Subject: ACEA proposal for Euro 6 OBD and Euro 6 PN limit for gasoline direct injection engines.

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1 Subject: for Euro 6 OBD and Euro 6 PN limit for gasoline direct injection engines. Amendments to Regulations 715/007 (1) Regulation 566/011 (3) and 69/008 (), as amended by Note: ACEA s initial comments on OBD are available on the website of the TCMV held on 17 th June 011 (4). This new document deals with both Euro 6 OBD threshold limits and the PN limit for gasoline direct injection engines, two remaining and important issues which must be discussed, agreed and adopted as a package before the end of this year. It is based on document (5) which was discussed at TCMV on 17 th June 011 under agenda item 9. General summary: ACEA urges the legislators to quickly complete both the OBD threshold limits and the PN limit for gasoline direct injection engines, both of which are needed for Euro 6 approvals that are mandatory from the dates given in Article 10(4) and 10(5) of Regulation 715/007. The Commission should make a proposal covering both of these issues as soon as possible and the TCMV should vote on the proposal by the end of this year, at the latest. In making such a proposal, it is recognised that the proposal for the gasoline engine PN limit and the OBD threshold limits may be made in two parts an initial set of limits to apply immediately for Euro 6 approvals and a further reflection on those limits via a full and proper impact assessment conducted in a timely manner to determine if a further reductions are technically feasible and necessary. Such an assessment and adoption and entry into force of any necessary legislation should result in industry having at least 4 years lead-time before any new measures were to apply. In addition, ACEA urges the member states and the Commission to decide that all of the open issues regarding future environmental requirements in Euro 6 (and other Regulations) which still remain to be discussed and agreed, either through co-decision or comitology must, as far as possible, be applied from a common date framework in the future and with sufficient industry leadtime. In this respect the current practice of granting vehicles of category N1 classes II and III and category N an extra one year for meeting future emission requirements should be maintained. Moreover, the Commission as a major stakeholder in the UN-ECE WLTP program must, by all means, ensure the consistency between the application dates of the new WLTP and of future new EU Regulations. Industry cannot again face the complicated situation of Euro 5. It is against the principles of better regulation established and supported through CARS1. (1) () (3) (4) (5) Regulation 715/007,Official Journal of the European Communities, L171, , p.1. Regulation 69/008, Official Journal of the European Communities, L199, , p.1. Regulation 566/011, Official Journal of the European Communities, L158, , p.1. See: 011/110614_acea_obdpdf/_EN_1.0_&a=d Euro 6 OTL: a proposal for discussion - discussed at MVEG on 0 th May (agenda item 03) and TCMV of 17 th June (agenda item 09).

2 Amendments to Regulation 715/007 and 69/008 for introducing the Euro 6 OBD threshold limits and the Euro 6 gasoline PN limit A. Amendments to Regulation 715/007: 1. The following paragraph 7 shall be added to Article 10: 7. The PI emission limit for number of particles referred to in Table of Annex I and the OBD limits shown in the Table in paragraph.3.4 of Annex XI shall be effective from the applicable dates set out in paragraphs 4 and 5.. Table of Annex I is replaced by the following table:

3 Reference mass (RM) kg carbon monoxide (CO) L1 total (THC) L Table Euro 6 Emission Limits nonmethane (NMHC) L3 oxides of nitrogen (NOx) L4 Limit values Combined mass of and oxides of nitrogen THC+NOx) L+L4 particulate matter (PM) L5 Number of particles (P) Category Class PI CI PI CI PI CI PI CI PI CI PI (1) CI PI (1) () CI M - All ,0/4,5 5,0/4,5 6, , N 1 I II III RM < RM < RM L6 (#/km) ,0/4,5 5,0/4,5 6, , ,0/4,5 5,0/4,5 6, , ,0/4,5 5,0/4,5 6, , N - All ,0/4,5 5,0/4,5 6, , Key: PI = Positive Ignition, CI = Compression Ignition (1) Positive ignition particulate mass and number standards shall apply only to vehicles with direct injection engines. () Any further reduction of the values in this column is pending the review outlined in Article 14(7).

4 3. The following paragraphs 9 and 10 shall be added to Article 10: 9. Subject to Article 14(7), with effect from 1 September 017, and from 1 September 018 in the case of category N1 class II and III and category N vehicles, the national authorities shall refuse, on grounds relating to emissions or fuel consumption, to grant EC type approval or national type approval for new types of vehicle which do not comply with this Regulation and its implementing measures, and in particular with the particle number limit for positive ignition direct injection engines set out in Table of Annex I and the OBD threshold limit values set out in the table in paragraph.3.3 of Annex XI. 10. Subject to Article 14(7), with effect from 1 September 018, and from 1 September 019 in the case of category N1 class II and III and category N vehicles, national authorities shall, in the case of new vehicles which do not comply with this Regulation and its implementing measures, and in particular with the particle number limit for positive ignition direct injection engines set out in Table of Annex I and the OBD threshold limit values set out in the table in paragraph.3.3 of Annex XI, consider certificates of conformity to be no longer valid for the purposes of Article 7(1) of Directive 70/156/EEC and shall, on grounds relating to emissions or fuel consumption, prohibit the registration, sale or entry into service of such vehicles. 4. The following paragraphs 7 and 8 shall be added to Article 14: 7. Understanding that exhaust aftertreatment technology to control the emission of particles from direct injection positive-ignition engines is still relatively new and unproven at a wide industrial level, especially in relation to the stability and mode of regeneration, durability, capability for OBD monitoring and effects on fuel consumption and CO, the Commission shall conduct a review of the technical feasibility, environment and health benefit and cost effectiveness of reducing the emission limit for number of particles from direct injection positive-ignition engines shown in the respective column of Table. According to the results of this review, the Commission should either confirm or make an appropriate regulatory proposal to lower the limit for number of particles from direct injection positive-ignition engines shown in the respective column of Table and/or the mandatory date of application, at least 4 years before the earlier date in Article 10(9). 8. The Commission shall conduct a review of the indicative final OBD threshold limits shown in the table in paragraph.3.3 of Annex XI. If the cost effectiveness and technical feasibility for the prescribed introduction timing is demonstrated, the Commission shall confirm their values at least 4 years before the earlier date in Article 10(9). If the cost-effectiveness or the technical feasibility for the prescribed introduction timing is not demonstrated, or the review is not completed, the Commission shall make a proposal to amend their values and/or the mandatory dates of application shown in Article 10(9) and 10(10) and adopt such a proposal at least 4 years before the earlier date in Article 10(9). In respect of presently non-quantified partial failures of a diesel particle filter and to consider any further reduction in the diesel NOx OBD threshold limit, the Commission shall, in particular, review of the technical feasibility and cost effectiveness of the diesel NOx and PM OBD threshold limits specified in the respective columns of the table in section.3.3. The review shall also assess the environmental and human health benefit and the technical feasibility of an OBD threshold limits for the number of emitted particles (PN) and of the technical feasibility of CO and NMHC OBD threshold limits ensuring a robust monitoring of the diesel oxidation catalyst (DOC) for partial failures. Depending on the results of this review the Commission should make an appropriate regulatory proposal.

5 B. Amendments to Regulation 69/008: 1. Article 4(7) is deleted.. Table 1 in section 1 of Appendix 6 to Annex I shall be replaced by the following: Table 1 Character Emissions standard OBD standard Vehicle category and class Engine Implementation date: new types Implementation date: new vehicles Last date of registration A Euro 5a Euro 5 PI, CI B Euro 5a Euro 5 M 1 to fulfil specific social needs CI (excluding M 1 G) C Euro 5a Euro 5 M 1 to fulfil specific social CI needs D Euro 5a Euro 5 II PI, CI E Euro 5a Euro 5 PI, CI F Euro 5b Euro 5 PI, CI G Euro 5b Euro 5 M 1 to fulfil specific social needs CI (excluding M 1 G) H Euro 5b Euro 5 II PI, CI I Euro 5b Euro 5 PI, CI J Euro 5b Euro 5+ PI, CI K Euro 5b Euro 5+ M 1 to fulfil specific social needs CI (excluding M 1 G) L Euro 5b Euro 5+ II PI, CI M Euro 5b Euro 5+ PI, CI N Euro 6a Euro 6- CI

6 O Euro 6a Euro 6- II CI P Euro 6a Euro 6- Q Euro 6b Euro 6- CI CI R Euro 6b Euro 6- II CI S Euro 6b Euro 6- T U V Euro 6b Euro 6b Euro 6b Euro 6- plus IUPR Euro 6- plus IUPR Euro 6- plus IUPR W Euro 6b Euro 6-1 CI CI II CI CI PI, CI X Euro 6b Euro 6-1 II PI, CI Y Euro 6b Euro 6-1 Z Euro 6c Euro 6- PI, CI PI, CI ? Euro 6c Euro 6- II PI, CI ? Euro 6c Euro 6- PI, CI Key: 'Euro 5a' emissions standard = excludes revised measurement procedure for particulates, particle number standard and flex fuel vehicle low temperature emission testing with biofuel. 'Euro 5b' emissions standard = Full Euro 5 emission requirements including revised measurement procedure for particulates, particle number standard for CI vehicles and flex fuel vehicle low temperature emission testing with biofuel. 'Euro 6a' emissions standard = excludes revised measurement procedure for particulates, particle number standard and flex fuel vehicle low temperature emission testing with biofuel. 'Euro 6b' emissions standard = Euro 6 emission requirements including revised measurement procedure for particulates, particle number standard for CI vehicles and flex fuel vehicle low temperature emission testing with biofuel. 'Euro 6c' emissions standard = Full Euro 6 emission, i.e. Euro 6b emission standard and particle number standards for PI direct injection vehicles. 'Euro 5' OBD standard = Base Euro 5 OBD requirements excluding in use performance ratio (IUPR), NOx monitoring for petrol vehicles and tightened PM threshold limits for diesel. 'Euro 5+' OBD standard = includes relaxed in use performance ratio (IUPR), NOx monitoring for petrol vehicles and tightened PM threshold limits for diesel. 'Euro 6-' OBD standard = relaxed diesel OBD threshold limits. 'Euro 6- plus IUPR' OBD standard = includes relaxed diesel OBD threshold limits and relaxed in use performance ratio (IUPR). 6

7 'Euro 6-1' OBD standard = Full Euro 6 OBD requirements according to the OBD threshold limits defined in section.3.4 of Annex XI. 'Euro 6-' OBD standard = Full Euro 6 OBD requirements according to the OBD threshold limits defined in section.3.3 of Annex XI, subject to Article 14(7)(b). 3. The following sections shall be added to Annex XI:.3.3. The OBD thresholds limits for vehicles that are type approved according to the Euro 6 emission limits set out in Table of Annex I of the Regulation (EC) No 715/007 from the dates shown in Articles 10(9) and 10(10) of Regulation (EC) 715/007 are contained in the following table. Indicative final Euro 6 OBD threshold limits (Note: the table below compares the proposal for discussion with the shown in yellow shaded) Reference mass (RW) (kg) carbon monoxide (CO) nonmethane (NMHC) oxides of nitrogen (NOx) particulates (PM) Number of particles (1) (PN) (#/km) Category Class PI CI () PI CI () PI CI PI CI PI CI M N 1 (3) N - All I RW II 1305<RW III 1760<RW All Key: PI = Positive Ignition, CI = Compression Ignition (1) The environmental benefit and feasibility of a particle number OBD threshold limit shall be assessed in line with the review foreseen in Article 14(8). () The technical feasibility of CO and NMHC thresholds ensuring a robust monitoring of the DOC for partial failures shall be assessed in line with the review foreseen in Article 14(8) In deviation from the provisions of the previous section vehicles that are type approved after the dates given in Article 10(4) and 10(5) of Regulation (EC) No 715/007 and before the respective dates given in Article 10(9) and 10(10) of the same Regulation according to the Euro 6 emission limit values set out in Table of Annex I of the same Regulation, may be type-approved according to the OBD threshold limits contained in the following table. These threshold limits shall cease to apply from the respective dates shown in Article 10(10) for new vehicles to be registered, sold or entered into service. 7

8 Preliminary Euro 6 OBD threshold limits (Note: the table below compares the proposal for discussion with the (yellow shaded) Reference mass (RW) (kg) carbon monoxide (CO) nonmethane (NMHC) oxides of nitrogen (NOx) particulates (PM) Category Class PI CI PI CI PI CI PI CI M N 1 (3) N - All I RW II 1305<RW III 1760<RW Key: PI = Positive Ignition, CI = Compression Ignition All Section.14 in Annex XI (introduced in Regulation 566/011) is replaced by the following:.14. In deviation from point of Annex 11 to UN/ECE Regulation No 83, As from 1 September 011 in the case of a particulate trap fitted to diesel engines as a separate unit or integrated into a combined emission control device and, for vehicles certified against either the OBD threshold limits shown in the table in section.3.3 or.3.4 in the case of DOC and NOx aftertreatment devices fitted to diesel engines as a separate unit or integrated into a combined emission control device, such devices shall always be monitored at least for total failure or removal if the latter resulted in exceeding the applicable emission limits. Such devices shall also be monitored for any failure that would result in exceeding the applicable OBD threshold limits. 5. Point 6. (a) of Annex XVI (introduced in Regulation 566/011) is replaced by the following: a. For the purposes of this point these situations are presumed to occur, if the applicable NOx emission limit of Table 1 of Annex I to Regulation (EC) No 715/007, multiplied by a factor of 1,5, is exceeded. For a vehicle approved to the interim Euro 6 OBD threshold limits of point.3. of Annex XI to this Regulation or the preliminary Euro 6 OBD threshold limits of point.3.4 of Annex XI to this Regulation, those situations are presumed to occur if the applicable NOx emission limit of Table of Annex I to Regulation (EC) No 715/007 is exceeded by 100 mg or more. NOx emissions during the test to demonstrate compliance with these requirements shall be not more than 0% higher than the values referred to in the first and second sentence. 8