EU consumer organizations asking for more realistic vehicle testing

CO2 emission values for type approval of new cars are determined under laboratory conditions. But real-world driving cannot be perfectly simulated in the laboratory; for example, in laboratory testing it is assumed that the vehicle is always driven on a flat surface, when of course in reality the earth is not flat.

Thus, type approval values will always deviate somewhat from the values drivers experience on the road. However, one would expect this “normal” deviation between type-approval and real-world emission levels to remain approximately constant over time. There is no reason to assume that people nowadays drive much differently than they did ten years ago. Yet, analysis of historical data suggests that the gap between type-approval and real-world emissions has increased dramatically over the last few years. In a study analyzing the real-world CO2 emissions of about 28,000 German car owners, ICCT found that the gap increased from about 8% in 2001 to about 21% in 2010.

A possible explanation for this development might be the flexibilities and tolerances allowed by the current vehicle test procedure. For example, a vehicle manufacturer might use very efficient tires for the actual laboratory test while knowing that this particular set of tires is rarely sold in reality with his vehicles, and that the typical tires are less efficient. By doing so, the generated CO2 emission values would be lower than what most customers find with their own vehicle. Now, it might be that a few years ago the manufacturer did not put a lot of effort into optimizing the CO2 emission levels of its vehicles, as there was no CO2 regulation for new cars in effect yet. Today the situation is very different: manufacturers in the EU have to comply with CO2 emission targets, and in case of noncompliance have to pay substantial penalties. It is quite possible that this has led to a situation in which (at least some) vehicle manufacturers are exploiting existing flexibilities and tolerances more than they used to in the past.

Earlier this week three EU consumer organizations—BEUC, FIA, and ANEC— sent a letter to the Vice-President of the European Commission demanding that the Commission act to address this growing gap. Their interest in this subject and concern, as consumer organization, is not surprising. CO2 and fuel consumption are directly linked to each other. Apart from the effect on emission levels and climate change, an increasing gap between type approval and real-world values means that “the full benefits of higher emission standards are not fully grasped by consumers, i.e. the fuel consumption reductions achieved in laboratory conditions are not translated into monetary benefits for consumers.”

In fact, at the United Nations level a revised test cycle and test procedure for light-duty vehicles is being developed. We have previously commented on shortcomings that this new cycle and procedure, the so-called Worldwide Harmonized Light Vehicles Test Procedure (WLTP), most likely will solve. However, the consumer organizations, as well as some other organizations, are concerned that the introduction of the WLTP might come too late, and might not even solve all of the existing problems with the test procedure. Thus, they call for immediately limiting the possibility of exploiting flexibilities and tolerances in the current test procedure (the NEDC), the introduction of the new test procedure by 2016 at the latest, and for own actions of the European Commission, in case the WLTP is delayed or would still not represent realistic driving conditions. They also point out “a need to significantly strengthen both compliance testing and sanctions by the authorities in case of non-compliance”, something that is highly topical at the moment, given the recent experiences in the United States that we reported on recently.

In the meantime, the ICCT is working on an update of its study on real-world fuel consumption in the EU. The new version of the report will draw upon many more data sources and is scheduled to be published in early 2013.

Vehicle testing