Regulations Spotlight

Back in 2018, the European Commission began work on the development of a new set of "Euro 7" emissions requirements which were intended to replace the existing Euro 6 light duty vehicle and Euro VI heavy duty vehicle emissions requirements. As part of this development process, the European Commission engaged various expert organisations in the field of vehicle emissions testing to carry out research on their behalf. Furthermore, they sought input from all affected stakeholders via public consultation exercises and by setting up a specific advisory group; the Advisory Group on Vehicle Emission Standards (AGVES), which included representatives from Member States, Type Approval Authorities, automotive industry, consumer organisations and environmental groups.

The draft Regulation which was formulated as a result of this work, referred to as COM (2022) 586 Final, was published on the European Commission’s "Better Regulation" web site on November 10, 2022 for public consultation. This new draft Regulation represents a major change in approach compared to the existing Euro 6 and Euro VI emissions Regulations and proposes a large number of significant changes to the currently applicable emissions requirements. Whilst it is not possible to include details on all of the proposed "Euro 7" amendments in this article, the following is a brief summary of some of the key amendments included in the draft Regulation:

Single emissions Regulation covering all categories of vehicle - Unlike the Euro 6/Euro VI emissions requirements, which were specified within two separate Regulations, the proposed Euro 7 requirements are contained in a single Regulation which covers all M and N category vehicles, i.e. passenger cars, multipurpose passenger vehicles, vans, pick up trucks, heavy trucks, buses and coaches. The intention of the European Commission is to simplify the emissions requirements by incorporating all of the emissions requirements into one Regulation. However, it should be noted that numerous Implementing Regulations will also be required to provide the detailed technical requirements, test procedures and administrative processes necessary for the implementation of these emissions requirements.

New and revised pollutant emissions limits - For tailpipe pollutant emissions, the draft Regulation essentially proposes only two sets of emissions limits; one set of limits applicable to all M1 and N1 category vehicles, i.e. passenger cars, multipurpose passenger vehicles, vans and pick up trucks, and one set of limits applicable to all M2, M3, N2 and N3 category vehicles, i.e. buses, coaches and heavy trucks. Furthermore, these emissions limits are applicable regardless of fuel type (e.g. petrol, diesel, etc,) and powertrain type (e.g. internal combustion engine, hybrid, etc.). In terms of stringency, the proposed Euro 7 limits for M1 and N1 category vehicles are equivalent to the most stringent currently applicable Euro 6 limits, whereas the proposed Euro 7 limits for M2, M3, N2 and N3 category vehicles represent a reduction over the most stringent currently applicable Euro VI limits. In addition to the pollutants regulated under the Euro 6 and Euro VI emissions requirements, for Euro 7, a limit on ammonia (NH3) emissions is proposed for M1 and N1 category vehicles and limits on formaldehyde (HCHO) and nitrous oxide (N20) emissions are proposed for M2, M3, N2 and N3 category vehicles.

Focus on real world emissions - Following the trend introduced by the Euro 6 and Euro VI emissions requirements, in the draft Euro 7 emissions requirements, more emphasis is placed on demonstrating compliance with the emissions requirements during Real Driving Emissions (RDE) testing and during In Service Conformity (ISC) testing, rather than during laboratory testing following defined drive cycles. Furthermore, the environmental conditions under which compliance with the emissions limits must be demonstrated are expanded and "Conformity Factors" are no longer applied to the emissions figures measured during RDE testing.

Increased durability requirements - Compared to the Euro 6 and Euro VI requirements, the draft Euro 7 Regulation increases the specified "vehicle life", i.e. the time period/distance over which the vehicle must comply with the applicable emissions requirements. For M1 and N1 category vehicles, the "vehicle life" is increased from 5 years/100,000km to 10 years/200,000km. The "vehicle life" figures for other vehicle categories are also increased, but not by such a significant margin.

New and revised evaporative emissions requirements - For petrol fuelled vehicles, the draft Euro 7 Regulation introduces a more stringent test procedure and a reduced limit for evaporative emissions testing. In addition, a new test procedure to measure the vapour emissions during refuelling, with an associated limit, is also introduced.

Particulate emissions from brake and tyre wear - In a radical departure from previous European emissions Regulations, the draft Euro 7 Regulation proposes the introduction of limits on the particulate emissions from sources other than the exhaust system, i.e. from the brakes and tyres fitted to the vehicle. Currently, there are no Regulations which cover the measurement of particulate emissions from brakes or from tyres. However, the draft Regulation does empower the European to develop suitable test procedures and Implementing Regulations on these topics, referencing any work undertaken under the auspices of the United Nations Economic Commission for Europe (UN ECE) on these subjects, where available.

New requirements on battery durability - In another radical departure from previous European emissions Regulations, and recognising the ongoing transition from internal combustion engined vehicles to pure electric vehicles, the draft Euro 7 Regulation proposes the introduction of requirements on the durability of traction batteries for pure electric vehicles and for hybrid electric vehicles which are capable of off vehicle charging. The test procedures for determining the durability of the traction battery will be based on those specified in United Nations Economic Commission for Europe (UN ECE) Global Technical Regulation (GTR) No. 22, and the Euro 7 Regulation will specify minimum performance requirements that the traction battery must comply with after prescribed time period/distance covered. For instance, it is proposed that, after 5 years or 100,000km, the energy storage capacity of the traction battery for a pure electric M1 category vehicle must be at least 80%, compared to the energy capacity of the battery when new.

Exemptions and relaxations for small volume manufacturers -To accommodate small volume manufacturers, the European Commission have included some clauses in the draft Euro 7 Regulation to reduce the burden on them. All "small volume manufacturers" are allowed to substitute certain tests with declarations of conformity and are not required to carry out Conformity of Production emissions tests on their vehicles. However, vehicles produced by "small volume manufacturers" will still be subject to in service conformity and market surveillance emissions testing. “Ultra small volume manufacturers" are permitted to carry out their emissions testing in an emissions test laboratory, rather than conducting the tests on the road. However, the drive cycles used must be random real world drive cycles. There are also some relaxations to the mandatory introduction dates applicable to small volume manufacturers (see below),

Mandatory compliance dates - Unlike most other EU Regulations relating to vehicle type approval, the draft Euro 7 Regulation does not specify a date from which new types of vehicle must comply with the new requirements. The draft Regulation only specifies dates from which new vehicles can no longer be first registered if they do not comply with the Euro 7 emissions requirements.

For M1 and N1 category vehicles, the proposed date from which all new vehicles must comply with the Euro 7 emissions requirements is July 1, 2025. However, for small volume manufacturers, this date is delayed until July 1, 2030.

For M2, M3, N2 and N3 category vehicles, the proposed date from which all new vehicles must comply with the Euro 7 emissions requirements is July 1, 2027. However, for small volume manufacturers, this date is delayed until July 1, 2031.