Explanatory Memorandum to COM(2025)180 - Amendment of Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers and Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union - Main contents
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dossier | COM(2025)180 - Amendment of Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers and Directive ... |
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source | COM(2025)180 ![]() |
date | 24-04-2025 |
1. CONTEXT OF THE PROPOSAL
• Reasons for and objectives of the proposal
This explanatory memorandum accompanies the proposal for the revision of two Directives:
Directive 2014/45/EU of the European Parliament and of the Council on periodic roadworthiness tests for motor vehicles and their trailers 1 ;
Directive 2014/47/EU of the European Parliament and of the Council on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union 2 .
Road transport plays a vital role in connecting businesses and consumers across the EU, facilitating trade and supporting economic growth and employment. However, it is also a source of certain problems, such as road crashes and air pollution.
Road crashes are one of the most devastating consequences of road transport, with significant costs to society. The main causes of road crashes are speeding, driving under the influence of alcohol or drugs, distracted driving, and various driver errors (such as misjudging a situation or driving while tired). Other causes include the poor state or design of infrastructure (such as slippery surfaces, inadequate markings and poor maintenance) and vehicle defects. Due to EU type-approval rules and a well-developed system of technical inspections during a vehicle’s lifetime, vehicle defects are the cause of only a small percentage of road crashes in the EU. However, this also means that avoidable crashes caused by vehicle defects still occur. The Safe System approach requires action on all these fronts, recognising that the different parts of the entire system – including users, vehicles, infrastructure and emergency response – work together as a whole 3 .
Air pollutant emissions from road transport are the principal source of nitrogen oxides (NOX), responsible for 35.5% of emissions in 2021, and account for a significant share of particulate matter (PM) emissions (8.1% of PM2.5 and 9.5% of PM10 emissions) 4 . In particular in cities, these percentages are expected to be even higher and lead to high exposure to these pollutants from road transport. It was estimated that in 2018 up to 70 000 premature deaths in the EU were attributed to road transport emissions 5 . To reduce these emissions, revised rules on ambient air quality and cleaner air for Europe were set out in Directive (EU) 2024/2881 6 . The Directive aims to put the EU on a path to achieve zero pollution for air by 2050 at the latest while aligning air quality standards more closely with the World Health Organization’s guidelines, which require tougher measures to reduce emissions at their source.
Contents
- This initiative builds on the 2014 roadworthiness package (RWP), which is composed of the following three directives.
- Article 1(1) amends Article 2 of Directive 2014/45/EU on scope
- Article 1(2) amends Article 3 of Directive 2014/45/EU on definitions
- Article 1(3) replaces Article 4 of Directive 2014/45/EU on responsibilities
- Article 1(5) amends Article 5 of Directive 2014/45/EU on the date and frequency of testing
- Article 1(6) amends Article 6 of Directive 2014/45/EU on contents and methods of testing
- Article 1(7) replaces Article 8 of Directive 2014/45/EU on roadworthiness certificates
- Article 1(8) amends Article 9 of Directive 2014/45/EU on follow-up of deficiencies
- Article 1(10) amends Article 17 of Directive 2014/45/EU on delegated acts
- Article 1(11) replaces Article 20 of Directive 2014/45/EU on reporting
- Article 1(12) inserts a new Article 20a in Directive 2014/45/EU on communication of information to the Commission
- Article 1(13) replaces Article 22 of Directive 2014/45/EU on extension of validity of roadworthiness certificates in case of crisis
- Article 2(1) replaces Article 1 of Directive 2014/47/EU on subject matter
- Article 2(2) amends Article 2 of Directive 2014/47/EU on scope
- Article 2(3) amends Article 3 of Directive 2014/47/EU on definitions
- Article 2(5) inserts a new Article 4a on remote sensing
- Article 2(6) amends Article 5 of Directive 2014/47/EC on the percentage of vehicles to be inspected
- Article 2(7) amends Article 6 of Directive 2014/47/EU on the risk rating system
- Article 2(8) amends Article 7 of Directive 2014/47/EU on responsibilities
- Article 2(9) replaces Article 9 of Directive 2014/47/EU on the selection of vehicles for initial technical roadside inspection
- Article 2(10) amends Article 10 of Directive 2014/47/EU on the contents and methods of technical roadside inspections
- Article 2(11) replaces Article 13 of Directive 2014/47/EU on the inspection of cargo securing
- Article 2(12) of Directive 2014/47/EU replaces Article 14 of Directive 2014/47/EU on the follow-up in the case of major or dangerous deficiencies
- Article 2(13) amends Article 16 of Directive 2014/47/EU on the inspection report and databases on technical roadside inspections
- Article 2(16) replaces Article 20 on communication of information to the Commission
- Article 2(17) of Directive 2014/47/EU amends Article 21 of Directive 2014/47/EU on delegated acts
This initiative builds on the 2014 roadworthiness package (RWP), which is composed of the following three directives.
·Directive 2014/45/EU on periodic roadworthiness tests requires that road transport vehicles are periodically tested to ensure compliance with a set of minimum requirements. It applies to all cars, vans, trucks, buses, heavy trailers, faster tractors, and since January 2022, larger two- and three-wheel vehicles and quadricycles.
·Directive 2014/47/EU on technical roadside inspections complements Directive 2014/45/EU by requiring Member States to carry out roadside inspections of heavy passenger and freight vehicles and their trailers.
·Directive 2014/46/EU 7 on the registration documents for vehicles provides for the electronic recording of the data of all vehicles registered in every Member State and harmonised procedures for suspending a vehicle’s registration.
The 2014 RWP complements the safety and environmental requirements that vehicles must meet to be able to circulate on EU roads, i.e. the respective EU type-approval regulations 8 for motor vehicles. These regulations also set out the market surveillance requirements for motor vehicles. However, the focus of the RWP is different. 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 9 after that and focus on the manufacturer’s responsibilities, the RWP focuses on ensuring that minimum standards are maintained by owners throughout a vehicle’s lifetime. In addition, while market surveillance requires testing a limited number of vehicles per model, periodical technical inspections (PTIs) apply to almost all registered vehicles. Therefore, the RWP complements the market surveillance legislation in ensuring road safety and vehicles’ environmental performance during their lifetime.
Along with the 2014 RWP and the adoption of other related EU legislation since, there have been improvements in vehicle technology, including active safety and intelligent driver assistance systems in new vehicles. However, despite this progress, unsafe vehicles still circulate on EU roads, contributing to crashes, either as the main cause or as a contributing factor. Some unsafe vehicles are identified at PTIs or roadside inspections (RSIs), i.e. vehicles with major or dangerous deficiencies. Others may not be detected either because PTIs or RSIs cannot detect them or because they are not subject to testing. These situations include vehicles with tampered safety features and vehicles with cargo that has been improperly secured.
Another problem is the insufficient checks on vehicle air pollutant and noise emissions. Some of the tests used in today’s PTIs are no longer sensitive enough to detect emission failures of modern vehicles, and the current testing procedures are not fit to meet the EU policy goals for air pollution and noise. The measurement of NOX emissions or particle number (PN) values for new cars is still not covered by the current RWP, and there are currently no EU rules on testing whether vehicles have tampered or defective NOX aftertreatment systems or of particulate filters. Given these shortcomings, the RWP’s contribution to reducing the number of high-emitting vehicles has become less effective.
Moreover, Directives 2014/45/EU and 2014/47/EU are not effective in helping enforce rules on EU cross-border traffic and the trade in vehicles.
Although these Directives were slightly amended through delegated acts 10 to align them with updated vehicle categories in type-approval legislation 11 and to introduce testing eCall 12 in PTIs, the main rules have remained the same since 2014. The Sustainable and Smart Mobility Strategy 13 called for adjustments to the roadworthiness legislative framework to ensure a vehicle’s lifetime compliance with emission and safety standards, thereby contributing to the EU road safety policy framework 2021-2030 14 and supporting the European Green Deal’s objectives.
This initiative aims to further improve road safety in the EU, contributing to sustainable mobility and facilitating the free movement of people and goods in the EU. The objectives to unlock the full potential of the RWP, in particular Directives 2014/45/EU and 2014/47/EU, are described below.
Ensure the consistency, objectivity and quality of roadworthiness testing of today and tomorrow’s vehicles. In particular, testing electric vehicles (EVs) and electronic safety, including advanced driver assistance systems (ADAS), must be ensured before most new vehicles equipped with such systems are due for their first PTI. To tackle existing emission tests’ inability to identify high-emitting vehicles, newly developed test methods need to be incorporated into PTIs and RSIs.
Significantly reduce tampering and improve the detection of defective vehicles with faulty or tampered safety and emission control systems, as well as tampered odometers. This can be achieved by: (i) improving emission testing (air pollution and noise); (ii) providing better tools to detect modifications to safety features, especially vehicle software; and (iii) making inspections more frequent and more targeted. Today, some defective vehicles are not tested often enough or at all, which allows such deficiencies to go undetected.
Improve electronic storage and the exchange of relevant vehicle identification and status data to address the problem of insufficient data availability and facilitate mutual recognition by enforcement authorities. More accurate status data (such as mileage) and an efficient and effective exchange of information among Member States will also help identify vehicles with tampered odometers.
• Consistency with existing policy provisions in the policy area
The proposed revision of the RWP, in particular Directives 2014/45/EU and 2014/47/EU, is consistent with the objectives set in the EU road safety policy framework 15 and will contribute to achieving the objective of reducing fatalities and serious injuries by 50% by 2030. The proposed revision will also ensure alignment with the 2023 road safety package, i.e. the proposals to amend the Directive on driving licences and the Directive on facilitating cross-border exchange of information on road-safety-related traffic offences 16 . This proposal sets out the rules on vehicle registration documents, the possible future digitalisation of documents, and the exchange of vehicle-related information among Member States for enforcement.
The revision is also consistent with the EU’s clean air policy objectives, including those of the Ambient Air Quality Directives 17 and the National Emission Reduction Commitments Directive 18 , which require Member States to take measures to reduce air pollutants in the atmosphere in line with the Zero Pollution Action Plan goals 19 .
To a large extent, roadworthiness testing relies on the Type-Approval Regulations 20 . The proposal is aligned with the safety and environmental requirements set out in those rules, and it includes measures that aim to ensure that minimum standards are maintained by owners throughout the lifetime of the vehicle. It is consistent with the General Safety Regulation 21 and its predecessors, as well as with the Euro emission standards, and will ensure that any new equipment introduced that complies with these regulations will work as expected and, as a result, deliver the expected benefits. The proposal ensures alignment between PTI and RSI testing and the type-approval process, including the use of electronic technical inspections (ePTIs). The use of remote sensing in RSIs of all vehicles is particularly relevant for market surveillance as it allows for screening a large part of the vehicle fleet. This gives valuable insights into recurrent issues with specific technologies/solutions used as part of emission control systems, vehicle models, model years etc. There are also expected synergies with the new Euro 7 Regulation 22 , including the use of on-board monitoring features to help assess NOX emissions during PTIs and RSIs.
• Consistency with other Union policies
The revision of the RWP, in particular Directives 2014/45/EU and 2014/47/EU, is consistent with the Single Digital Gateway Regulation 23 by facilitating online access to vehicle-related information, the relevant administrative procedures, and assistance and problem-solving services. It also contributes to the objectives of the EU’s data strategy 24 for the development of European data spaces for public administrations that can support the enforcement of legislation, including road safety and environmental legislation. Rules on the protection of personal data also apply to exchanging information on vehicle registration certificates and roadworthiness certificates, as well as related vehicle registration data, in particular Regulation (EU) 2016/679 (General Data Protection Regulation) 25 .
The Commission is also currently working on an initiative for fair and non-discriminatory access to in-vehicle data, which is crucial for technical inspection centres to be able to carry out their daily tasks. That initiative will complement the Data Act 26 with guidance, possibly followed by a legislative proposal, on access to vehicle data, functions and resources 27 , which are essential for providing 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 28 . The revision of Directive 2014/45/EU (and its implementing act on the technical information necessary for roadworthiness testing 29 ) will set out specific provisions facilitating access to the data required for technical inspections.
Lastly, the EU Decision on the Digital Decade Policy Programme 2030 30 sets out that the European Parliament, the Council, the Commission and Member States should cooperate to achieve digital targets in the EU by 2030. This includes a target for the digitalisation of public services: 100% of key public services should be available online and, where relevant, people and businesses in the EU should be able to interact with public administrations online.
2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY
• Legal basis
The legal basis of the proposal is Article 91(1) of the Treaty on the Functioning of the EU (TFEU) 31 . Article 91(1)(c) TFEU sets out that the EU has competence in the field of transport to lay down measures to improve transport safety, including road safety.
• Subsidiarity (for non-exclusive competence)
The EU already has competence in the field of roadworthiness, by virtue of current Directives 2014/45/EU and 2014/47/EU. Various measures have been introduced at EU level since 1977, when Directive 77/143/EEC 32 introduced the requirement for motor vehicles to undergo periodic roadworthiness tests. The latest change in this area was brought about by the adoption of the RWP in 2014. The new rules to be introduced in this proposal remain within the competences conferred upon the EU under Article 91(1) TFEU, and given their connection to the already existing framework of roadworthiness, they can only be achieved adequately at EU level.
As road transport and the automotive industry are international sectors, it is much more efficient and effective to address the issues at EU level than at national level. While national practices differ historically, a 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 enjoy economies of scale and manufacturers of testing equipment will be able to operate in a more uniform market. The functioning of the single market will also be improved because vehicles will be subject to similar tests under similar conditions, and transport operators will have similar costs and will have to meet similar minimum requirements.
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 level action, Member States would continue to carry out periodic and roadside inspections. However, it is very unlikely that test methods and the scope of inspections required by EU legislation (e.g. testing brakes, suspension, electronic safety systems and emissions reduction equipment) would be applied in a harmonised or coordinated manner. Member States would apply different piecemeal solutions, which would lead to even larger differences in vehicles’ safety and environmental performance than today. This would risk distorting the single market and creating further barriers to free movement. The initiative therefore addresses safety and environmental protection needs of ‘Union relevance’.
• Proportionality
In line with the principle of proportionality set out in Article 5 i of the Treaty on European Union, the measures in this proposal do not go beyond what is necessary to achieve the objectives of the Treaties – improving road safety, contributing to sustainable mobility and facilitating the free movement of people and goods in the EU.
In general, the scope of the proposal is limited to what can best be achieved at EU level to harmonise testing methods and scope. For example, vehicles that are mostly used locally, such as mopeds and tractors are not targeted by the proposal.
As for the choice of instrument for EU action, revising the existing Directives 2014/45/EU and 2014/47/EU is considered to be the most appropriate solution. This allows for achieving the objectives of gradual harmonisation in this area, while leaving sufficient room for manoeuvre for Member States to implement the changes in a way that suits their specific national context by continuing to apply well-established national arrangements in roadworthiness testing. This choice, using minimum requirements instead of a one-size-fits-all approach, will also enable industry to develop the most efficient technical solutions that this continuously evolving field requires.
• Choice of the instrument
To ensure clear and consistent legal drafting, the most suitable legal solution is a revision of Directive 2014/45/EU and Directive 2014/47/EU, amending both in one proposal for a Directive.
3. RESULTS OF EX POST EVALUATIONS, STAKEHOLDER CONSULTATIONS AND IMPACT ASSESSMENTS
• Ex post evaluations/fitness checks of existing legislation
In 2023, the Commission conducted an evaluation of the 2014 RWP, assessing its relevance, EU added value, coherence, effectiveness and efficiency. The evaluation concluded that the RWP was partially successful in achieving its objectives, contributing to better road safety and helping reduce air pollutant emissions from road transport. However, defective vehicles may still not always be detected as some categories of vehicles are not subject to PTIs or RSIs in some Member States or the frequency or scope of the testing is not adapted to those categories’ higher safety and environmental risks. The identified weaknesses in the current RWP, in particular Directives 2014/45/EU and 2014/47/EU, require the Directives to be adapted to address not only current needs but also future challenges.
The conclusions of the evaluation are described below.
The RWP is not adapted to the latest technologies, such as advanced driver assistance systems and electronic safety features. It lacks specific testing protocols that would ensure the compliance and maintenance of electric and hybrid vehicles, including software updates. Technical inspections would have to be updated for acquiring important safety-related data efficiently and monitoring new sensors and features.
On emissions, some PTI tests and equipment must be adapted as they are no longer capable of detecting emission failures in the most recent internal combustion engine vehicles. Opacity measurement is outdated as it cannot detect diesel vehicles with defective particle filters or a tampered catalyst, which lead to high particle and NOX emissions. Instead, PN and NOX measurement should be used to check newer diesel and petrol vehicles for defects and tampering with emission control systems.
The current framework for exchanging information on test results between Member States has not been effective. Although the legislation mentions electronic data exchanges between Member States authorities as a possibility, not all of them implement it. Even if the harmonisation of vehicle registration documents made it easier for people to register vehicles from other Member States and the EEA, there is room to improve the data exchange and digitalisation process. Re-registration can still be a cumbersome process, and there is scope to improve the mutual recognition of PTIs between Member States.
The RWP should make better use of the benefits of digital data exchange and harmonise vehicle documents more to reduce the administrative burden and costs. In addition, digital vehicle registration documents could further facilitate digitalising vehicle registration and data-keeping processes and help reduce costs.
The consistency between the RWP, in particular Directives 2014/45/EU and 2014/47/EU, and relevant EU instruments could be improved by standardising safety-relevant vehicle data and the related responsibilities of manufacturers during the vehicle’s lifecycle. Clarifying responsibilities and mandating that certain information is made available for PTIs across Member States could reduce uncertainty and the time spent searching for information, which could improve the overall accuracy and efficiency of inspections. The RWP, in particular Directives 2014/45/EU and 2014/47/EU, should be also better aligned with the General Safety and Euro 7 Regulations.
• Stakeholder consultations
The consultations had two objectives. The first was to assess the performance of the RWP against the five evaluation criteria, identify possible issues with the existing legal framework and, on this basis, draw conclusions for future action. The second objective was to work with stakeholders to validate the Commission’s understanding of the issues at hand, draw up a list of possible policy measures and assess their likely impact on the various categories of stakeholders.
The consultations also gathered evidence on the expected costs and benefits of the policy measures under consideration. They helped to identify gaps in the intervention logic or areas requiring further attention. The consultation activities consisted of public consultations (via an inception impact assessment and an open public consultation published on the Commission’s Have your say website) and targeted consultations, including surveys and interviews. The targeted consultation activities were carried out throughout the evaluation and impact assessment process and covered all relevant aspects. The focus of the survey and interviews were on drawing up the different policy measures to meet the objectives set as part of the RWP’s revision, particularly to identify and quantify the costs and potential impact of these measures. The problem drivers and the possible policy measures of the RWP were also extensively discussed with stakeholders, e.g. in the Roadworthiness Expert Group, and are also a result of the evaluation’s stakeholder consultation activities.
A broad range of stakeholders was consulted, including: (i) public authorities in charge of road safety (including their representative associations, such as EReg 33 and CORTE 34 ); (ii) industry associations and companies (including their representative associations, such as CITA 35 and EGEA 36 , vehicle manufacturers and vehicle component suppliers); (iii) user group representatives; (iv) research organisations and road safety NGOs; and (v) the public.
• Collection and use of expertise
A wide range of experts from Member States, industry and other stakeholder groups was consulted during the preparatory work on the issues related to roadworthiness testing, roadside inspection and vehicle registers. Three dedicated workshops took place where the members of the Expert Group on Roadworthiness and Vehicle Registration Documents (RWEG) discussed the technical elements of the proposal. The Commission contracted two external consultants to carry out specific support studies underpinning the evaluation and the impact assessment. This input was complemented by ad hoc consultations of industry experts and the Commission’s own experience in monitoring and implementing the Directives.
• Impact assessment
This proposal is accompanied by an impact assessment report, a draft of which was submitted to the Regulatory Scrutiny Board (RSB) on 20 November 2023. The RSB issued a positive opinion with reservations on 15 December 2023 37 . The impact assessment report was adjusted accordingly to address the RSB’s comments. The analysed policy options are summarised below.
Four policy options (PO1a, PO1b, PO2, PO3) were designed to address the identified problems. All policy options include the following measures:
–adapt PTIs to electric vehicles and include new test items through ePTIs (including testing software integrity of safety- and emission-relevant systems);
–new emission test methods for particles and NOX, which are necessary to adapt to more recent emission control technologies and to identify high-emitting vehicles, including those that have been tampered with;
–require a roadworthiness test following any significant change to, for example, the propulsion system or the emission class;
–digitalising the roadworthiness certificate;
–linking national vehicle registers and extending the set of harmonised vehicle data in those registers;
–require Member States to record odometer readings in national databases and make those records available to other Member States when a vehicle is re-registered.
In addition to the common measures, policy option PO1a focuses on a more efficient use of vehicle (registration and status) data, including issuing registration certificates in digital format. Policy option PO1b focuses on more effective technical inspections using remote sensing technology, which helps to identify potentially high-emitting vehicles that can be either: (i) inspected at a subsequent roadside check immediately after being identified; or (ii) invited to a roadworthiness centre for an emission test. This option would also: (i) remove the possibility to exempt motorcycles from PTIs; (ii) require yearly emission testing of light commercial vehicles; (iii) make the inspection of cargo securing mandatory; and (iv) bring in mandatory annual PTIs for vehicles older than 10 years. PO1b would facilitate the free movement of people by requiring that the Member State registering a vehicle 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.
Policy option PO2 combines most of the measures proposed in PO1a and PO1b. It includes an additional measure on data governance, aiming to set out the procedures and the means of access to vehicle technical information (including in-vehicle data). PO2 also introduces roadside inspections for light commercial vehicles.
Policy option PO3 is the most ambitious policy option as it goes even further on harmonising the scope and methods of roadworthiness testing and the mutual recognition of PTI certificates. In addition to PO2’s measures, PO3: (i) extends the scope of PTI to cover all motorcycles, without exception, and light trailers; (ii) extends RSI to all motorcycles; and (iii) requires that PTI certificates issued in any other Member State are recognised by the Member State of registration without restrictions.
The impact assessment concludes that the preferred option is policy option PO2. This option is considered to be effective in reaching the intended policy objectives, presenting high efficiency and high net benefits and being proportionate to the initiative’s objectives. It is also coherent with the well-established national policies in the field.
The policy options are expected to improve road safety in the EU by more effectively identifying vehicles with major and dangerous defects, which should lead to a reduction in road crashes caused by technical defects. As a result, the number of fatalities and injuries (both serious and light) should decrease. The policy options also include other measures contributing to road safety, which relate to better implementation and enforcement of the roadworthiness legislation (such as the exchange of data among Member States’ authorities).
Under the preferred policy option PO2, it is estimated that around 7 000 lives will be saved and around 65 000 serious injuries will be avoided between 2026 and 2050, compared with the baseline scenario. In monetary terms, the reduction in the external costs of accidents is estimated at around EUR 74.2 billion, expressed as present value over the same period, compared with the baseline.
All policy options will also contribute to sustainable mobility by reducing air pollutant and noise emissions. This will lead to a reduction in the external costs of these emissions: the savings in PO2 are estimated to be EUR 83.4 billion.
All policy options will facilitate the free movement of people and goods in the EU by removing obstacles to re-registering vehicles in another Member State. PO1a, PO2 and PO3 are expected to be similarly effective, while PO1b is expected to be less effective due to the absence of measures on digital vehicle registration certificates and additional data included in the vehicle register.
On removing obstacles related to roadworthiness testing, PO3 is expected to be the most effective option because it extends EU-wide recognition, by the Member State of registration, of PTI certificates issued in another Member State to all vehicles, followed by PO2 and PO1b (limited EU-wide recognition of PTI certificates). PO1a is expected to be the least effective, relying on bilateral agreements for the recognition of PTI certificates.
The safety of vehicles is a core element of the Safe System approach and a core principle of the 2020 United Nations Stockholm Declaration on road safety 38 . The initiative also contributes to UN Sustainable Development Goal 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). It is also consistent with the environmental objectives of the European Green Deal and the European Climate Law 39 .
• Regulatory fitness and simplification
As part of the regulatory fitness programme (REFIT) 40 , this proposal contributes to increasing the efficiency of the existing legislation in various ways by: (i) replacing obsolete test methods with state-of-the-art solutions both at periodic checks and at roadside checks by requiring the use of the most recent measurement techniques and technology to more effectively detect a large number of high-emitting vehicles; (ii) introducing simple yet meaningful tests to assess the safety and environmental performance of modern vehicles in a harmonised way; and (iii) interconnecting national databases to help share and access vehicle data, rather than relying on more cumbersome procedures. The initiative is expected to significantly reduce fraud related to emission and safety-relevant systems, as well as mileage tampering in used vehicles, especially in cross-border sales. This would lead to significant savings in external costs as well as in avoided cost and damage to consumers.
The initiative encompasses the ‘digital by default’ principle 41 , promoting digital transformation where possible. For example, the mandatory electronic format of roadworthiness certificates should have a positive impact on digital transformation in the EU. For the re-registration process, authorities and the public will save time and money by moving away from exchanging information and data via email. Authorities and the public will also save time and money thanks to the digital registration certificate, which will make accessing and exchanging the relevant information easier and faster.
Applying the ‘one in, one out’ approach
The ‘one in, one out’ approach offsets any new burden for people and businesses resulting from the Commission proposals by removing an equivalent existing burden in the same policy area. This proposal is part of the RWP package, which is expected to result in administrative costs for PTI centres and vehicle manufacturers due to the data governance measure, while garages, motor vehicle dealers, tyre service and repair stations will face costs related to the odometer readings measure. Overall, the additional one-off administrative costs relative to the baseline relevant for the ‘one in one out approach’ in the preferred option are estimated at EUR 218 million in 2026. Expressed as annualised net present value over the relevant period they amount to EUR 25.5 million. In addition, the recurrent administrative costs relative to the baseline amount to EUR 26.4 million per year. Thus, the total additional administrative costs (one-off and recurrent) relevant for the ‘one in one out approach’ are estimated at EUR 51.9 million per year relative to the baseline.
• Fundamental rights
The proposal maintains full respect for human and fundamental rights, and it will have no negative impact on the fundamental rights set out in the Charter of Fundamental Rights of the European Union 42 (the Charter).
The proposal contains measures to help reduce the level of air pollutant emissions from vehicles (annual emission testing for light commercial vehicles, yearly testing of vehicles that are 10 years old or older and NOX measurement in RSI by remote sensing and plume chasing). These measures will help to improve the quality of the environment, in line with Article 37 of the Charter. Adapting PTI methods to test electric vehicles, including training inspectors, and making inspections of cargo securing in RSI mandatory will provide a safer work environment for vehicle inspectors and for professional drivers (Article 31). Measures designed to combat odometer fraud will help increase consumer protection in line with Article 38 of the Charter. Providing for the mutual recognition of roadworthiness certificates and digitalising the registration process will contribute to the freedom of movement and residence, in line with Article 45 of the Charter. Measures to ensure that owners of non-tampered vehicles are not disadvantaged compared with those of tampered vehicles will help promote equality before the law in line with Article 3 of the Charter.
The proposal includes a measure on odometer readings, which has as impact on the right to protection of personal data when data is stored and exchanged. It requires Member States to record odometer readings in a national database and make the records available to other Member States in the case of re-registration. Furthermore, it establishes a requirement for roadworthiness certificate to be issued in electronic format, with a paper printout as an option. From a road safety perspective, the automatic accessibility of certificates through a shared system holds significant advantages, particularly in facilitating cross-border inspections and enhancing consumer convenience. The data processing related to these measures was assessed as necessary and proportionate, and it can be used only for specific purposes specified in the proposal.
4. BUDGETARY IMPLICATIONS
The implications for the EU budget are mainly related to extending the features of the IT data exchange system (the MOVE-HUB). This includes one-off adaptation costs and recurrent updates and maintenance costs. These are required to add new data elements to the vehicle registers, providing electronic access to relevant data (including on PTI reports stored in national databases) and enabling the exchange of odometer readings from Member States’ databases. The associated costs are estimated at EUR 0.2 million in one-off costs and EUR 0.05 million per year in recurrent costs, covering the overall implementation of the RWP
5. OTHER ELEMENTS
• Implementation plans and monitoring, evaluation and reporting arrangements
The Commission will monitor the implementation and effectiveness of this initiative through several actions and a set of core indicators that will measure progress towards achieving the operational objectives. To measure the success of the initiative, the following operational objectives are set: (i) apply newly available safety and emission testing methods; (ii) interconnect Member States’ vehicle registers and odometer databases through a common hub; (iii) digitalise vehicle documents; and (iv) reduce the number of defective and tampered vehicles on EU roads. The data for assessing these operational objectives will draw on regular reporting by Member States as well as ad hoc data collection efforts, including the use of data exchange systems, such as the MOVE-HUB.
Five years after the revised legislation enters into application, the Commission will carry out an evaluation to assess to what extent the objectives of the initiative have been reached.
• Explanatory documents (for directives)
Member States have implemented Directives 2014/45/EU and 2014/47/EU in different ways, and a significant number of amendments are being proposed. As a result, Member States’ notifications of their transposition measures must be accompanied by one or more documents explaining the relationship between the parts of both directives and the corresponding parts of the national laws.
• Detailed explanation of the specific provisions of the proposal
The proposal for revising Directives 2014/45/EU and 2014/47/EU is structured around the three main policy objectives set out in Chapter 1. These objectives are interrelated and aim to improve road safety in the EU, contribute to sustainable mobility and facilitate the free movement of people and goods in the EU. The main provisions that substantially change the Directives or add new elements are described below.
To improve its coherence, the article is amended to include electrically powered motorcycles in the scope next to those equipped with internal combustion engines, which are already in scope. For the same reason, the option to exclude motorcycles from the scope of roadworthiness testing is removed.
The definitions of ‘connected vehicle’ and ‘temporary roadworthiness certificate’ are added to specify the terms used in connection with the provisions on recording odometer readings (new Article 4a of Directive 2014/45) and on recognising roadworthiness certificates (amended Article 4), respectively.
To facilitate the free movement of people and goods, the existing requirement that roadworthiness tests must be carried out by the Member State registering the vehicle is complemented with the following provisions.
The article is amended to introduce the possibility for the owners or holders of passenger cars to take periodic roadworthiness tests in a Member State other than the Member State of registration. The temporary roadworthiness certificate issued in this case will be valid for six months. The subsequent PTI must take place in the Member State of registration, unless that Member State unilaterally recognises roadworthiness certificates issued by other Member States. This option is available to Member States for any vehicle category.
The article also specifies that vehicle manufacturers must make the technical information necessary for roadworthiness testing available to Member States’ competent authorities free of charge. These authorities must then make the data available to their testing centres. In addition, the Commission is empowered to specify the technical information, data format and access procedures through implementing acts.
Article 1 i inserts a new Article 4a in Directive 2014/45/EU on recording odometer readings
The article extends the obligation to record odometer readings beyond PTI centres to any service provider that carries out repairs or maintenance work on a vehicle for payment. The recorded readings may be stored in a dedicated national database or in the national vehicle register.
Vehicle manufacturers must also send regular odometer readings from their connected vehicles. The article also requires Member States to share odometer history with inspectors, the holder of the registration certificate and competent the authorities in the Member States.
Point (a) of Article 5(1) is amended to require annual testing of cars and vans that are more than 10 years old. It also requires vans to be subject to exhaust emissions tests every year following their date of first registration. This point also specifies how the date of the subsequent PTI is to be calculated following the expiry of a temporary roadworthiness certificate referred to in Article 4 of Directive 2014/45/EU.
Article 5(2) of Directive 2014/45/EU is amended to align with the change made in Article 2 on including electrically powered motorcycles in the scope of PTIs.
Finally, the conditions under which Member States or the competent authorities may require a vehicle to undergo a roadworthiness test before the expiry date of its roadworthiness certificate are simplified. While four of the existing five possibilities listed in paragraph 4 of Article 5 of Directive 2014/45/EU are removed, the one concerning significant modifications to the safety and environmental systems of the vehicle, which require a test, becomes part of a new paragraph 2a.
The article is amended to accommodate the extension of scope to electrically powered motorcycles and to allow Member States to exempt only those vehicles from exhaust emissions or noise testing that successfully passed a corresponding technical RSI during the six months before the PTI.
While the existing rules (paragraph 2 of Article 8) already allow the use of ‘electronically produced’ roadworthiness certificates, that article is amended so that the digital version becomes the default solution. The person presenting the vehicle will be able to request a certified printout. These certificates, including temporary ones, will have to be recognised by all Member States.
Paragraphs 2 and 3 of Article 9 are amended to provide for the necessary exchange of information, including when a registration is suspended, between the Member State of registration and the Member States where the vehicle has undergone a roadworthiness test.
Paragraph 4 is added to provide for effective penalties for obvious tampering with a vehicle’s components, including emission control and safety systems.
Article 1(9) replaces Article 16 of Directive 2014/45/EU with a new Article 16 on the exchange of data between Member States’ authorities
The new Article 16 introduces an obligation on Member States to connect their national vehicle registers and roadworthiness databases with the MOVE-HUB platform developed by the Commission, for relevant data to be exchanged during periodic roadworthiness testing. The exchange of information includes vehicle registration data, data on the content of the certificate of conformity, the last roadworthiness certificate and of any roadside inspection report.
Under paragraph 2 of the new Article 16, the Commission will have to lay down detailed rules on the arrangements, data formats and message content to implement the data exchange within two years after the entry into force of this amending directive. The data exchange will have to be operational within one year after that.
Article 17 is amended to include the delegation of power to the Commission to specify the methods for the new emission tests (introduced for vehicle categories M and N equipped with internal combustion engines) in Section 8.2 of Annex I.
Article 20 is amended to reflect the most significant changes to the rules on which the Commission will have to report.
Article 1(12) inserts a new Article 20a in Directive 2014/45/EU on communication of information to the Commission
Article 20a is introduced to feed into the Commission’s report on the implementation of Directive 2014/45/EU. While Member States already report on technical roadside inspections carried out in their territories every two years, similar information has not been systematically available to the Commission on PTIs. This Article aims to fill this gap by requiring Member States to communicate a minimum set of information related to PTIs every three years. The reporting format will be laid down in an implementing act to be adopted by the Commission.
Article 1(13) replaces Article 22 of Directive 2014/45/EU on extension of validity of roadworthiness certificates in case of crisis
This new Article 22 is introduced to provide for the possibility to extend the validity of roadworthiness certificates where a crisis, such as a pandemic, would prevent carrying out PTIs in a timely manner.
The article is updated to include remote sensing of vehicle emissions.
In paragraph 1 of Article 2 of Directive 2014/47/EU, vans are added to the scope (point (aa)). Furthermore, a second subparagraph is added to specify that the provisions on remote sensing also apply to cars and motorcycles. Paragraph 2 is adjusted to reflect the changes in paragraph 1.
The most significant changes are the addition of definitions for ‘remote sensing’ and ‘plume chasing’
Article 2 i replaces Article 4 of Directive 2014/47/EU on roadside inspection systems
The article is updated to include a reference to remote sensing.
This new article is added to require Member States to make use of remote sensing technology to screen the noise and exhaust emissions of large parts of their vehicle fleet to identify potentially high-emitting vehicles (of any vehicle category). Paragraph 3 requires that Member States check the emissions of those vehicles either at a roadside check or by inviting the owner or holder of the vehicle to a PTI centre. Paragraph 4 provides for the methods to check the emissions of vehicles registered in a Member State other than the one where the remote sensing measurement took place.
Article 2(6) amends Article 5 of Directive 2014/47/EC on the percentage of vehicles to be inspected
The article is updated to link the existing 5% target (of the total number of heavy commercial vehicles) to each Member State instead of it being an EU-wide target.
In addition, a 2% target is proposed for RSIs of light commercial vehicles, i.e. vans of category N1.
The only change to Article 6 is the addition of a reference to vans (definition (aa) in Article 2(1)).
Paragraph 1 of Article 7 is updated to require the recognition of electronic evidence, such as the most recent PTI certificate.
Article 2(9) replaces Article 9 of Directive 2014/47/EU on the selection of vehicles for initial technical roadside inspection
The article is updated to include remote sensing as a possible basis for the selection of a vehicle for RSI.
Article 2(10) amends Article 10 of Directive 2014/47/EU on the contents and methods of technical roadside inspections
Points (a) and (c) are amended to align them with the amendments related to roadworthiness certificates and cargo securing requirements.
Article 13 is amended to make cargo securing checks (in line with Annex III) mandatory for Member States rather than optional.
Article 2(12) of Directive 2014/47/EU replaces Article 14 of Directive 2014/47/EU on the follow-up in the case of major or dangerous deficiencies
A fourth paragraph is added to Article 14 to provide for effective penalties for obvious tampering with a vehicle’s components, including emission control and safety systems.
Article 2(13) amends Article 16 of Directive 2014/47/EU on the inspection report and databases on technical roadside inspections
Paragraph 2 of Article 16 is amended to provide an electronic version of the report by default.
Article 2(14) of Directive 2014/47/EU amends Article 18 of Directive 2014/47/EU on cooperation between Member States.
Article 18 is updated to refer to the implementing rules already adopted by the Commission on notifying major and dangerous deficiencies found in roadside checks of vehicles registered in another Member State.
Article 2(15) inserts a new Article 18a in Directive 2014/47/EU on the exchange of data between Member States’ authorities
Like the new Article 16 of Directive 2014/45/EU, this new Article 18a introduces an obligation on Member States to connect their national vehicle registers and roadworthiness databases with the MOVE-HUB platform developed by the Commission, for relevant data to be exchanged during roadside inspections. The exchange of information includes vehicle registration data, data on the content of the certificate of conformity, the last roadworthiness certificate and of any roadside inspection report.
Under paragraph 2 of the new Article 18a, the Commission will have to lay down detailed rules on the arrangements, data formats and message content to implement the data exchange within two years after the entry into force of this amending directive. The data exchange will have to be operational within one year after that.
Article 20 is updated to streamline and simplify reporting requirements in the following ways: (i) less detailed reports will be required (see changes to Annex V to Directive 2014/47/EU); (ii) these reports will be required every three years instead of every two years; and (iii) Member States will use a common reporting platform rather than sending emails with Excel files attached.
Article 2(17) of Directive 2014/47/EU amends Article 21 of Directive 2014/47/EU on delegated acts
The fourth and fifth indents are added to empower the Commission to: (i) adopt delegated acts to set common limit values for remote sensing measurement; and (ii) specify the test methods for measuring particle number and nitrogen oxides at roadside checks.
Article 2(18) replaces Article 24 of Directive 2014/47/EC on reporting.
The article is updated to reflect the most significant changes to the rules on which the Commission will have to report.
Annex I amends the following annexes to Directive 2014/45/EU.
·Annex I – MINIMUM REQUIREMENTS CONCERNING THE CONTENTS AND RECOMMENDED METHODS OF TESTING
The annex is amended to include: (i) new test items relevant for battery electric and hybrid vehicles (Section 4.14 on high-voltage systems); (ii) new emission tests to measure ultrafine particle and nitrogen oxide emissions from petrol and diesel vehicles (Section 8.2); and (iii) a new Section 10 on testing electronic safety systems using the vehicle’s electronic interface. In addition, a number of small changes are made to other items to reflect the views of the experts in this area.
·Annex III – MINIMUM REQUIREMENTS CONCERNING ROADWORTHINESS FACILITIES AND TEST EQUIPMENT
Points 16 and 17 are added to require testing centres to be equipped with the devices needed to measure particle numbers and nitrogen oxides at PTIs.
·Annex IV – MINIMUM REQUIREMENTS CONCERNING THE COMPETENCE, TRAINING AND CERTIFICATION OF INSPECTORS
The annex is updated to require training for inspectors so they can test alternative propulsion systems (including high-voltage, hybrid and hydrogen systems).
Annex II amends the following annexes of Directive 2014/47/EU.
·Annex II – SCOPE OF TECHNICAL ROADSIDE INSPECTIONS
Similar to Annex I to Directive 2014/45/EU, this annex is amended to include new test items for: (i) battery electric and hybrid vehicles (Section 4.14 on high-voltage systems); (ii) new emission tests to measure ultrafine particle and nitrogen oxide emissions from petrol and diesel vehicles (Section 8.2); and (iii) a new Section 10 on testing electronic safety systems using the vehicle’s electronic interface. In addition, a number of small changes are made to other items to reflect the views of the experts in this area.
·Annex III – CARGO SECURING
The first sentence in Chapter II. Section 3 is amended to make the rules inspecting the specific items of cargo securing listed in Table 1 compulsory.
·Annex IV – MORE DETAILED TECHNICAL ROADSIDE INSPECTION REPORT INCORPORATING A CHECKLIST
Point 6 of the specimen is updated to include N1 (vans) among the vehicle categories. Point 10 is updated to include the new test items on high-voltage systems (4.14), emission testing (revised item 8.2) and electronic safety systems (new item 10).
·Annex V – STANDARD FORM FOR REPORTING TO THE COMMISSION
The form is updated by adding the required columns for N1 vehicles, correcting the list of countries of registration, and simplifying the reporting requirement by removing the ‘defect details’ part.