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"content": "MAT-A-BMUB-2-1 [Ordner 46 von 60] D r a f t a g en d a SffiTHTCMV MEETING EUROPEAN COMMISSION \\ 7^»“ DIRECTORATE-GENERAL FOR INTERNAL MARKET, INDUSTRY, ENTREPRENEURSHIP AND SMES J Ä Industrial Transformation and Advanced Value Chains 'xrC 'l ™ y Automotive and Mobility Industries TECHNICAL COMMITTEE - MOTOR VEHICLES (TCMV) Brasseis, 24 September 2015 GROW/C4 - CM - D r a ft A genda o f the 50th m eeting o f the ‘Technical Committee - M otor vehicles’ (TCMV) Brussels, 06 October 2015 *10h00 - 17h00* Place: CCAB IB Documents can be downloadedfrom the CJRCABC group \"Automotive Industry Committees and Working Groups httPs://circabc,euroTOaeu/w/browse/laf723ce-8472-47f8-bc.67“9ab4269bb8c4 I 1. Approval of the draft agenda; 2. Updating of the TCMV members’ list; 3. Approval of the draft minutes from the 49th meeting held on the 10 September 2015; 4. Exchange of views and request for information from Member States on the Volkswagen case; 5. Exchange of views with respect to the preparation for the UNECE WP29 session of 09 -1 3 November 2016: a. Information from the .Commission on the position to be taken by the European Union in the relevant Committees of the United Nations Economic Commission for Europe as regards the proposals for amendments to Nos 12, 16, 26, 39, 44, 46, 58, 61, 74, 83, 85, 94, 95, 97, 98, 99, 100, 101,106, 107, 110, 116, 127, on a new UN Regulation on frontal impact, on amendments to the Consolidated Resolution on the Construction of Vehicles (R.E.3) and on a new Mutual Resolution No. 2 (M.R.2) on vehicle powertrain definitions (mega decision); b. Exchange of views on the financing of the UNECE database for the exchange of type-approval data (DETA). 6. Exchange of views on a proposal for a Commission Directive amending Directive 97/24/EC of the European Parliament and of the Council of 17 June 1997 on certain components and characteristics of two or three-wheel motor vehicles and Directive 2009/67/EC of the European Parliament and of the Council of 13 July 2009 on the installation of lighting and light-signalling devices on two- or three-wheel motor vehicles 7. Discussion on the updated Commission draft proposal for the amendments to Regulation (EU) 582/2011; 8. Exchange of views on proposals for updating Annex 4 of the General Safety Regulation; 9. Exchange of views and discussion on the further development of the RDE legislation; 10. AOB European Commission - B-1049 Brussels - Belgium - Office: Telephone: direct line . Fax: . E-mail: @ec.europa.eu 111",
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"content": "MAT-A-BMUB-2-1 [Ordner 46 von 60] 000108 MINUTES 50th TCMV m eetin g EUROPEAN COMMISSION . ' ~ ----- INTERNAL MARKET, INDUSTRY, ENTREPRENEURSHIP AND SMES DIRECTORATE- \" •; ; ,v . GENERAL r ;■ ; . ' ’ ^1* ' Industrial Transformation and Advanced Value Chains Automotive & Mobility Industries * TECHNICAL COMMITTEE - MOTOR VEHICLES (TCW8V) Brussels, 26 November 2015 GROW /C4 - CM - F in a l m in u t e s o f t h e 50th m e e t i n g o f t h e ‘T e c h n i c a l C o m m i t t e e - M o t o r VEHICLES’’(TCMV) MEETING HELD IN BRUSSELS ON 06 O ctober 2015 European Commission - B-1049 Brussels - Belgium - Office: Telephone: direct line Fax: . E-mail: @ec.europa.eu 112",
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"content": "MAT-A-BMUB-2-1 [Ordner 46 von 60] 000109 1. Approval of the draft agenda; The agenda was approved. 2. Updating of the TCMV members’ list; The participants were asked to send any changes to the secretariat. 3. Approval of the draft minutes from the 49th meeting held on the 10 September 2015; The minutes were approved. 4. Exchange of views and request for information from Member States on the Volkswagen case; The EC representative explained the point and referred to the questions in the note sent to t the Member States. The DE Representative stated that DE will test Volkswagen vehicles with the concerned engines, other vehicle types of the Volkswagen group and also vehicle types from other manufacturers, aiming on the identification of manipulations and the use of prohibited defeat devices. VW has confirmed the manipulation regarding the exhaust emissions and offered cooperation. VW was asked to provide information about an action plan and time schedule to KBA, in order to bring the concerned vehicles in compliance with the requirements of the regulation. Once KBA will receive the information, the decision on necessary actions will be made. DE welcomes the approach of the Commission regarding exchange of information, as there is an EU aspect. Regulation 715/2007, art. 5(2) prohibits defeat devices and has exceptions, which also needs to be taken into account. The tests have been going on for a week now, but testing, evaluation and drawing of conclusion^ need more time. The affected vehicles are VW vehicles with Euro 5 diesel engines 1.2, 1.6, and 2.0 1 (engine EA 189). They are no longer in production. Euro 6 vehicles are in the focus for testing at the very beginning, because these vehicles are now in production. KBA described the developed test procedure that probably can identify manipulations and the use of prohibited defeat devices. The test design includes also the testing of vehicles on the roads, with PEMS. DE will continue to provide information to the European Commission, the Member States and the type approval authorities. The EC representative asked if the affected vehicles are still being sold in Germany and if yes, what will be done if the conclusions are that these vehicles are not in conformity with the legislation. Agreed that the focus should be on Euro 6 vehicles. Asked all MS whether the sale of the affected vehicles have been stopped. The DE representative stated that the sales of Euro 5 vehicles Continue, but are talking about very few vehicles (end of series). 2 113",
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"content": "MAT-A-BMUB-2-1 1f [Ordner 46 von 60] 000110 The ES representative thanked the Commission for the coordination.- Spain has stopped end of series sales of Euro 5 diesel vehicles, on the basis of national legislation (end-of-series is a national decision). All manufacturers have been asked whether they have used a similar strategy. Most of them have replied and said no. They have met with VW and are waiting for information. Don't know what kind of tests die TAA could do, legally, to check this issue. The FR representative thanked the Commission for the coordination. The device is technically very complicated - TAC was requested to come up with a test and to test the vehicles represented in the FR market. This started 1 October. It has also started to test the vehicles Euro 4, 5 and 6 to check whether similar devices have been used. JRC is cooperating and will have preliminary results to share at the end of October. There are already actions against VW by consumer organisations. The NL representative is following the process in Germany. Sales are not blocked in NL. It is not only end of series, some are still being registered (Ml II and HI). Importers are not selling the vehicles anymore, but not upon a decision of the NL authorities. NL has sent letters to the manufacturers type-approved in NL asking for information. 2.000 type-approvals - 22 manufacturers. - The system they have in place does not allow finding this kind of problem. RDE will be vital in this respect, as it will allow independent testing. The IT representative stated that this is a serious case, the most serious so far for our TA system. IT authorities contacted DE immediately, and with the information received will now try to identify the affected vehicles in the database. The vehicles are not being sold - decision of the concessionary. An investigation will be started comparing die emissions in laboratory and in RDE and on eventual defeat devices (will focus on vehicles that have very high differences). If the problem is confirmed, action will have to be taken. The system in the FD should be less vulnerable to diese situations. The LUX representative : Competitiveness Council - the Ministers have delegated in DE the task of analysing the issue and coming up with solutions. The EU TA system did not manage to detect the problem, but nor did the market surveillance system - it was a private initiative. Our system still has more advantages that disadvantages. It is the responsibility of the manufacturer to build its vehicles in accordance with the TA rules. In the future we will need to strengthen the TA system. The UK representative stated that the TA system is under threat - it is a good system, but we need to reflect on how it should be improved. The Volkswagen case affects 1.2 million Euro 5 vehicles in the UK. VW UK voluntarily stopped sales in die UK of the remaining Euro5 derogation vehicles. The national authorities have limited powers in situations like this; we cannot act without absolute proof of illegality. The UK government will ensure, vehicle owners will not incur additional taxation if their existing vehicles are found to be fitted with illegal software that manipulates emissions tests. The UK government has also announced a programme to retest vehicles. The Vehicle Certification Agency, the UK type 3 114",
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"content": "MAT-A-BMUB-2-1 [Ordner 46 von 60] approval authority, is running laboratory tests starting with those VW Group vehicles for which VCA has provided approvals. While Euro 6 is important, as it is the future, this test programme will focus on Euro 5 vehicles initially. The testing will include RDE, WLTP and NEDC tests. The UK asked about the coordination role of the Commission, commenting that we should try to avoid overlaps in TAA testing as these are very costly tests. The UK also commented on the Commission’s important role in drawing together common conclusions. Finally the UK highlighted that the text regarding defeat devices for heavy duty vehicles is different from light duty, and suggested that the light duty regulation may benefit from being updated to align with heavy duty requirements. The SE representative mentioned that they have done some tests on in-service vehicles. SWE has an in-service program and do some tests outside the regulations. In this context SWE have testes 6 vehicles in accordance with RDE in the last three years, 3 of them diesel. They exceeded the limits. The CZ representative informed die Committee that there: registered cars in CZ: 230.000. 100.000 of these are Skoda. Will start this week to test Euro 5 and 6 vehicles. This is being coordinated with the DE authorities. After, the results will be discussed with Skoda. No more Euro 5 Skoda vehicles for sale. The BE representative explained that a committee to deal with this issue has been created. They need more information. Once they have the necessary information they will decide what to do. Information from importers: 400.000 vehicles in BE. They have launched a procedure on RAPEX concerning measures on dealers and importers. No specific info on the concrete measures. The representative asked how BE can have access to the necessary info. The RO representative stated that RO had immediately contacted KBA, which gave information on the vehicles affected. 5.000 vehicles concerned. 300 end-of-series. The sales have been blocked by the authorities. National producer - information that the problem does not exist. No measures yet (no own tests) The HU representative stated that there are possibly 23.000 affected vehicles in HU. They have not stopped the sale of vehicles. They have asked other manufacturers represented in HU whether they are also affected. The DK representative stated that there are 90.000 vehicles from VW in DK and the importer has voluntary stopped the sales. No own testing being done, The EC representative: Definition of defeat devices: LD - was carried out from the existing legislation in 2007. It corresponds to the US definition at that time. HD - also the US definition, but has also the need for type-approving these devices. 4 115",
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"content": "MAT-A-BMUB-2-1 [Ordner 46 von 60] 000112 EU - there isn't the obligation for manufacturers to have alternative emission control strategies (that may be defeat devices) type-approved. Should amend the legislation. DE has made a proposal for Coreper in the context of Euro 5/6. The EC representative asked for an exchange of information: the Commission will create an IT tool and all exchanges should go through this. DE should put all the available information there. Uniform testing: all relevant information on testing methods should be sent to the Commission - IRC. We should achieve comparable results. Asks for particular attention to be given by MS to the answer of question 3. 5. Exchange of views with respect to the preparation for the UNECE WP29 session of 09 -1 3 November 2016: a. Information from the Commission on the position to be taken by the European Union in the relevant Committees of the United Nations Economic Commission for Europe as regards the proposals for amendments to Nos 12,16, 26,39, 44, 46, 58, 61, 74, 83, 85, 94, 95,97,98,99,100,101,106,107,110,116,127, on a new UN Regulation on frontal impact, on amendments to the Consolidated Resolution on the Construction of Vehicles (R.E.3) and on a new Mutual Resolution No. 2 (M.R.2) on vehicle powertrain definitions (mega decision); The EC representative presented the draft mega decision. He brought 4 points to the attention of tiie participants. The first point concerned a proposal from the UNECE secretariat to correct a sentence in paragraph 5.2.8.2. on electrolyte spillage of the new UN Regulation on frontal impact (ECE/TRANS/WP.29/2015/105) as follows: ‘For open type traction batteries no more than 7 per cent with a maximum of &£ 5.0 litres shall spill outside the passenger compartment.’ This change is in line with UN Regulation No 94 on which this new Regulation is based. This change will be proposed by the secretariat before the vote on the document and the EC recommends accepting the document including this correction. The second point was the recent choice from GRSG to withdraw document ECE/TRANS/WP.29/2015/90 from the WP29 agenda, which is an amendment to UN Regulation No 110 on CNG and LNG vehicle requirements. The document will be revisited by GRSG and resubmitted in the March 16 WP29. Consequently the document reference will be deleted from the mega decision. The EC representative continued with the presentation by referring as third point to an amendment of the consolidated Resolution on the construction of vehicles (R.E.3, ECE/TRANS/WP.29/2015/111). The document is ready and acceptable for vote and he invited the DE representative in his capacity as Chairman of GRPE to provide a verbal update on the discussions in GRPE earlier this year. Finally as fourth point he thanked the DE representative on behalf of the EC for his work as Chairman on the informal UNECE working group VPSD. The output of this group is mutual Resolution No 2 (M.R.2, ECE/TRANS/WP.29/2015/110), which is ready for vote in the coming WP29 meeting. The DE representative explained that M.R.2 is applicable both under the 1958 and 1998 Agreements und intends harmonising vehicle powertrain system definitions. He anticipates that this document is not controversial and that WP29 will consider it in the upcoming meeting in November. With respect to the amendments on market fuel quality in R.E.3 he noted that the 5 116",
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"content": "MAT-A-BMUB-2-1 [Ordner 46 von 60] changes are important for the European industry exporting their products to third countries and he therefore recommended adopting this document too. The FR representative noted that die amendment to Regulation No 107 ( ECE/TRANSAVP.29/2015/88) required corrigendum GRSG-109-02 as this was recommended by GRSG last week and he requested the IT representative in his capacity as GRSG Chairman to confirm this. The NL representative confirmed that this comgendum would be needed as well as an additional corrigendum. The IT representative in his capacity as GRSG Chairman recalled that GRSG had decided to submit ECE/TRANS/WP.29/2015/88 to the Nov 16 WP29 session for adoption first as it stands and to submit the consolidated changes as a supplement for the March 16 session of WP29 as it was felt that it was not appropriate to submit these changes as corrigenda with such a short notice to WP29. Nevertheless he was going to verify that with the UNECE secretariat and would confirm this after the meeting. The UK representative stated that his colleagues were still examining the proposed mega decision and that to date no concerns were identified but nevertheless the UK was raising a parliamentary reservation until final confirmation that there are no issues. However, in principle the UK would vote in favour. b. Exchange of views on the financing of the UNECE database for the exchange of type- approval data (DETA). The EC representative presented some elements of document WP29-166-07 regarding financing of the UNECE DETA, which is a database at the premises of the UNECE for the secure exchange of international type-approval data. The UNECE secretariat had summarised its analysis in this document and anticipates a total sum of $ 125000 per year to operate the database mid helpdesk services. The secretariat identified 4 options listed in the document. The EC representative asked the meeting participants to share their views and express preferences to the EC to allow communicating the common EU position with respect to this subject in the upcoming WP29 meeting. The NL representative was definitely in favour of financing DETA by increasing in the UNECE regular budget (4th option). He anticipated that the other options would increase burden and make it less attractive for candidate contracting parties to accede to the Agreement. He was also concerned with discontinuity of DETA if other options than increasing of the regular budget would be chosen. The IT representative agreed with his Dutch colleague that traditional financing by increase of the regular UNECE budget is the right way forward. The BG representative supported the views from NL and IT. The UK representative also agreed with increasing the regular UNECE budget as for the other 3 options it is likely that the financing would need to be shouldered by only the EU Member States whereas all 51 CPs would benefit from the database. He noted that DETA could also be 6 117",
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"content": "MAT-A-BMUB-2-1 [Ordner 46 von 60] 000114 beneficial for CPs of the 1998 Agreement but that some CPs to that Agreement considered BETA as only an item relevant for type-approval. He would like to convince the CPs of the 1998 Agreement that DETA is also useful for countries with a self-certification system. The SE and DE representatives were in agreement and in favour of increase of the regular budget. The EC representative took note of this consensus and stated that the EC would communicate the preference of the MS in the upcoming WP29 meeting. 6. Exchange of views on a proposal for a Commission Directive amending Directive 97/24/EC of the European Parliament and of the Council of 17 June 1997 on certain components and characteristics of two or three-wheel motor vehicles and Directive 2009/67/EC of the European Parliament and of the Council of 13 July 2009 on the installation of lighting and light-signalling devices on two- or three-wheel motor vehicles The EC representative presented a proposal to amend Directives 97/24/EC and 2009/67/EC which are part of the current type-approval package based on Directive 2002/24/EC. He explained that it would still be worthwhile to introduce these changes as Regulation (EU) No 168/2013, that replaces Directive 2002/24/EC, contains transitional provisions in Article 77(3) allowing new types of two-, three- and four-wheeled mopeds (categories Lie, L2e and L6e) still to be approved in accordance with Directive 2002/24/EC in 2016, despite the fact that Directive 2002/24/EC and its implementing Directives will be repealed on 31 Dec 15. There are precedents of such scenarios in EU approval legislation. Existing moped type-approvals based on 2002/24/EC will still be valid until 31 December 2017 in accordance with Annex IV to Regulation (EU) No 168/2013. He stated that the proposal had already been introduced in the Motorcycle Working Group meeting of 23 Sep 15 and that the deadline for comments had been set to 05 Oct 15. He proposed to extend the deadline until 13 Oct 15 for Member States to comment. Targets are the TCMV vote still in 2015 and an adoption process allowing publication of the amendments by the end of May 2016. The DK representative was concerned with this proposal from the legal point of view. He pointed out that EC adoption can only follow after the three months scrutiny period, which means that the EC would adopt legislation after its repeal. He questioned the proposed timing as Member States need at least half a year to transpose a Directive into national legislation, which results in publication by the end of 2016 and he wondered whether this work would still be justified for a just a couple of months up to the point that Regulation (EU) No 168/2013 would be applicable for all vehicles of category L. The BG representative understands the justification from the EC to still try and make these amendments to the current legal package but she agreed with her Danish colleague that the proposal was problematic from the legal point of view.< She wanted to know from the EC which will be the final anticipated date in Article 3 of the proposal for transposition into national legislation. The EC representative took the point from the DK and BG representatives and acknowledged that, assuming the 6 months transposition time, the anticipated entry-into-force date would probably be towards the end of 2016. He stated that the EC would investigate this further and would update the participants in the next TCMV meeting. 7 118",
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"content": "MAT-A-BMUB-2-1 [Ordner 46 von 60] 7. Discussion on the updated Commission draft proposal for the amendments to Regulation (EU) 582/2011; The EC representative presented in brief die main changes introduced in the draft proposal following the last TCMV and the technical expert group meeting which was held on the 22nd September. The main change concerned the deletion of all the items referring to the PEMS-PM measurements and introducing a recital on the obligation of the Commission to introduce instead a PEMS-PN measurement and limit as soon as technically feasible. The EC will launch die pilot study for validating the PEMS-PN methodology already on the 22nd October 2015 in a meeting of the experts in Ispra Italy, with the aim of completing the whole exercise in the minimum time technically possible. Other issues like a possible Cold Start procedure, the introduction of special provisions for paraffinic fuels, the changes in the payload limits to be tested and some other minor issues were not yet introduced in die text, because the EC is waiting for input from the industry and/or MS. The AT representative commented that the speeds used are not representative for the reality in Austria and need to be increased for both highways and national roads. The EC representative replied that it is true that the speed limits used necessarily reflect a European average situation. Since speed limits in various countries differ, it is not possible to select limits that reflect all situations. The DE representative asked clarifications on the timing of the PEMS-PN and welcomed the introduction of the PEMS-PN, if this will happen quickly. The EC representative answered that the whole exercise will have a very strict timing and will only be successful if the EC manages to secure the help of vehicle and instrument manufacturers. The current draft plans for the exercise to finish by the end of 2016 in order to allow adoption of the new procedure by early 2017, but a more accurate plan will be available after the kick off meeting. The FR representative welcomed the introduction of the PEMS-PN procedure and abandoning the PEMS-PM. She noted that there is a consistency problem in Annex I Table 1 of appendix 9 between the last date of registration of step C (30/12/2017) and the first implementation date for all vehicles of step D. (31/12/2018). This means that there is one year + one day between the end the step C and the beginning of step D for new vehicles of existing types. They propose instead the following: Implementation dates: all vehicles for step C: 31.12.2016 and last date of registration for step C: 30.12.2018. Other statements and questions were provided in writing after the meeting. The UK representative welcomed the introduction of the PEMS-PN procedure and abandoning the PEMS-PM. The SE representative welcomed the introduction of the PEMS-PN procedure and abandoning the PEMS-PM. He repeated the issue which was raised in the previous meeting with the lowering of the test start temperature to 30 °C, which would not allow for two tests per day, increasing thus the burden for the testing labs. 119",
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"content": "MAT-A-BMUB-2-1 [Ordner 46 von 60] 000116 The EC representative replied that the introduction of the 30 °C was in order to avoid that vehicles come into the test with preconditioning of their exhaust after-treatment systems and will revaluate it once the cold start discussion is finalised. The NL representative welcomed the introduction of the PEMS-PN procedure and abandoning the PEMS-PM. He promised assistance in redrafting the text on the issue of paraffinic fuels and payload. The DE representative also supported the introduction of the PEMS-PN procedure. With regard to cold start. DE declared that that this is a crucial issue. If no quick solution can be found for the issue of cold start in the current comitology package this should be addressed äs soon as possible., DE will also support the introduction of start test temperature at 30 °C. 8. Exchange of views on proposals for updating Annex 4 of the General Safety Regulation The EC representative outlined the proposal to update Annex 4 of Regulation (EC) No ( ; 661/2009. He explained it was a relatively straightforward update of the references to the Official Journal, given the ongoing translations of published UNECE regulations. He noted the updates of Regulation Nos 118 regarding fire resistance of coaches and R46 regarding die more stringent requirements for N2 and N3 trucks. For these reasons die validity of old and previously equivalent Directive approvals would be limited to a proposed deadline of 1 April 2016. A number of Member State representatives noted that this date should be reconsidered given the short timeframe. The Commission representative noted that transitional provisions of UNECE regulations have been first negotiated in Geneva and subsequently endorsed (again) by Member States for the Council Decision. There should not be a third negotiation when updating Annex 4. Manufacturers are strongly encouraged to adhere to the transitional provisions as provided in the various UNECE regulations as they can be translated and published in the Official Journal with little prior warning. The Commission representative asked Member States for their written comments in this context. The DK and RO representatives noted that there was some confusion as regards the entry into force dates for various listed regulations, i.e. whether or not this should be understood to be 1 April 2016 for the level as indicated in Annex 4. The Commission representative agreed to clarify in the recitals what the entry into force date means. 9. Exchange of views and discussion on the further development of the RDE legislation; The Technical Committee - Motor Vehicles debated the further development of the RDE legislation, in particular the NTE emission limits and the application dates for the RDE. The EC representatives presented and explained in detail the circulated in advance note. It was stressed that the proposal is based on assessment of the problem predating the VW case. In that sense, the content of the proposal is based on available data from Commission sources and input from stakeholders. The content of the proposal is thus not influenced by the VW case. The EC representative expressed determination to transform the political commitments made by the Competitiveness Council of 1 October into concrete legislative actions. The EC representative took the position that no further discussion on the parameters of the proposal should be scheduled and that the elements of the proposal have been extensively 9 120",
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"content": "MAT-A-BMUB-2-1 £ [Ordner 46 von 60] 0 0 011 7 and clearly discussed in previous meetings. The Commission considered that their reasoning and proposed solutions have been sufficiently explained. Taking into account the discussion and the written contributions by the Member States, the Commission will said a revised version of the proposal. The deadline for written feedback and positions on the proposal was set for 16 October 2015. Representatives of DG Environment expressed their support of the proposal and stressed the importance of RDE for the air quality. The Member States welcomed the proposal of the Commission but expressed the need t© consult internally before a definitive position is provided. Most Member States were in general positive and urged for a quick implementation. Some Member States -IT, ES, Ro- expressed reservations towards the timeline provided by the proposed text. Additionally, reservation towards the CF were expressed and discussed. The Member States generally agreed that the introduction of transfer functions (TF) should not delay the adoption of the second regulatory RDE package. Details: The DE representatives welcomed that the package was now tabled by the Commission and pointed the need for a quick implementation of an effective RDE as soon as possible and at latest till end of 2015. A position on the draft text will be sent after internal consultations. Regarding the TF, Germany considered that discussions on TF should not delay the adoption of the proposal. The FR representatives welcomed and is in general positive, but still needs to consult internally. Regarding TF, France did not object making a reference in the text, provided that this does not delay the adoption of this text. The IT representatives expressed concerns on the application of the timeline, noting that the dates should be moved to 2017 and 2019 for the first stage. It was suggested that classes II and HI should not be covered in a 1st stage. Additionally, IT expected that the 1st stage should allow current Euro 6 vehicles to comply with the legislation with a mere calibration of the engine. IT agreed with FR that TF can me mentioned provided that this does not cause delays for the implementation of the package. The ES representatives expressed concern about the competitiveness of the EU industry. Like IT, considered that the proposal is too strict and there should be a balance between the dates and the CF. He also emphasised that the effect of the RDE legislation on C02 emissions of the vehicle fleet should be considered and that transfer functions are a valid concept, which should be further pursued. The UK representatives also had reservations on the CF for both stages. On the topic of dates, the UK considered that the dates for the 1st stage of the proposal are acceptable, but could not comment on the dates of the second stage. The SE representatives expressed concern about the CF in the first stage, but approved of the CF in the second stage. Concerning the timing of the first stage, SE considered the timing 10 121",
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},
{
"document": "https://fragdenstaat.de/api/v1/document/145578/",
"number": 12,
"content": "MAT-A-BMUB-2-1 [Ordner 46 von 60] for new types to be acceptable but that the date for new vehicles should be extended to September 2019, in addition the proposal should not define the concept of transfer functions. The BG representatives expressed the need to balance protection of the environment with competitiveness of EU industry. The NL representatives supported the proposal and considered that it is urgent to implement the proposed package. It was proposed that the timeline could even be sped-up and that it is technically feasible to achieve the suggested CF. Therefore, the mandatory application date should be set on the 1 January 2017 for type approvals and for new vehicles (all types) on the 1 January 2018 with a conformity factor for the NOx emission level of 1,5 for the moderate condition and a conformity factor of 2 for extended conditions. Two years later the conformity factor should be set to 1 with the margins as proposed in the Commission proposal. This means with the earlier introduction dates: 1 January 2019 for new type approval and 1 January 2020 for new vehicles (all types). The Netherlands do not see the need to delay the RDE for N1 vehicles of category II and III and N2 vehicles with 1 year so the NL representative proposed the same date as for the Ml vehicle category NL also requested the possibility, in the future, for a CF for urban driving. Some concern was expressed regarding the dynamic boundaries- since most trips in NL would be excluded. The NL representatives did not support inclusion of the TF for die moment. The DK representatives agreed with NL that entry into force could be accelerated and that even lower CF could be adopted. DK was also against die inclusion of TF for the moment. The BE representatives were generally positive about the proposal. Yet they there might be reservations. BE was also against the inclusion TF in the current package. The PL representatives support the quick implementation of RDE, but will still discuss the details internally before and a position is offered. PL did not support the inclusion of TF in the current text. The RO representatives stressed that they would favour a technological approach, diking into consideration the costs. Like IT, RO considered that the 1st phase should, only require re calibration of the engines. In that light, this proposal is not realistic. The FI representatives expressed their support for the proposal and were against the inclusion of TF in the text. The HU representatives agreed that discussions on TF should not delay the adoption 11 122",
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}
]
}
