DRAFT MINUTES of the 101 st meeting of the Working Group on "AGRICULTURAL TRACTORS"

EUROPEAN COMMISSION INTERNAL MARKET, INDUSTRY, ENTREPRENEURSHIP AND SMEs DIRECTORATE-GENERAL Sustainable Growth and EU 2020 Sustainable Mobility and Automotive Industry Working Group on Agricultural Tractors (WGAT) Brussels, 09/07/2015 GROWTH/G/3 ESG/AV DRAFT MINUTES of the 101 st meeting of the Working Group on "AGRICULTURAL TRACTORS" Brussels, 2 nd February 2015

The meeting documents can be downloaded from CIRCABC: https://circabc.europa.eu/w/browse/ea200742-cf1d-4da0-9367-9bb388568128 Madam Chair (Mrs B. Bonvissuto, EC/DG GROW/Unit G3) welcomed the participants and went through the agenda points. 1) APPROVAL OF THE DRAFT AGENDA 01. Draft agenda The agenda was approved with the addition of a presentation by CEMA, providing with their feedback on the study on the availability of technology to apply Stage IV to NTTs. 2) APPROVAL OF THE DRAFT MINUTES OF THE 99 TH AND 100 TH MEETINGS OF THE WORKING GROUP ON AGRICULTURAL TRACTORS HELD ON 9 TH SEPTEMBER 2014 AND 17 TH OCTOBER 2014 02. Draft minutes of the 100th WGAT meeting of 17 October 2014 02. Draft minutes of the 99th WGAT meeting of 9 September 2014 The minutes of the 99 th Working Group on Agricultural Tractors (WGAT) held on 9/9/2014 were adopted. Madam Chair invited the participants to comment on the minutes of the 100 th WGAT in writing, due to their recent upload on CIRCABC. They would then be adopted during the 102 nd WGAT. 3) BRIEF UPDATE ON THE STATE OF PLAY OF DELEGATED AND IMPLEMENTING ACTS Madam Chair informed the participants on the publication dates of the delegated acts under the Regulation 167/2013, namely: - for the Regulation on Vehicle Construction Requirements (RVCR): 18/12/2014; - for the Regulation on Vehicle Braking Requirements (RVBR) and for the Regulation on Environmental and Propulsion Performance Requirements (REPPR): 23/1/2015; - for the Regulation on Vehicle Functional Safety Requirements (RVFSR): 17/2/2015. The Regulation on Administrative Requirements (RAR) was scheduled for publication on 24/2/2015 and Madam Chair expressed her estimate that the publication will be on that date. 2

4) DISCUSSION ON UPDATES OF THE IMPLEMENTING MEASURES 04. Presentation: Updates of the legislation under Regulation (EU) 167/2013 (for discussion) 04.1. Regulation RVCR Q&A list 04.8. FR presentation on ROPS for T4.1 tractors 4A) Updates of all implementing measures Mr Efrén Sánchez Galindo (ESG - EC / DG GROW / G3) presented the need for update of definitions and terminology in all implementing measures; this update would be focused on actual mass, tracks, mechanical couplings, tyres and terms related to braking of C-category vehicles. In addition, ESG informed that the references from one implementing measure to another should be corrected with the exact OJ reference after the OJ publication of RAR. CEMA requested for the correction of the double references to implementing measures and identical texts in the delegated acts RVFSR and RVBR and responded positively to the request of Mr Andreas Vosinis (AV - EC / DG GROW / G3) to CEMA to provide for precise examples of this issue. IT asked the reasons for using the actual mass in the legislation. Madam Chair replied that during the 3 rd meeting of the Technical Committee Agricultural Vehicles (TC-AV) on 16/12/2014, which voted for the RAR, the introduction of a definition for that concept was required by DK and supported by AT. Madam Chair invited the participants to thoroughly discuss on the need for that concept and on the requirements related to it. CEMA commented on this that the tyres play an important role for a tractor (various tyre combinations may be suitable for a tractor) and they significantly influence its mass. Madam Chair reiterated that the EC can consider points of view at this stage on the necessity to mention the actual mass of the vehicle for its type-approval and then to further examine whether any amendments will be introduced with respect to that. 4B) Updates on RVCR ESG informed in relation with the RVCR, that FR had requested the introduction of ROPS requirements for tractors of category T4.1; In that regard, Madam Chair asked FR whether a document, that they had communicated to EC with such requirements, should be uploaded to CIRCABC. FR replied that they would inform EC on that later on. 4C) Updates on RVFSR 04.6. Regulation RVFSR Q&A list AV presented the points that were considered for update in RVFSR: - On mechanical couplings: introduction of requirements for the drawbar; compulsory introduction of reference to UNECE Regulation 55, wherever this is necessary and possible. 3

CEMA informed that the industry would need time to assess the necessity of making compulsory the introduction of UNECE Regulation 55 reference in RVFSR. IT asked whether the EC has the intention to introduce reference to UNECE Regulation 55 in its current version or it will be first expected that requirements, accounting for the tractors particularities, be introduced in that UNECE Regulation. Madam Chair replied that there is the possibility of waiting for specific requirements for tractors to be introduced to UNECE Regulation 55 and then discuss in the WGAT the compulsory reference to the latter in RVFSR. - On lighting installation: replacement with reference to UNECE Regulation 86 after the new version prepared by AVLI group is adopted. CEMA informed that such a reference is foreseen to be possible within 2017, due to the next phases for the expected approval of the amended UNECE Regulation 86 (October 2015 in the relevant group of UNECE GRE and then adoption by WP29 in November 2015, plus the time for being in force). - On tyres: revision of requirements on tyres for special purposes might be necessary; also, the amendment of Annex I to Regulation (EU) 167/2013 to introduce requirements on tyres applicable to C-category tractors. CEMA informed that there are two additional UNECE Regulations on tyres trailers and that information on them would be provided. - On VIN marking: point 4.3 of Annex XX should be drafted as point 4.4. The latter was agreed after an IT request agreed on the 100 th WGAT. With no comments by the participants, this point was concluded. 4D) Updates on RVBR 04.5. Regulation RVBR Q&A list AV informed that terms related to braking of C-category vehicles as well as definitions in the Regulation should be reviewed. In addition, AV informed that guidelines for drafting test reports, addressed to the technical services, could be considered to facilitate the work of the latter. Madam Chair commented that CEMA had principally asked for these guidelines and invited the participants to comment on whether such guidelines would indeed be necessary. 4E) Updates on REPPR 04.3. Regulation REPPR Q&A list AV informed that two amendments for the acceptance as equivalent to the type approvals granted in accordance to Regulation (EU) 167/2013 and REPPR were under consideration by EC: 4

a) type-approvals according to Directive 97/68/EC; b) type-approvals approvals according to 04 series of amendments of UNECE R96. FI asked for the need of the amendment mentioned in a), commenting also that Annex IV of REPPR mentions Directive 97/68/EC. EUROMOT responded to FI that this amendment concerned the introduction of a full equivalence of engine type-approvals under Directive 97/68/EC with engine typeapprovals granted under the REPPR; these provisions were different than the references to the requirements of Directive 97/68/EC already present in the REPPR. IT supported the point of view expressed by EUROMOT. Madam Chair concluded the discussion on REPPR by commenting that the EC will consider introducing those amendments depending on the feedback from MS it would get. 4F) Updates on Regulation (EU) 167/2013 04.4. Regulation (EU) 167/2013 Q&A list 04.7. Presentation: Updates of the legislation under Regulation (EU) 167/2013 (AT comments for discussion) AV informed that amendments of two kinds would be considered for Annex I to Regulation (EU) 167/2013, as proposed by AT: a) Drafting corrections in the following lines of the table in that Annex, because the corresponding requirements have been updated in the RVFSR: - Line 6, speedometer; - Line 9, rear view mirrors: requirements compulsory for T3a; - Line 17, heating system: requirements compulsory for T3b with closed cabin; - Line 30, tyres: requirements compulsory for C category; - Line 34, Mechanical couplings: requirements compulsory for T3b. b) Introduction of new requirements in the suitable delegated acts, if necessary, and the simultaneous correction of the corresponding line in Annex I. The two following lines are concerned: - Line 23, ballast masses: consider to include T3 category; - Line 41, passenger seats for T2 tractors: already amended by RVCR. Madam Chair commented that the EC had to decide on the legal grounds for amending Annex I: if the topic subject of amendment was already included in Annex I, it would be possible to amend it trough delegated acts. Otherwise, further legal assessment should be needed. CEMA requested for the more precise timeline for eventual amendments, provided that the next WGAT is in October 2015. CEMA expressed the concern whether the time till end of 2015 would be enough for the considered amendments. Madam Chair responded that the EC might consider arranging another WGAT in June 2015 and invited the participants to inform the EC on the points that they consider as most urgent. 5

IT expressed the importance of finalising a set of amendments by end 2015 and to publish them within 2016. Furthermore, IT asked whether this was possible for the EC. Madam Chair commented that we may attempt to present a first draft with the amendments on the most urgent matters in a WGAT on October 2015. FI requested whether the introduction of tyre requirements to C-category vehicles means that the tracks could be fully replaced by tyres and whether any such intention existed from the EC. Madam Chair responded that this topic would be required for C-category vehicles, as those vehicles fitted with a combination of wheels and endless tracks fall under this category in accordance with Article 4(9) of Regulation (EU) 167/2013. FI informed that the new requirements are clear to them and there is no further concern if a C-category vehicle is considered to have always at least one axle with tracks. 4G) Updates on RAR 04.2. Regulation RAR Q&A list ESG informed that it had been requested by ETRTO to review the information document for the EU type-approval of tyres as a component and that the EC was willing to carry it out. He also indicated that the Excel list with the proposals for amendment of editorial mistakes, proposed mainly by AT up to then, had already been uploaded in CIRCABC. With no comments by the participants, Madam Chair concluded this point. 5) PRESENTATION OF THE STUDY ASSESSMENT ON THE AVAILABILITY OF TECHNOLOGY ALLOWING VEHICLES OF CATEGORIES T2, T4.1 AND C2 TO FULFIL STAGE IV EMISSION LIMITS ; 05. Presentation: Assessment on the availability of technology allowing vehicles of categories T2, T4.1 and C2 to fulfil Stage IV emission limits 05.1. CEMA comments on the feasibility of Stage IV for narrow tractors Maciej Szymanski (MSZ EC/DG GROW/Unit G3) presented the work (divided in four tasks) and conclusions of the above mentioned study. The main points of the presentation were: - The study objective was to assess the technical readiness of narrow track tractors (NTTs) to meet the engine pollutant emissions Stage IV. - Manufacturers expressed their concerns about the decrease of manoeuvrability in narrow spaced crops and on the reduced field of vision on tractors fitted with Stage IV engines; they were also worried about the high costs of development and production implementation and for the tight deadlines for the Stage IV implementation. - Task 1: Tractors data from literature and interested parties contacts have been provided on the technical characteristics per category of NTT, fleet number per category (major 6

part is T2, followed by C2 and T4.1) and numbers of usage hours per tear or lifespan (average usage is double for T2 than for C2 and T4.1 and the lifespan is 10 20 years for each category). - Task 3: Assessment of technological solutions, which has pointed out the Selective Catalytic Reduction (SCR) as existing technology to reduce NOx from CI engines in Stage IV. Nevertheless, the design of necessary equipment for suitable size positioning and the reduction of the SCR substrate size (already done on T1 and heavy duty vehicles) are necessary for its application to NTTs. Other state-of-the-art solutions are: a) SCR-based emissions after treatment (EAT) for Stage IIIB already applied to T1 and also for Stage IV to tractors with engine power greater than 75 kw and for Stage IIIB of T1 tractors with engine power 56 75 kw. b) Diesel Oxidation Catalyst (DOC), already in use on NTTs. c) High Pressure Common Rail (HPCR) with pressure up to 1 kbar is ready on NTTs and towards readiness for them with pressure 2 3 kbar for Stage IV. Under development technology includes a) Catalysed Soot Filters (CSF) as alternative to DOC and Diesel Particulate Filter (DPF). b) SCR on Filter (SCRonF) for Stage IV. c) Combination cans and changing substrate shape, already available on Non-Road Mobile Machinery and appearing on tractors. - Task 2: Assessment of the technical requirements on tractors for compliance with Stage IV Various positions on NTTs have been assessed for the installation the necessary emissions after treatment equipment for compliance with Stage IV. For T2, the positions above the engine, at its side in front of the cabin and at its side above the wheel have been proposed as possible ones. For C2, the positions above the tracks, above the engine and at the front of the tractor have been proposed. For T4.1, there are various possible EAT locations, due to their design flexibility, with most probable location on or around the ROPS behind the operator s cabin. - Task 4: Environmental impact If vehicles fitted with Stage IIIB engines would continue to be placed on the market, the estimated cumulative value of NOx in EU is 14,000 tonnes by 2021 and 65,000 tonnes by 2025. Although NTTs contribute less than 1% to current EU NOx emissions, local effects are a burden for agricultural areas due to low NOx dispersion in the air. In conclusion: 7

- The Stage IV is technically feasible on NTTs. - Necessary powertrain and after treatment technologies are already available on other comparable vehicles. - Redesign might be necessary to accommodate mid-mounted implements and keep visibility and availability, but market forces will ease decreasing the size of SCR, either through choice by the manufacturers of fitment locations following user's needs or through offer of multiple optional fitment locations. Therefore, a closer collaboration between tractor and engine manufacturers from the earliest stages of the tractor design and taking into consideration different exhaust systems and emission abatement designs under a single engine type-approval could be anticipated. IT requested some more time to go through the published NTT study. In addition, IT commented that: - The representative engine taken in the study was not the one used in reality for NTTs. - 1,800 mm is the working width usually for NTTs, i.e. smaller than the one considered in the study. - Stage V for NTTs should be introduced much later than Stage V for NRMM ones (i.e. after 2019, depending on the co-legislators input for NRMM), so that small tractors' manufacturers have enough time lead to adapt to the new engine emissions. Madame Chair replied that the scope of the study was in line with the mandate provided to the Commission by co-legislators. MSZ commented that the power range of the engines considered in the study was in accordance with the engine power categories that can be dealt with according to the engine power under Stage IV. Concerning the working space width, there has been no feedback / input on that sense by the stakeholders during the study. Feedback by CEMA on the above mentioned NTT study CEMA provided a presentation with their feedback on the above mentioned NTT study, with the following main points: - CEMA considers application of Stage IV to NTTs more problematic for industry and users. - The subsequent Stage V looks to have an unfeasible timeline for NTTs. Therefore, a clear and feasible roadmap for the NTTs emissions has to be provided for the next 5 8 years. - Narrow tractors themselves need high manoeuvrability, limited height and adapted use of implements to operate correctly in the fields. - The installation positions for the SCR equipment proposed by the study are either impossible or present major setbacks: at the side of the tractor, problems arise with ROPS, visibility and installation of implements; the space above the engine is already 8

occupied by the Stage IIIB equipment; at the front of the tractor, it is too close to the cooling pack, whilst reduction of manoeuvrability also occurs. - The study recognises that a penalty on the functionality will exist to meet Stage IV requirements. This penalty will remain and will even trigger a change in the current farming techniques. NTTs already face such penalty due to Stage IIIB, likely to increase with the introduction of Stage IV. - CEMA believes that the adverse effects to NTTs are worse than presented by the study: multiple fitment locations are not economically viable and the engines produced for NTTs yearly are not enough to justify design, test and production of specific EAT devices by engine manufacturers. - The report does not differentiate between the bigger and the narrowest NTTs. - The resulting timetable for the introduction of Stage IV is not feasible, because that Stage duration is significantly lower than the typical 3 years from one stage to another. - Assuming that no Stage IV is introduced and thus Stage V follows immediately after Stage IIIB, then NTTs for Stage V should be available well before the introduction of Stage V engines. This is not feasible due to the introduction of NTTs by many manufacturers just before the emissions Stage introduction and that NRMM would benefit from a staged transition scheme. - From the environmental point of view, the NOx low dispersion makes the pollution local and still the 2014 Air Quality Report of the European Environmental Agency recognises that only one station in the whole EU exceeded the NOx limits. In addition, the current EU legislation will deliver further NOx emissions in the future. Also, the increased PM emissions are not considered by the study; on the other hand, the NOx emissions are overestimated, considering as mean engine power 111,5 kw, whilst the maximum engine power in the market is 80 kw for NTTs. - Concerning the users, they have to invest in new vehicles to meet Stage IV emission limits and at the same time be confronted with reduced functionality of the NTT. This limitation, together with an unfeasible timetable for emissions, would have a negative impact to economic growth. In the study report it is not clearly mentioned whether the users opinion has been sought. - In conclusion, major challenges for industry remain, negative consequences for farmers are present for usability of NTTs and farming techniques, adverse economic consequences occur with an unfeasible timetable, whilst the environmental advantage is minimal. With no comments from the participants, MSZ commented on the CEMA positions that some penalties can occur, but due to the maturity of the current technology, this is not a stopping factor for the implementation of Stage IV on NTTs. Madame Chair commented that in the stakeholders meeting, organised during the study, all involved parties were invited, including farmers' associations. The study concluded that technology for Stage IV is available. However, the Commission understands that the industry needs time for the Stage V and it is open to consider a transitional scheme. 9

IT asked whether a transitional scheme, dedicated to the introduction of Stage V to NTTs, will be provided, similar to the one already existing for Stage V in the general considerations of NRMM. EUROMOT asked under which legislative instrument could be introduced the dedicated Stage V transition scheme for NTTs. Madame Chair replied that this issue should be further looked at. IT asked further whether we could pass directly from Stage IIIB to Stage V. Madame Chair replied that several options could be considered but there are limits to what the Commission can do on the basis of its empowerments. 6) A.O.B. There were no subjects introduced under this point. Consequently, Madame Chair concluded the WGAT by informing the participants that the EC will propose by end of April 2015 a date for the June 2015 WGAT meeting. Annex I: Attendance List 10

ANNEX I 101 st meeting of the Working Group on "AGRICULTURAL TRACTORS", held in Brussels on 2 nd February 2015 ATTENDANCE LIST MEMBER STATES Bulgaria Croatia Finland France Milena Atanasova Tonko Županić Timo Kärkäinen Thierry Langle Jean-Pierre Rochette Italy Latvia Malta Portugal Slovakia Spain Antonio Erario Adris Bumbuls Cathryn Camilleri Sandra Candeias Dušan Štofik José Luís García Ignacio Ruiz OBSERVERS Norway Hagerupsen Asbjorn ORGANISATIONS AND ASSOCIATIONS ATVEA CEETTAR CEMA Thomas Linget Kjeldal Mogens Ulrich Adam Ivo Hostens Keith Hawken Tim Hamers Stefano Pagliarani CLEPA Thomas Kuhn 11

EFFAT EUROMOT OECD UNACOMA Sébastian Dittmar Paul Williams José Brambila Luca de Rinaldis EUROPEAN COMMISSION DG ENTR-B-4 Barbara Bonvissuto (Chair) Renate Repplinger Hach (Legal Officer) Efrén Sánchez Galindo (Legislative Officer) Maciej Szymanski (Policy Officer) Andreas Vosinis (Legislative Officer) Catherine Matthews (Secretariat) 12