and implementing procedures to facilitate inspections in another Member State. Assuming each Member State establishes three bilateral agreements, the total costs for 41 such agreements have been estimated at around EUR 1.4 million in 2026 (EUR 53,550 per Member State). In addition, PM1 will require that those Member States 150 that do not have a PTI requirement for motorcycles to introduce roadside inspections for motorcycles over 125cm3 as an alternative, leading to the need of purchasing additional equipment to support these inspections (one-off adjustment costs) and of maintaining it (recurrent adjustment costs). The one-off adjustment costs due to PM1 are estimated at EUR 0.1 million in 2026 and the recurrent adjustment costs at EUR 12,000 per year from 2026 onwards 151  (see Table 5 and Table   6 ). The total one-off and recurrent adjustment costs for national public authorities due to PO1a are thus estimated at EUR 7 million (see Table 4 ), expressed as present value over 2026-2050, of which EUR 4.4 million one-off costs.  

In PO1b, in addition to the costs of the common measures (PMC2, PMC3 and PMC4), the most significant additional adjustment costs for authorities arise due to the introduction of remote sensing, and the option to use plume chasing to measure NOx emissions from trucks, as well as the installation of noise cameras (PM12). PM12 involves one-off costs for the purchase of the necessary equipment, the setting up of the corresponding IT infrastructure and related training of inspectors, as well as recurrent costs for the maintenance of the equipment and data management, and labour costs for the inspectors performing the plume chasing 152 . The one-off adjustment costs due to PM12 amount to EUR 23.6 million in 2026, and the recurrent adjustment costs to EUR 9.4 million per year (see Table 5 and Table   6 ). Total adjustment costs due to this measure are thus estimated at EUR 192.9 million, expressed as present value over 2026-2050 relative to the baseline. In addition, PM13 is expected to lead to one-off adjustment costs for national public authorities for training on cargo securing in the 14 Member States 153 that currently do not require minimum training of inspectors (EUR 26,916 in 2026), and recurrent adjustment costs for the retraining of inspectors on a biennial basis (EUR 26,916 per year every second year after 2026) 154 . Total adjustment costs for PO1b are thus estimated at EUR 198.3 million (see Table 4 ), expressed as present value over the 2026-2050 period relative to the baseline, of which EUR 26.5 million one-off costs.

PO2 includes the adjustment costs related to the common measures (PMC2, PMC3, PMC4), the costs related to PM1 as in PO1a, and the costs related to PM12 and PM13 as in PO1b. To this, PO2 adds one-off costs for additional roadside equipment and training of inspectors due to the introduction of roadside inspections for light commercial vehicles (PM14) 155 , estimated at EUR 3.1 million in 2026, and recurrent costs for the maintenance of equipment, estimated at EUR 0.3 million per year 156 (see Table 5 and Table   6 ). Expressed as present value over 2026-2050, the total costs of PM14 are estimated at EUR 8.6 million. Total adjustment costs for PO2 are thus estimated at EUR 207.2 million, expressed as present value over 2026-2050 relative to the baseline, of which EUR 29.7 million one-off costs.

PO3 includes the adjustment costs related to the common measures (PMC2, PMC3, PMC4) and the costs related to PM12, PM13 and PM14 as in PO2. Moreover, it adds one-off adjustment costs for the purchase of additional mobile inspection units due to the introduction of roadside checks for motorcycles (PM15) 157 , estimated at EUR 0.4 million in 2026, and recurrent costs for the maintenance of the inspection units (EUR 40,000 per year from 2026 onwards) 158 . Expressed as present value over 2026-2050, the total costs of PM15 are estimated at EUR 1.1 million. Thus, the total adjustment costs for authorities for PO3 are estimated at EUR 208 million, expressed as present value over 2026-2050 relative to the baseline, of which EUR 30 million one-off costs.

Administrative costs. All policy options include administrative costs for public authorities related to four common measures (PMC6, PMC7, PMC8 and PMC9). The digitalisation of the roadworthiness certificate (PMC6) is expected to lead to one-off administrative costs for the development of the software for electronic certificates, estimated at EUR 17.8 million in 2026 159 , and recurrent administrative costs for the maintenance and update of the system (EUR 0.9 million per year from 2026 onwards) 160 . The interconnection of national vehicle registers (PMC7) would result in one-off administrative costs for developing the common interfaces for accessing the data, estimated at EUR 8.1 million in 2026 (EUR 300,000 per Member State), and recurrent administrative costs for providing access to the relevant data (EUR 0.4 million per year from 2026 onwards). Further harmonisation and regular update of technical data in the registration documents (PMC8) is expected to lead to one-off administrative costs for redesigning and setting up the new template for the registration documents, estimated at EUR 0.7 million in 2026 and recurrent administrative costs for the regular update of the vehicle registration documents with new items that may be found relevant in the future (EUR 0.5 million per year from 2026 onwards). The most significant administrative costs in all policy options arise from PMC9, under which authorities (except Belgium and the Netherlands that have already implemented the system) will need to develop a system for the recording of odometer readings of vehicles at garages and other repair stations. Based on the information provided by CAR-Pass 161 , the one-off cost per database that will be collecting the odometer readings at Member State level is estimated at around EUR 1 million. Furthermore, the annual cost of operating the system was estimated at around EUR 0.42 per vehicle (in 2022 prices) 162 . In total, one-off administrative costs for authorities are estimated at around EUR 25 million in 2026, and recurrent costs at EUR 111.4 million in 2030 and EUR 125.6 million in 2050 relative to the baseline 163 . Expressed as present value over 2026-2050, the total one-off and recurrent administrative costs are estimated at EUR 33.7 million for PMC6, EUR 15.4 million for PMC7, EUR 9.4 million for PMC8 and EUR 2.12 billion for PMC9 (see Table 4 ). Thus, the administrative costs due to the common set of measures (PMC6, PMC7, PMC8 and PMC9) are estimated at around EUR 2.18 billion, expressed as present value over 2026-2050, of which EUR 51.6 million one-off costs. 

In PO1a, beyond the costs of the common measures (PMC6, PMC7, PMC8 and PMC9), additional administrative costs are expected from the introduction of RSI for motorcycles not covered by PTI in six Member States (PM1), from the digitalisation of the registration certificates (PM16), and from adding new data elements to the vehicle registers (PM17). The recurrent administrative costs (i.e., labour costs for the additional inspections) due to PM1 are estimated at EUR 0.5 million in 2030 and EUR 0.6 million in 2050 relative to the baseline 164 . For PM16, the one-off costs for the adaptation of the IT system are estimated at EUR 12.8 million in 2026, while the recurrent costs for maintenance are estimated at EUR 1.3 million per year 165 . The one-off costs for harmonising the dataset in PM17 are estimated at EUR 0.5 million in 2026 and the recurrent costs for continuous data updates and broader maintenance of the dataset at EUR 0.4 million per year. Expressed as present value over 2026-2050, total administrative costs are estimated at EUR 9.1 million for PM1, EUR 35.8 million for PM16 and EUR 8.4 million for PM17. Altogether, the administrative costs for authorities under PO1a amount to EUR 2.23 billion expressed as present value over 2026-2050 relative to the baseline.

On top of the common measures, PO1b includes only one measure that generates administrative costs for authorities, namely the mandatory inspection of cargo securing (PM13). The recurrent administrative costs relate to labour costs for the additional cargo securing inspections and are estimated at EUR 0.5 million in 2030 and EUR 0.6 million in 2050 relative to the baseline 166 (EUR 9.8 million expressed as present value over 2026-2050). The total administrative costs for authorities under PO1b are thus estimated at EUR 2.19 billion, expressed as present value over 2026-2050.

PO2 includes the administrative costs related to the common measures, the costs related to PM1, PM16 and PM17 as in PO1a, and the costs related to PM13 as in PO1b. In addition, it includes administrative costs related to two other measures (PM11 and PM14). In the case of PM11 (adaptations related to data governance ensuring access to vehicle data for PTI centres), total one-off costs for the adaptation of the IT system are estimated at EUR 13 million in 2026 167 , and recurrent administrative costs at EUR 1.3 million per year 168 . This is equivalent to total one-off and recurrent costs of EUR 36.3 million, expressed as present value over 2026-2050. In addition, the roadside testing of vans (PM14) will also generate recurrent administrative costs (i.e., labour costs for the additional inspections), estimated at EUR 5.6 million in 2030 and EUR 6.7 million in 2050 169  relative to the baseline (EUR 107.5 million, expressed as present value over 2026-2050). All in all, the one-off and recurrent administrative costs for authorities under PO2 are expected to amount to EUR 2.39 billion, expressed as present value over 2026-2050.

PO3 includes the administrative costs related to the common measures and the costs related to the additional measures under PO2 (except for PM1). In addition, the introduction of RSI for motorcycles (PM15) is expected to lead to recurrent administrative costs (i.e., labour costs for the additional inspections), estimated at EUR 1 million in 2030 and EUR 1.3 million in 2050 170 (EUR 19.5 million expressed as present value over 2026-2050). Thus, the total one-off and recurrent administrative costs for authorities due to PO3 would be close to EUR 2.40 billion, expressed as present value over 2026-2050 relative to the baseline.

Enforcement costs. No enforcement costs for national authorities are expected in PO1a and PO2. In PO1b recurrent enforcement costs are due to the introduction of mandatory PTI for motorcycles above 125cm3 (PM2) that will imply some extra costs for the authorities that are responsible for monitoring the operation of the system, for evaluating the quality and impartiality of the additional tests. Recurrent enforcement costs in PO1b are estimated at EUR 1.7 million in 2030 and EUR 2.1 million in 2050 171  (see Table 5 ), or EUR 32.9 million expressed as present value over 2026-2050 relative to the baseline. Similarly, in PO3, the extended scope of PTI to all motorcycles (PM3) is expected to result in monitoring costs of EUR 2 million in 2030 and EUR 2.5 million in 2050 (EUR 38.1 million expressed as present value over 2026-2050) and the mandatory PTI for light trailers (PM4) will lead to monitoring costs of EUR 2.1 million in 2030 and EUR 2.3 million in 2050 172 (EUR 39.2 million expressed as present value over 2026-2050). Total recurrent enforcement costs for PO3 are thus estimated at EUR 77.4 million, expressed as present value over 2026-2050 (see Table 4 ).

Administrative cost savings. Recurrent cost savings for national administrations arise from the common measures PMC6 (roadworthiness certificate in electronic format) and PMC7 (the interlinking of national vehicle registers) in all policy options, as well as from PM16 (issuing digital registration certificates) included in PO1a, PO2 and PO3. The savings are expected to be significant in all options, and especially under PO1a, PO2 and PO3, reaching EUR 5.23 billion, expressed as present value over 2026-2050 (see Table 4 ). In PO1b they are estimated to be lower, at EUR 3.80 billion. The largest potential savings are expected from PMC6, due to issuing the roadworthiness certificates in electronic format only, estimated at EUR 167.3 million in 2030 and EUR 190.6 million in 2050 (EUR 3.16 billion expressed as present value over 2026-2050) 173 . Cost savings related to PMC7, due to the time saved for the re-registration of a vehicle in another Member State, are estimated at EUR 35.8 million per year from 2026 onwards (EUR 641.8 million expressed as present value over 2026-2050) 174 . In addition, PM16 will bring further recurrent administrative costs savings for national public authorities, by avoiding the costs of printing, distribution and handling of paper/plastic registration certificates, estimated at EUR 79.3 million in 2030 and EUR 86.3 million in 2050 (EUR 1.43 billion expressed as present value over 2026-2050) 175 . 

Net benefits. All policy options are expected to lead to net benefits for national public authorities. Net benefits, expressed as present value over 2026-2050 relative to the baseline, are estimated to be the highest in PO1a (EUR 2.99 billion), followed by PO2 (EUR 2.63 billion), PO3 (EUR 2.54 billion) and PO1b (EUR 1.38 billion).

Table 4: Recurrent and one-off costs, and costs savings for national public authorities in the policy options, expressed as present value over 2026-2050 relative to the baseline, in million EUR (2022 prices)

Source: Ricardo et al. (2024), Impact assessment support study

Table 5: Recurrent and one-off costs, and costs savings for national public authorities in the policy options, in 2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices)

Source: Ricardo et al. (2024), Impact assessment support study; Note: negative values for net benefits represent net costs.

Table 6: One-off costs for national public authorities in the policy options, in 2026, 2030 and 2050, relative to the baseline, in million EUR (2022 prices)