Draft Updates to the EU Regulation on Light Duty Vehicle Emissions Published
Over the past few years, the European Commission have been working on the development of a new set of "Euro 7" emissions requirements, which are proposed to become mandatory for new passenger cars and light commercial vehicles at some point in the future. However, the European Commission have determined that, prior to the introduction of the Euro 7 light duty vehicle emissions requirements, it is necessary to introduce one further set of amendments to the existing Euro 6 light duty vehicle emissions requirements.
The amendments to the Euro 6 light duty vehicle emissions requirements being proposed by the European Commission, which are referred to as "Euro 6e", are mostly refinements and clarifications to reflect technical development and experience gained in the application of the existing "Euro 6d" requirements. However, there are some amendments included in the "Euro 6e" proposal which have the effect of increasing the stringency of the applicable requirements.
A draft version of the EU Regulation amending (EU) 2017/1151 to introduce the proposed "Euro 6e" light duty vehicle emissions requirements was published on the European Commission’s "Better Regulation" web site on May 23, 2022 for public consultation, with the reference Ares(2022)3868187. Due to the large number of proposed amendments included in this draft Amending Regulation, it is not possible to detail all of them within this article. However, the following is a brief summary of some of the key amendments proposed within the draft Amending Regulation:
Mandatory fitment of onboard fuel consumption measuring (OBFCM) devices to N2 category vehicles - Under the current "Euro 6d" light duty vehicle emissions requirements, the fitment of an onboard fuel consumption measuring (OBFCM) device is mandatory for M1 and N1 category vehicles. Due to the fact that it is permissible to obtain type approval to (EU) 2017/1151 for certain N2 category vehicles (i.e. goods vehicles with a maximum laden mass exceeding 3,500kg, but not exceeding 12,000kg), it is proposed that the fitment of OBFCM devices should also become mandatory for N2 category vehicles which obtain type approval via this route.
Auxiliary emission strategy (AES) activation "flag" - To make it easier to identify whether a vehicle under test is operating under an auxiliary emission strategy (AES), the draft Amending Regulation requires the addition of an "AES flag" in the vehicle’s onboard diagnostic (OBD) system. This "AES flag" must be activated whenever the vehicle is utilising an auxiliary emission strategy (AES), rather than the base emission strategy (BES), and it must be possible read this status of this "AES flag" through the onboard diagnostic (OBD) port. Where the vehicle has more than one AES, this "AES flag" must identify which AES is in operation.
Formal documentation package for BES and AES - In addition to the currently required extended documentation package, which contains detailed information regarding the base emission strategy (BES) and any auxiliary emissions strategies (AES), it is proposed to also require a formal documentation package on BES and AES. This formal documentation package would only contain basic details regarding the BES and AES. However, unlike the extended documentation package, the formal documentation package would be made available to all Type Approval Authorities, Technical Services, Market Surveillance Authorities, third parties carrying out conformity testing and the European Commission upon request.
Implementation of UN ECE Regulation No. 154 - During the development of UN ECE Regulation No. 154 on the Worldwide Harmonised Light Duty Test Procedure (WLTP), a number of revisions to the WLTP methodology were introduced to reflect the latest technical developments and experience gained in the early application of the WLTP testing requirements. The European Commission are keen for these important revisions to be implemented as part of the Euro 6e requirements. To achieve this without having to transpose each of the revisions into the relevant Annexes to (EU) 2017/1151, the draft Amending Regulation proposes to delete the WLTP testing requirements from the Annexes to (EU) 2017/1151 and replace them with references to UN ECE Regulation No. 154.
Revisions to the real driving emissions (RDE) requirements - UN ECE are currently in the process of developing a new UN ECE Regulation on real driving emissions (RDE) and, as part of this work, a number of revisions to the RDE methodology have been identified to clarify and simplify their interpretation and application. Because the European Commission are keen for these important revisions to be implemented as part of the Euro 6e requirements, the draft Amending Regulation includes proposed amendments to Annex IIIA of (EU) 2017/1151 to align its requirements with those specified in the draft UN ECE Regulation on RDE.
Reduced Conformity Factors for RDE testing - Based on reviews of the latest available data on the performance of portable emissions measuring systems (PEMS) carried out by the Joint Research Centre (JRC), the European Commission are proposing to reduce the "Conformity Factors" applied to RDE test results. For nitrogen oxide (NOx) results, it is proposed to reduce the Conformity Factor from 1.43 to 1.10. For particulate number (PN), it is proposed to reduce the Conformity Factor from 1.50 to 1.34. It is also worth noting that, in the draft Amending Regulation, these factors are referred to as "PEMS margins" rather than "Conformity Factors".
Revised Utility Factors for plug-in hybrid electric vehicles - Noting that recent studies into the real world fuel consumption and CO2 emissions performance of plug-in hybrid electric vehicles have identified significant differences between the "type approval" values and those achieved in the real world, the European Commission are proposing some revisions to the Utility Factors applied to such vehicles during their type approval. (Note: The Utility Factor is essentially an estimate of the expected proportion of driving that will be undertaken in "charge depleting" and "charge sustaining" modes when the vehicle is in normal use, taking into account how frequently the vehicle is expected to be recharged from the mains.) It is proposed that the Utility Factors are revised in two phases. New Utility Factor calculation formulae are included in the draft Amending Regulation for each phase. However, the European Commission have reserved the right to modify these formulae ahead of their mandatory introduction based on real world fuel consumption and CO2 emissions data which becomes available to them prior to those dates.
With regard to introduction dates, unlike previous EU Regulations on light duty vehicle emissions, this draft Amending Regulation does not specify different introduction dates based on vehicle category and Class. Instead, it is proposed that compliance with the Euro 6e requirements becomes mandatory on the same dates for all applicable categories of vehicle, i.e. M and N.
Compliance with the majority of the Euro 6e requirements, including the reduced Conformity Factors for RDE testing and the mandatory fitment of OBFCM devices for N2 category vehicles, becomes mandatory from September 1, 2023 for new types of vehicle and from September 1, 2024 for all new vehicles.
Compliance with the "AES flag" requirement, RDE testing at expanded ambient temperature conditions and the first phase of the revised Utility Factor calculation requirements becomes mandatory from January 1, 2025 for new types of vehicle and from January 1, 2026 for all new vehicles.
Compliance with the second phase of the revised Utility Factor calculation requirements becomes mandatory from January 1, 2027 for new types of vehicle and from January 1, 2028 for all new vehicles.