ACEA Position Paper: Views on proposals for Euro 7 emission standard – December 2020
The CLOVE consortium's proposals for Euro 7 presented to AGVES on 27 October 2020 are technically infeasible for vehicles with combustion engines and have not been subject to any impact assessment or peer review. Independent air quality studies show the proposed emissions limit scenarios and Real Driving Emissions (RDE) boundary conditions to be contrary to the principle of proportionality. Current Portable Emissions Measurement Systems (PEMS) devices show an absolute measurement uncertainty that is of the same order of magnitude as the proposed emissions limits, making it impossible to legally assess such limits with the necessary level of certainty during on-road testing. Although costs must be addressed later in the form of a robust impact assessment, any scenario for a future regulation considered in such an assessment must actually be credible for the assessment to have any value. The implementation of Euro 7/VII, the Green Deal, and pathways to the de-fossilisation of road transport must continue to facilitate the competitiveness of the automotive industry in Europe and its place as a globally-leading industry. The proposals for Euro 7 have not been developed with adequate levels of transparency or debate.