Position of Spain concerning the Commission proposal of amending
Regulation (EC) No 692/2008 as regards emissions from light
passenger and commercial vehicles (Euro 6)
(TCMV 28.10.15)
A. General Statement
Spain welcomes the proposal from the European Commission concerning the second
package of the real driving emissions (RDE) test procedures. We are in favour of a
quick introduction of the first phase of requirements in order to improve the air quality
in our cities. In that sense, we think that the date of September 2017 is acceptable. In
that context, Spain can accept the text proposed by de Commission in TCMV, on
6.10.2015, with the following modifications:
1. Recitals:
10)

In order to allow manufacturers to gradually adapt to the RDE rules, the final
quantitative RDE requirements should be introduced in two subsequent steps. In
the first step, which should apply from 3 years after the mandatory Euro 6 dates,
a Conformity Factor of 2,3 should apply. The second step should follow 3 years
after and should require full compliance with the emission limit value for NOx
of 80 mg/km set out in Regulation (EC) No 715/2007 plus a margin taking into
account the additional measurement uncertainties of the PEMS test procedure
with a Conformity Factor of 1.6. For extended conditions as defined in point
5.2 of Annex IIIA to Regulation (EC) 692/2008, NTE emission limits should be
increased by 60 % as compared to moderate conditions.

2. Article 1:
Article 1
Regulation (EC) No 692/2008 is amended as follows:
Annex I is amended as follows:
In Appendix 6, table 1 is amended as follows:
(i)

Rows ZD, ZE, ZF shall be replaced by the following:

"
ZD Euro 6c-TEMP Euro 6-2 M, N1 class I

PI, CI

1.9.2017

1.9.2019 31.8.2022

ZE Euro 6c-TEMP Euro 6-2 N1 class II

PI, CI

1.9.2018

1.9.2019 31.8.2020

 ZF

Euro 6c-TEMP Euro 6-2 N1 class III, N2 PI, CI

1.9.2018

1.9.2019 31.8.2020

"

(ii)

The following rows are inserted after row ZF:

"
ZG Euro 6c

Euro 6-2 M, N1 class I

PI, CI

1.9.2020

1.9.2022

ZH Euro 6c

Euro 6-2 N1 class II

PI, CI

1.9.2021

1.9.2023

ZI

Euro 6-2 N1 class III, N2 PI, CI

1.9.2021

1.9.2023

Euro 6c

"
2.1.1 Final Conformity Factors
The conformity factor CFpollutant for the respective pollutant is specified as followas:
Pollutant

Mass
of
oxides
of
nitrogen
(NOx)

CFpollutant

1,6

Number of
particles
(PN)

Mass
of
carbon
monoxide
(CO)(1)

Mass of total
hydrocarbons
(THC)

Combined mass of
total hydrocarbons
and
oxides
of
nitrogen (THC +
NOx)

tbd

-

-

-

Margin is parameter taking into account the additional measurement uncertainties
introduced by the PEMS equipment and is set to 0,2. This value shall be regularly
revised according to the improved quality of the PEMS procedure due to technical
progress.
2.1.2 Temporary Conformity Factors
By way of exception to the provisions of point 2.1.1, until 6 years after the dates given
in Article 10 (4) and (5) of Regulation (EC) 715/2007 and upon request of the
manufacturer, the following temporary conformity factors may apply:

Pollutant

Mass
of
oxides
of
nitrogen
(NOx)

Number of
particles
(PN)

Mass
of
carbon
monoxide
(CO)(1)

Mass of total
hydrocarbons
(THC)

Combined mass of
total hydrocarbons
and
oxides
of
nitrogen (THC +

 NOx)
CFpollutant

2,3

tbd

-

-

-

The application of temporary conformity factors shall be recorded in the certificate of
conformity of the vehicle.

5.4.1 The overall excess or insufficiency of driving dynamics during the trip shall be
checked using the methods described in Appendix 7a of this Annex.
In this regards, average v.apos should be limited to less than or equal to 12 in the
case of moderate conditions and should be limited to less than or equal to 17 in
case the of extended conditions.
5.4.2
(g) In point 6.11, the following sentence is added:
“In addition, the proportional cumulative positive altitude gain shall be less than
650 m/100 km for moderate conditions, and less than 1100 m/100 km in the case of
extended conditions, and be determined according to Appendix 7b.”
B. Justification
Spain is the European leader in production of diesel vehicles which
represents 54.2% of our total national production motor vehicles, that
represents 1.4 million of diesel passenger cars per year. In fact, 31 over 43
models manufactured in Spain are provided with a diesel engine.
Regarding diesel engines, the total yearly production reaches the amount of
1.1 million. In terms of work force, the data shown before represents an
amount of 2.500 qualified employees.
In total, net value of diesel vehicles and engines production in Spain reaches
the amount of 25.000 mill. € per year.
The introduction of severe new requirements in terms of timing and
conformity factor would have the following consequences:






Negative influence in the Spanish economy.
Difficulties in meeting CO2 targets.
Weakness in European competitiveness related to diesel technology.
Would introduce the risk of destroying highly qualified jobs.
Would reduce the investment in R+D+i.

 


Would facilitate the introduction of non European technologies.
Would have implications across the entire value chain: suppliers,
OEMs and dealers.

Regarding vehicles of category N1 class II and III, it should be considered
that the European market of LCVs in category N1 classes II & III, N2 and M2
is relatively small: around 9% of the total passenger car and LCV market.
Moreover, some of these vehicles are outside the scope of the RDE
requirements since they are approved according to the heavy-duty
emissions legislation. It is, then, appropriate to delay the application of the
new requirement for some years.