Issue No. 1, 2006
JAMA Comments on the CARS 21 Final Report
In December 2005, the European Commission published its final report on ‘CARS 21-A Competitive Automotive Regulatory System for the 21st century’. Increasing the competitiveness of the European automotive industry is an extremely important issue for JAMA, which has contributed to the CARS 21 process as much as was possible. Given the far-reaching implications of the recommendations in the CARS 21 final report for JAMA members, JAMA provided the Commission with its assessment and position on a number of critical issues. These are summarised below.
Better Regulation and Simplification
Simplification and international harmonisation of automotive standards are highly desirable with the advancement of globalisation. The undertakings of the European Commission in this regard are therefore welcomed by JAMA. However, JAMA hopes to see improvements in the transparency and accountability of the comitology process in discussions on regulatory formulation in the EU.
The early formulation of Global Technical Regulations (GTRs) is an essential issue in assuring international competitiveness. JAMA expects the EU side to take an active role in advancing GTRs at WP29. In particular, JAMA anticipates Japan-EU cooperation on the early adoption of the Pedestrian Protection Directive (Phase II) proposed by the European Commission as a GTR standard.
Reduction of CO2 emissions: JAMA supports the adoption of an integrated approach that aims for further reductions of CO2 emissions through the involvement not just of auto manufacturers but all relevant stakeholders, including government and vehicle users. JAMA specifically looks forward to the early introduction of eco-driving and gear-shift indicators, since previous studies have established their beneficial role in CO2 reduction.
CO2 reduction is also dependent on the availability of high-quality fuels. Better quality fuels should therefore be supplied in accordance with the specifications of the World-Wide Fuel Charter advocated by ACEA, JAMA, the
Euro 5: JAMA members have two major concerns about the current proposal:
(i) Heavy passenger vehicles: It will be technically difficult for vehicles exceeding 2.5t in GVW to comply with the M1 criteria. JAMA therefore considers it appropriate to establish two different criteriaone for passenger vehicles up to 2.5t and another for vehicles exceeding 2.5t.
(ii) Lead times: JAMA strongly favours the introduction of enforcement dates as follows: Either 2010 or 24 months after regulatory enactment (whichever is later) for new M-class vehicles up to 2.5t; and either 2011 or 36 months after regulatory enactment (whichever is later) for new M-class vehicles exceeding 2.5t. JAMA has further requested that a lead time of one year after the enforcement dates for the aforementioned two categories of new vehicles be applied to all other vehicles.
Mobile air conditioners (MACs): A number of important concerns regarding the proposed ban of HFC-134a were communicated by JAMA but have not yet been fully addressed. These include:
i. Although CO2 systems exhibit superior performance with regard to direct emissions (refrigerant leakage), this advantage does not necessarily hold true with indirect emissions (decreased fuel economy as a result of increased power consumption by the MAC system). This fact, which is supported by preliminary data, warrants a thorough assessment of the respective systems’ global warming impact, taking into account total vehicle emissions (direct and indirect).
ii. The Commission should also clarify the economic burden resulting from the polarisation of refrigerant types. It has been noted that the use of HFC-134a as an automotive refrigerant is expected to continue outside of Europe, including
Under these circumstances, JAMA strongly urges the Commission to review the regulations banning HFC-134a in 2007, by which time the results of a quantitative test on running vehicles will be available.
Road safety technologies: JAMA hopes that a timetable will be drawn up once reliable technical performance evaluations have been concluded. The United Nations Economic Commission for Europe (UNECE) has already commenced deliberations on electronic stability control (ESC), daytime running lights (DRL) and seatbelt reminders (SBR). JAMA strongly favours conducting such holistic deliberations at the UNECE level (as opposed to the EU25 level).
Pedestrian Protection Directive Phase II: JAMA also strongly favours international harmonisation and the adoption of the Global Technical Regulation (GTR) currently under examination by the UNECE.
Trade: JAMA firmly believes that the removal of tariffs and non-tariff barriers (including zero-zero harmonisation agreements among advanced nations) in the automotive (autos and auto parts) sector, which constitutes a large percentage of global trade, will be effective in promoting not only further trade liberalisation but also enhanced competitiveness for the EU auto industry (e.g. through expanded export opportunities and greater technical innovation by virtue of the inexpensive imports of technologies from other regions).
Taxation and fiscal incentives: JAMA endorses the Commission’s policy to gradually abolish current passenger car registration taxes and transition to a system based on an annual circulation tax. It also considers it advisable, when formulating a tax base that incorporates a CO2-based element, to design a system that will advance harmonisation among EU Member States.
JAMA also fully supports the introduction of harmonised fiscal incentives to stimulate consumer demand for vehicles incorporating advanced environmental and safety technologies. In this regard, JAMA believes that such incentives should be technology-neutral and that all advanced environmental and safety technologies should be considered fairly. JAMA also believes that the coordinated introduction of such incentives to the EU is of critical importance.
Intellectual property: JAMA concurs with Recommendation No 18 on design protection and welcomes its advancement. However, it views the removal of design protection from visible spare parts as a violation of the spirit of that recommendation. JAMA is convinced that the protection of intellectual property rights in turn helps protect the safety of consumers.
The next 10 months will be very important, as measures resulting from the CARS 21 recommendations will be discussed and proposed by the Commission. It is hoped that a system will be established that ensures not only complete fairness and transparency in the process, but also the provision of opportunities whereby JAMA can convey its position and participate in relevant discussions.