Health impacts and social costs in Brazil of a one-year delay in P-8 standards

Since 2020, the National Association of Vehicle Manufacturers (ANFAVEA) has pressured the Federal Prosecutor’s Office to delay implementation of the newest phases of emission control regulations for heavy-duty and light-duty vehicles, known as P-8 and L-7, respectively. The government largely resisted the lobbying until recently, when it okayed delays in implementing the L-7 standards. Despite the legal uncertainty of this measure, contested by the Federal Prosecutor’s Office, the worry now is that it might grant similar delays for the P-8 standards that govern trucks and buses.

This is a good moment to consider what’s at stake with a delay. ICCT analysis shows that even a one-year delay would mean thousands of premature deaths and billions in economic damage. As the science on the health effects of air pollution becomes clearer and more sobering, the government needs to double down on efforts to clean up Brazil’s transport sector—not retreat from the effort.

Striving for clean transportation

Brazil adopted soot-free standards equivalent to Euro VI in November 2018, with implementation for new heavy-duty vehicles starting in 2022, eight years behind Europe and 12 years behind equivalent standards in the United States. The Air Pollution Control Program for Motor Vehicles (Proconve) P-8 standards are designed to reduce real-world particle emissions and NOx emissions by 90% or more compared to current P-7 standards.

The standards are needed: Accounting for only 5% of the national vehicle fleet, heavy vehicles contribute 88% of the transport sector’s emissions of fine particulate matter (PM2.5) and nitrogen oxides (NOx).  PM is the largest contributor to air quality-related health impacts, followed by ground-level ozone (O3), based on the most recent Global Burden of Disease (GBD) study. NOx emissions contribute to both by forming particles in the atmosphere, and they are a critical precursor of O3. In addition to their health impacts, these particles also have a serious climate impact. Black carbon, the largest component of diesel PM from pre-Euro VI and pre-US 2007 engines, is a short-lived climate pollutant that contributes substantial near-term climate warming. Ground-level ozone is also an important climate pollutant.

Our investigation

The ICCT analysis of the impact of a P-8 delay updates a cost-benefit analysis completed in 2016, which assessed the overall benefits of implementation of P-8 standards. It uses current local data on human and vehicle populations in Brazil, as well as the new Fast Assessment of Transportation Emissions (FATE) model, which captures premature mortality impacts associated with PM and NOx emissions. This update remains highly conservative, however: we do not consider the non-fatal disease burden (including chronic impacts such as asthma), climate impacts, or the potential fuel savings associated with the transition to P-8 standards.

The study modeled exhaust emissions under two scenarios: implementation of P-8 standards as scheduled on January 1, 2023, and with a year’s delay, until January 1, 2024. The analysis considers medium-duty trucks (MDT), heavy-duty trucks (HDT), and buses. Based on analysis of sales data and survival curve, an estimated 236,400 vehicles would be affected by the delay.

Our analysis yielded some powerful results:

Over the period of 2023 to 2050, the one-year delay in the introduction of P-8 standards would result in an excess of 890 tons of PM2.5 and 520,000 tons of NOx. For context, this is more than 50% of the estimated annual full-fleet HDV NOx emissions in 2020 and approximately 3% for PM2.5.

The additional emissions were converted into health impacts using the FATE model that the ICCT developed in collaboration with researchers at the University of Colorado Boulder and George Washington University. This model uses outputs from the Roadmap model to calculate two health metrics: premature deaths and years of life lost (YLL) due to premature mortality.

FATE uses gridded coefficients derived from GEOS-Chem to translate emissions of NOx, BC, organic carbon (OC), sulfur dioxide (SO2), ammonia (NH3), carbon monoxide (CO) and volatile organic compounds (VOCs) to population-weighted ambient PM2.5 and ozone concentrations, which can be used to assess health impact. The calculation of premature deaths and YLL follows the most recent methodology of the GBD study, taking into account projected changes in population, age distribution, and baseline disease rates.

The cumulative impact of a one-year delay in implementation of P-8 standards would be an additional 6,000 premature deaths. Table 1 shows the cumulative increase in the number of premature deaths and YLL due to a one-year delay from the P-8 standards. Increased concentrations of PM2.5 are responsible for approximately 60% of the premature deaths and 75% of the YLL, with the rest due to increased ozone concentrations. For context, these health impacts are of the same magnitude as the health impact from the total HDV fleet exhaust emissions in 2020.


Table 1. Increase in cumulative YLL and premature deaths from heavy vehicle NOX and PM2.5 exhaust emissions due to the one-year delay of P-8 standards in Brazil
Metric Pollutant Cumulative increase in health burden due to one-year delay, 2023-2050
Premature deaths PM2.5 3,500
O3 2,500
Total 6,000
YLL PM2.5 72,000
O3 37,000
Total 109,000


The costs of delay far outweigh the benefits. Moreover, costs are borne by society, while benefits accrue to private firms. With regard to societal costs, using a benefit-transfer approach to assign a monetary value to premature deaths from exposure to fine particulate matter and ozone reveals that delayed P-8 standards would cost Brazilian society USD 6.26 billion, with net costs of USD 5.92 billion.

On the other hand, manufacturers would see cost savings through delay of P-8 standards as firms sidestep advanced emission-control technologies such as diesel particulate filters, selective catalytic reduction (SCR) systems, and on-board diagnostics. Figure 1 shows the per-vehicle technology costs applied for Brazil’s transition from P-7 to P-8 standards. (Because fuel savings are an important motivator for use of variable geometry turbochargers (VGT) and high-pressure fuel systems, only 50% of the costs were assigned for those technologies.) The total costs associated with introducing the technology and the incremental operating cost of the affected vehicles would be on the order of USD 0.34 billion. If P-8 standards are delayed, these costs would be avoided and are therefore counted as a benefit to firms.


Figure of per-vehicle technology costs

Figure 1. Per-vehicle technology costs to comply with P-8 compared to P-7 standards for Brazil’s heavy-duty fleet.


The cost-benefit analysis presents a clear picture: delay in implementing the P-8 standards results in USD 18 in societal costs for everv USD 1 in benefits to firms.  Table 2 presents the costs of a one-year delay, with vehicle costs represented as savings (negative costs) and the health costs represented as costs.


Table 2. Incremental costs of the one-year delay of P-8 standards in Brazil, in billions of US$2020, assuming a 5% discount rate.
Incremental costs due to a one-year delay, over the useful life of affected vehicles, from 2023 to 2050
Cost of vehicle technology* -$0.31 billion (USD, 5% discount rate)
Operational cost
(DEF, DPF) *
-$0.03 billion (USD, 5% discount rate)
Health damage $6.26 billion (USD, 5% discount rate)
Incremental net cost $ 5.92 billion

* Costs avoided considering the delay in entering the phase.


This updated analysis throws into stark relief the impact of a potential delay of P-8 standards. Every dollar saved by manufacturers over the one-year delay corresponds to a societal health cost of $18. From a per-vehicle perspective, avoiding the incremental lifetime cost to meet P-8 standards, approximately $1,400 per vehicle, would generate approximately $25,000 in costs to human health for each P-7 vehicle sold during the delay year. And this analysis is conservative, because it does not capture all the benefits of P-8 standards, including non-fatal health impacts, climate-related impacts, and forgone fuel savings, which could drive the cost of delay substantially higher. This is no time to delay P-8 implementation. Instead, the Federal Prosecutor’s Office should stick to its implementation plan. The health of all Brazilians is at stake.



Tracking progress