kom (2025) 0180 - Ingen titel

Europaudvalget 2025
KOM (2025) 0180
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EUROPEAN COMMISSION

Brussels, 15.12.2023

SEC(2025) 119 final

REGULATORY SCRUTINY BOARD OPINION

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

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 Directive 2014/47/EU on the technical roadside inspection

of the roadworthiness of commercial vehicles circulating in the Union

{SWD(2025) 96 final}

{SWD(2025) 97 final}

{SWD(2025) 98 final}

{SWD(2025) 99 final}

kom (2025) 0180 - Ingen titel

Ref. Ares(2023)8616336 - 15/12/2023

EUROPEAN COMMISSION

REGULATORY SCRUTINY BOARD

Brussels,

RSB

Opinion

Title: Impact assessment / Roadworthiness package

Overall opinion: POSITIVE WITH RESERVATIONS

(A) Policy context

The 2014 Roadworthiness Package aims to ensure defective vehicles are not allowed on

the roads and that they respect the environmental standards in place. This is done through

periodic technical inspections (PTIs), roadside inspections, and rules on the registration

of vehicle documents. The evaluation of the package identified enforcement shortcomings

and a mismatch between the framework in place and technical and market developments.

In this context, the Commission is working on a proposal to revise the rules.

(B) Summary of findings

The Board notes the additional information provided and commitments to make

changes to the report.

However, the report still contains significant shortcomings. The Board gives a

positive opinion with reservations because it expects the DG to rectify the following

aspects:

(1) The report is not sufficiently clear about the scale of the problem, the robustness

of the underlying evidence and the assumptions made in the analysis.

(2) The report does not clearly explain the reasoning behind the packaging of

options. It does not sufficiently bring out the key policy choices and the related

trade-offs, including in terms of reduced fatalities and injuries. The costs and

benefits implications of key safety measures are not clearly presented.

(3) The comparison of options is not sufficiently detailed and nuanced, including in

terms of coherence with the ‘Vision Zero’ road safety policy framework.

________________________________

This opinion concerns a draft impact assessment which may differ from the final version.

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111

[email protected]

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(1) The report should make clear what the scale of the problems identified is, including

regarding vehicles currently exempted, such as motorcycles, or not subject to a yearly PTI,

such as vehicles older than 9 years. The strength and robustness of the evidence

underpinning the analysis of the problems and impact analysis and of related estimations

should be made more explicit. The report should clarify supporting assumptions when it

comes to the contribution of defects in vehicles to road crashes and the link between road

safety and inspections. The geographical distribution of the problems identified should

also be better explained, with clear references to the situation in different Member States.

(2) The report should more clearly acknowledge any uncertainties related to the evidence

and assumptions used, in particular in relation to the analysis of the impacts of the

odometer fraud measure. A sensitivity analysis should be carried out to show how these

limitations affect the overall cost-benefit analysis (looking for instance at the assumptions

on the number of cars affected and the economic damage caused by odometer fraud). The

report should be clearer about the assumptions used and why different data points (lower

bound in some cases) were selected for the estimations. It should also clarify to what extent

key assumptions were validated by independent experts and represent the state of the art

on this matter. Similarly, the report should clarify the scale and geographical distribution

of the problem when it comes to older cars, lighter vehicles and mopeds not being

(sufficiently) tested for roadworthiness and the consequences of this.

(3) The report should explain more clearly the reasoning behind the packaging of options.

It should clarify why certain policy measures, such as recording the odometer reading or

registration of certificates in digital formats are not included in all policy packages. Given

that the policy measure aimed at tackling odometer fraud is expected to bring by far the

most significant net benefits, excluding this measure in some policy packages would make

them underperforming by design. The report should provide a clear justification why this

key measure should not be included in the set of measures common for all options. If an

exclusion can be convincingly argued, the report should present variants for options 1a/b

including the odometer measure to allow a fairer and more balanced comparison of

options.

(4) The report should explain the reasoning behind advocating a non-binding measure for

the testing of powerful motorcycles, despite its more limited potential beneficial impact

on road safety. The explanation should also clarify why a non-binding measure is

considered as an adequate measure exclusively in the safety case of powerful motorcycles

but not for any other road safety problem area. When substantiating this reasoning, the

report should make clear references to the evidence available from different Member

States (which are currently applying a testing regime and which are not and what a non-

binding or binding EU measure on this would bring).

(5) The report should present better the key policy choices and related trade-offs, in

particular regarding the benefits and costs of several key road safety measures, including

the mandatory yearly testing for older vehicles and the ending of the exemptions of

motorcycles and light trailers. These measures are currently included as a bundle and

assessed together only in the most ambitious option package 3. However, a

complementary measure-by-measure benefit-cost assessment should allow the

identification of potentially net beneficial measures in terms of overall reduced fatalities

and injuries. As these are highly relevant for decision-making, the report should bring

them out more clearly.

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(6) The comparison of the revised set of options needs to be more nuanced and granular.

To allow a more coherent effectiveness comparison of options the report should present

one clear set of specific objectives avoiding overlaps with the general objectives.

Regarding coherence, the report needs to demonstrate why packages 2 and packages 3 are

scored the same, despite the significant differences with respect to contributiong to the

Vision Zero road safety goals. The comparision overview Table 25 should be reworked to

allow a detailed overview of quantitative and qualitative key impacts, so that the key

differences between the options become more obvious. On this basis, the report should

better justify the choice of the preferred option, while being clear on the key trade-offs

between options in terms of efficiency, effectiveness and coherence.

The Board notes the estimated costs and benefits of the preferred option(s) in this

initiative, as summarised in the attached quantification tables.

Some more technical comments have been sent directly to the author DG.

(D) Conclusion

The DG must revise the report in accordance with the Board’s findings before

launching the interservice consultation.

If there are any changes in the choice or design of the preferred option in the final

version of the report, the DG may need to further adjust the attached quantification

tables to reflect this.

Full title

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,

Directive 2014/47/EU on the technical roadside inspection of the

roadworthiness of commercial vehicles circulating in the Union,

and Directive 1999/37/EC on the registration documents for

vehicles

PLAN/2021/10932

20 November 2023

13 December 2023

Reference number

Submitted to RSB on

Date of RSB meeting

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ANNEX: Quantification tables extracted from the draft impact assessment report

The following tables contain information on the costs and benefits of the initiative on which

the Board has given its opinion, as presented above.

If the draft report has been revised in line with the Board’s recommendations, the content of

these tables may be different from those in the final version of the impact assessment report,

as published by the Commission.

I. Overview of Benefits (total for all provisions) – Preferred Option (PO2)

Description

Amount

Direct benefits

Administrative costs

savings for Member

States administrations,

expressed as present

value over 2026-2050,

relative to the baseline

EUR 5.23 billion

Administrative cost savings for

national administrations due to

issuing the roadworthiness

certificates in electronic format only,

the interlinking of national vehicle

registers, the time saved for the re-

registration of a vehicle in another

Member State, and due to avoiding

the costs of printing, distribution and

handling of paper/plastic registration

certificates, estimated at EUR 5.23

billion, expressed as present value

over 2026-2050.

Administrative costs savings for PTI

centres due to the access to relevant

technical

information

(data

governance) estimated at EUR 1.64

billion, expressed as present value

over 2026-2050.

Benefits from additional periodic

technical inspections for PTI centres

due to the extension of scope of PTI

and more frequent testing of certain

vehicle categories. Estimated at EUR

2.32 billion expressed as present

value over 2026-2050.

Administrative costs savings for

other businesses (vehicle owners)

due to the possibility to avoid

emission testing at PTI in case the

vehicle passed a roadside inspection

or was in line with the emission

limits during a screening by remote

sensing. The savings are estimated at

EUR 1.29 billion, expressed as

present value over 2026-2050.

Benefits for other businesses (vehicle

owners) due to mandatory recording

and reporting to a national central

database of vehicle mileage,

whenever a vehicle undergoes

repair/maintenance or in the case of

tyre changes/replacement which

helps reducing odometer fraud,

estimated at EUR 96.1 billion ,

Comments

Administrative costs

savings for businesses

(PTI centres), expressed

as present value over

2026-2050, relative to

the baseline

Benefits for businesses

(PTI centres) from

additional technical

inspections, expressed

as present value over

2026-2050, relative to

the baseline

Administrative costs

savings for other

businesses (vehicle

owners) expressed as

present value over

2026-2050, relative to

the baseline

EUR 1.64 billion

EUR 2.32 billion

EUR 1.29 billion

Benefits for other

businesses (vehicle

owners) due to avoided

odometer fraud

EUR 96.1 billion

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I. Overview of Benefits (total for all provisions) – Preferred Option (PO2)

Description

Amount

Comments

expressed as present value over

2026-2050.

Adjustment costs

savings for citizens

(vehicle owners)

expressed as present

value over 2026-2050,

relative to the baseline

EUR 2.1 billion

Adjustment cost savings for citizens

due to the recognition of PTI

certificates issued by a Member State

other than Member State of

registration of up to six months, as a

result of avoided travel costs back to

the country of vehicle registration for

a PTI. Estimated at EUR 2.1 billion

relative to the baseline (expressed as

present value over 2026-2050).

Administrative costs savings for

citizens due to not requiring emission

testing at PTI after the vehicle has

successfully passed a screening by

remote sensing, estimated at up to

EUR 591.9 million, expressed as

present value over 2026-2050.

Benefits due to the obligation for

Member States to record odometer

readings in a national database, as

well as to make them available to

other Member States in the case of a

re-registration of a vehicle in order to

reduce odometer fraud. Estimated at

around EUR 53.3 billion, expressed

as present value over 2026-2050.

Positive impact on the functioning of

the internal market is expected due to

the the measures related to improving

the availability and exchange of

vehicle-related information, making

the

roadworthiness

certificate

available in electronic format,

harmonising testing methods, the

frequency of testing, requirements for

the improvement of the PTI and the

scope of testing. Harmonising vehicle

registration

documents

across

Member States will help to verify the

vehicle's characteristics, and its

registration status in the country of

origin. This can help addressing

potential obstacles to re-registration

in another EU Member State where

the vehicle is reported stolen, or its

registration certificate is suspected of

being fraudulent.

The mandatory electronic format of

roadworthiness certificates should

have a positive impact on digital

transformation in the EU. For the

process of re-registration, it will save

Administrative costs

savings for citizens

(vehicle owners)

expressed as present

value over 2026-2050,

relative to the baseline

Benefits for citizens

(vehicle owners) due to

avoided odometer fraud

EUR 591.9 million

EUR 53.3 billion

Improvement in the

functioning of the

internal market

Benefits for citizens

and administration due

to ‘digital by default’

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I. Overview of Benefits (total for all provisions) – Preferred Option (PO2)

Description

Amount

Comments

time and costs for authorities and

citizens by moving away from

information and data exchange via e-

mail, which is less efficient and time

consuming. A digital registration

certificate should help reduce time

and costs for authorities and citizens

by making access and exchange of

the relevant information easier,

faster.

Increase in employment

of PTI and RSI

inspectors, relative to

the baseline

PTI inspectors: 2,626 additional full time Preferred policy option will lead to

inspectors in 2030 and 2,053 in 2050, additional inspections and the need

relative to the baseline

for additional inspectors PTI and RSI

to perform them due to extension of

vehicle scope or increase in testing

RSI inspectors: 204 additional full time

frequency for particular vehicle

inspectors in 2030 and 243 in 2050,

categories (such as annual emission

relative to the baseline

testing of vans, the noise testing of

motorcycles and extension of RSI to

vans). As well as the increase in the

number of inspectors employed,

there will be benefits from the

additional training for the inspectors

that will be needed to be able to

deliver the new testing methods. The

demand for additional and new

testing equipment will lead to an

increase in production-related jobs

within Member States. There will

also be employment opportunity

related to providing ongoing

maintenance for the new testing

equipment.

Indirect benefits

Reduction in the

number of fatalities and

serious injuries relative

to the baseline

(cumulative over

2026-2050)

4,452 lives saved and 37,777 serious

injuries avoided

Indirect benefit to society at large.

Significant positive effects on road

safety are expected, in particular due

to to the more effective identification

of vehicles with major and dangerous

defects in the fleet, which should

lead to the reduction of road crashes

caused by technical defects and, as a

result, to reduced fatalities and

injuries. Measures which relate to

better implementation and

enforcement of the roadworthiness

legislation will also contribute. The

impacts are estimated at 4,452 lives

saved and 37,777 serious injuries

avoided over the 2026-2050, relative

to the baseline.

Indirect benefit to society at large,

due to the lives saved and injuries

avoided. The reduction in the

external costs of accidents is

Reduction in external

costs of accidents

(fatalities and serious

injuries), expressed as

EUR 49.5 billion

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I. Overview of Benefits (total for all provisions) – Preferred Option (PO2)

Description

present value over

2026-2050, relative to

the baseline

Reduction of air

pollutant emissions

(kilo tonnes of NOx

and PM2.5 avoided)

(cumulative over 2026-

2050)

Air pollutants reduction: 4,119.5 kilo-

tonnes of NOx and 206.2 kilo-tonnes of

Amount

Comments

estimated at EUR 49.5 billion,

expressed as present value over the

2026-2050 horizon (in 2022 prices)

relative to the baseline.

Indirect benefit to society at large

Significant positive effects on

environment are expected, due to the

measures having an impact on air

pollutant emissions and targeted at

high emitters of NOx and particulate

matter in the vehicle fleet, which

should be effectively identified and

repaired, with expected cumulative

impact on air pollutants reduction

4,119.5 kilo-tonnes of NOx and

206.2kilo-tonnes of PM over 2026-

2050.

Indirect benefit to society at large,

due to the reduced air pollutant

emissions. The reduction in the

external costs of air pollution is

estimated at EUR 79.2 billion,

expressed as present value over the

2026-2050 horizon (in 2022 prices)

relative to the baseline.

Indirect benefit to society at large,

due to the reduced noise emissions.

The reduction in the external costs of

noise pollution is estimated at EUR

7.3 billion, expressed as present

value over the 2026-2050 horizon (in

2022 prices) relative to the baseline.

Reduction in the

external costs of air

pollutant emissions

relative to the baseline,

expressed as present

value over 2026-2050

EUR 79.2 billion

Reduction in the

external costs of noise

emissions relative to the

baseline, expressed as

present value over

2026-2050

EUR 7.3 billion

II. Overview of costs – Preferred option (PO2)

Citizens/Consumers

One-off

Direct adjustment costs

(expressed as present

value over 2026-2050,

relative to the baseline)

Recurrent

Businesses

One-off

Recurrent

For PTI

centres: EUR centres: 3.43

2.12 billion

billion

Administrations

One-off

For

national

public

authorities:

EUR 29.7

million

For

national

public

authorities:

EUR 73.6

million

Recurrent

For

national

public

authorities:

EUR 177.5

million

For

national

public

authorities:

EUR 2.31

billion

Direct administrative

costs (expressed as

present value over 2026-

2050, relative to the

baseline)

For citizens

(vehicle

owners):

EUR 344.2

million

For

businesses:

EUR 218

million, of

which:

For

businesses:

EUR 2.63

billion, of

which:

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II. Overview of costs – Preferred option (PO2)

Citizens/Consumers

One-off

Recurrent

Businesses

One-off

- EUR 48.9

million for

PTI centres

- EUR 149.2

million for

garages,

repair

stations, etc.

- EUR 20

million for

vehicle

manufacturers

Recurrent

- EUR 87.7

million for

PTI centres

- EUR 310.8

million for

garages,

repair

stations, etc.

- EUR 35.9

million for

vehicle

manufacturers

- EUR 2.20

billion for

other

businesses

(for vehicle

owners)

Administrations

One-off

Recurrent

Direct regulatory fees

and charges

Direct enforcement costs

(expressed as present

value over 2026-2050,

relative to the baseline)

Indirect costs

III. Application of the ‘one in, one out’ approach – Preferred option (PO2)

[M€]

One-off

(annualised total net

present value over the

relevant period)

Recurrent

(nominal values per year)

Total

Businesses

New administrative

burdens (INs)

EUR 25.5 million, of

which:

- EUR 5.7 million for the

PTI centres

- EUR 2.3 million for

vehicle manufacturers

- EUR 17.5 million for

garages, repair stations

EUR 26.4 million, of which: EUR 51.9 million, of

- EUR 4.9 million for PTI

which:

centres

-EUR 10.6 million

- EUR 2 million for vehicle

for PTI centres

manufacturers

-EUR 4.3 million

- EUR 19.5 million for

for vehicle

garages, repair stations, etc.

manufacturers

-EUR 37 million

for garages, repair

stations, etc.

Removed

administrative

burdens (OUTs)

Net administrative

burdens

Adjustment costs

(expressed as

EUR 25.5 million

For PTI centres: EUR

2.12 billion

EUR 26.4 million

For PTI centres: 3.43 billion

EUR 51.9 million

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III. Application of the ‘one in, one out’ approach – Preferred option (PO2)

[M€]

One-off

(annualised total net

present value over the

relevant period)

Recurrent

(nominal values per year)

Total

present value over

2026-2050, relative

to the baseline)

Citizens

New administrative

burdens (INs)

Removed

administrative

burdens (OUTs)

Net administrative

burdens

Adjustment costs

Total administrative

burdens

EUR 25.5 million

EUR 26.4 million

EUR 51.9 million

Electronically signed on 15/12/2023 11:37 (UTC+01) in accordance with Article 11 of Commission Decision (EU) 2021/2121