Vehicle registration documents and vehicle registration data (Roadworthiness package)

The Transport Alliance for Clean Air, a group of companies and associations from the transport and mobility space that shares a common vision for clean air in the EU, welcomes the opportunity to contribute to the European Commissions consultation on the proposed revision of the EUs roadworthiness package.

As AVL, we strongly support the positive approaches in the draft on the subject of Remote Emission Sensing. AVL refers to many years of experience in the field of emission measurement in the context of vehicle development, calibration, type approval, PEMS testing and periodic technical inspections.

Feedback to COM(2025)180 concerning amendments to Directive 2014/45/EU on periodic roadworthiness tests. CLEPA recommends opting for a Regulation instead of a Directive to secure a harmonised legal framework across the EU is effectively and consistently applied, to reduce operating costs for all operators and users, as well as preserve consistency of test parameters and equipment to those used in type-approval.

The European Express Association (EEA), representing the interests of the express industry in Europe, welcomes the opportunity to contribute to the call for evidence on the revision of the Road Worthiness Package. Members of the EEA, DHL, FedEx, and UPS, remain dedicated to the safety of employees and wider civil society when fulfilling transport operations as part of key European supply chains.

July 2025 DHL Group Feedback on European Commission Proposed Revision of the Roadworthiness Package DHL Group plays a pivotal role within the supply chains of Europe, providing logistic services across a variety of transportation modes via a variety of business models.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The FIA European Bureau welcomes the Commissions aim to enhance road safety and environmental performance through the Roadworthiness Package. However, we stress the importance of maintaining affordability, transparency, and fairness for citizens, and considering the self-diagnostic capabilities of modern vehicles as well as their suitability to replace additional tests and measurements.

MAHLE is a leading international development partner and supplier to the automotive industry with customers in both passenger car and commercial vehicle sectors. Through our division Lifecycle and Mobility we provide approximately 150 million spare parts globally and develop service equipment utilized by workshops in vehicle repair and maintenance as well as roadworthiness inspections.

The Japan Automobile Manufacturers Association, Inc. (JAMA) is a non-profit industry organisation comprising Japans fourteen manufacturers of passenger cars, light commercial vehicles, trucks, buses, and motorcycles. Please find attached JAMA's contribution to the request for feedback on the revision of the EU's roadworthiness package.

About SMaT SMaT Association of owners and technicians of PTIs, ECs, OCHs is a professional organization associating authorized persons (owners) of PTIs, PTIs technicians and administrative staff in the Slovak Republic.

CONSIGLIO NAZIONALE DEI PERITI INDUSTRIALI E DEI PERITI INDUSTRIALI LAUREATI P R E S S O I L M I NI S T E R O DE L L A G I US T I Z I A Proposta di Emendamenti alla Direttiva COM(2025) 180 final Valorizzazione delle competenze tecniche dei liberi professionisti nell’ambito della sicurezza stradale Relazione esplicativa La presente proposta intende chiarire e rafforzare il contributo dei liberi professionisti…

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FIGIEFA, the European Association of independent wholesalers & retailers of automotive parts and components, welcomes the EU Commissions initiative to revise the EUs roadworthiness package and acknowledge the importance of ensuring that vehicles remain safe, environmentally compliant, and fit for purpose throughout their lifetime.

The Spanish Association of Automobile and Truck Manufacturers (ANFAC) considers that European Commissions Roadworthiness Package (RWP) aims to enhance road safety and environmental standards through updated regulations on Periodic Technical Inspections (PTI), Roadside Inspections (RSI), and vehicle registration.

(5) Ref.1Ares(2025)6338433 - 04/08/2025 FEEDBACK FOR THE EUROPEAN COMMISION’S PROPOSAL FOR THE ROADWOTRHINESS PACKAGE DIRECTIVES Suomen Motoristit ry (SMOTO), a Finnish motorcyclists' association, provides feedback on the European Commission's proposal to update the roadworthiness package directives.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Automobile Manufacturers' Association (ACEA) represents Europes 16 major Car, Van, Truck and Bus manufacturers. Technical defects on vehicles are related to less than 1% of fatalities, as a study from fka (RWTH Technical University Aachen) shows: https://www.acea.auto/news/less-than-1-of-accidents-caused-by-technical-defects-confirms-new-study/ Each potential measure should be evaluated with a…

In this document, the General Council of Industrial Technical Engineering (COGITI) makes its comments on the proposal for a directive of the European Parliament and of the Council amending Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers and Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union, with…

Filed in Spanish · English published by the European Commission

AFIBA welcomes the EU Commissions proposal for the revision of the Roadworthiness Package. In the opinion of AFIBA, the proposal will enhance road safety, promote environmental protection, and facilitate the mutual exchange of information among member states. The attached document is AFIBAs key position and recommendations with the intention to support the initiative to achieve the targets of the proposal

I support this amendment. Motorcycles (MCs) are now still exempt from annual testing, while research shows they are both extremely dangerous ànd produce disproportionate amounts of noise and air pollution*. The two included graphics with external (environmental) costs, say it all.

As AVL DiTEST we strongly support the revision of the EU Roadworthiness package for road safety and vehicles environmental performance. We would like to point out that various testing procedures require access to vehicle data. Therefore, regulated and harmonized access to vehicle data is needed (e.g., EOBD, VIN).

Department of Public Affairs and Communication Directive Contrôle Technique Commentaires et recommandations de Mobilians Juillet 2025 La Commission européenne a présenté le 24 avril 2025 le paquet « Contrôle technique » qui propose la révision de deux directives : 1) La directive (2014/45/UE) relative au contrôle technique périodique des véhicules à moteur et de leur remoques ; 2) La directive (2014/47/UE) relative…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

— Please note the attached document – We welcome the Commission’s aim to align the EU Directive on roadworthiness tests with its state of development. At the same time, however, we see significant challenges in terms of practical implementation, which still need to be addressed until the Directive is adopted.

Filed in German · English published by the European Commission

Airyx is a technology start-up that participated in the EU Horizon 2020 CARES (City Air Remote Emission Sensing) Research & Innovation programme. We are the primary commercial developer of the Plume Chasing (PC) Remote Emission Sensing (RES) technique. This method is primarily used by regulatory and enforcement authorities to detect high NOx heavy-duty vehicles (HDVs) caused by tampering or malfunction.

The Gesellschaft für Technischeüberwachung mbH (GTÜ) explicitly welcomes the recast of Directive 2014/45/EU as it contributes to the modernisation, harmonisation and efficiency of roadworthiness testing in the EU.

Filed in German · English published by the European Commission

As AVL DiTEST we strongly support the revision of the EU Roadworthiness package for road safety and vehicles environmental performance. We would like to point out that various testing procedures require access to vehicle data. Therefore, regulated and harmonized access to vehicle data is needed (e.g., EOBD, VIN).

Mobivia, a European leader in automotive maintenance and repair with Norauto, ATU, Midas and Carter-Cash brands, supports the European Commissions efforts to modernize and harmonize vehicle inspection rules across the EU. The proposed reforms are essential to improve road safety, reduce emissions, and ensure inspections keep pace with new vehicle technologies such as electric vehicles and ADAS.

ASA welcomes the EU Commissions proposal for the revision of the Roadworthiness Package. In the opinion of ASA, the proposal will enhance road safety, promote environmental protection, and facilitate the mutual exchange of information among member states. The following points are ASA´s key positions and recommendations with the intention to support the initiative to achieve the targets of the proposal: 1.

INTERNATIONAL MOTOR VEHICLE INSPECTION COMMITTEE CITA Feedback to public consultation on the revision of the Roadworthiness Package The European Commission published (24th of April 2025) the proposal to amend the Roadworthiness Package, in particular the Directives on periodic roadworthiness tests for motor vehicles and trailers (2014/45/EU), on registration documents (2014/46/EU) and on roadside inspections…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Airyx is a technology start-up that participated in the EU Horizon 2020 CARES (City Air Remote Emission Sensing) Research & Innovation programme. We are the primary commercial developer of the Plume Chasing (PC) Remote Emission Sensing (RES) technique. This method is primarily used by regulatory and enforcement authorities to detect high NOx heavy-duty vehicles (HDVs) caused by tampering or malfunction.

Strong support The researchers involved in the Horizon 2020 project CARES strongly support an enhanced emission screening and inspection regime as proposed for the revision of the EUs roadworthiness package. CARES was a multi-year research project funded under the European Union Horizon 2020 Research and Innovation programme, which ran from May 2019 to April 2023 (https://cares-project.eu/).

ADAC e.V. is Europe’s largest car club and the world’s second largest car club, with currently more than 22 million members. The four letters ADAC represent an association that provides 24/7 assistance, protection and advice to its members and acts as an interest representative on all themes related to mobility.

Filed in German · English published by the European Commission

TÜV-Verband represents the political and technical interests of the TÜV organizations, which together employ around 30,000 highly qualified professionals in the automotive sector and are active in approximately 70 countries worldwide. As independent, neutral, and sovereignly recognized technical services, the TÜV organizations and their experts have been instrumental in advancing vehicle and road safety since 1910.

Dear Sirs, Citizen initiative Stop Verkeerslawaai Amersfoort (strop traffic noise Amersfoort) is a widely supported initiative to reduce excessive traffic noise. We are based in the Dutch city of Amersfoort. Our purpose is to create awareness and trigger action against drivers that intentionally cause extreme traffic noise by means of vehicle modifications and excessive behavior.

ANFIA – Associazione Nazionale Filiera Industria Automobilistica (Associazione Nazionale Filiera Industria Automobilistica), representing the Italian vehicle and component manufacturing sector, intends to express its support for this by fully agreeing with the proposed action that gives greater attention to the conditions of efficiency and safety of vehicles on the road.

Filed in Italian · English published by the European Commission

The International Council on Clean Transportation (ICCT) supports the proposed enhancements to the EUs roadworthiness package, particularly the strengthened emission screening and inspection program. Excess pollutant and noise emissions from on-road vehicles present a serious public health and economic burden across the EU.

ÖAMTC welcomes the efforts to modernize the EU Directive on the technical inspection but highlights specific operational and technical challenges in its implementation. Key aspects include practicality, efficiency, and balance in inspection methods. It is also essential to consider existing structures and systems.

E-Mobility Europe welcomes the European Commission proposals to amend the Roadworthiness Package, which provides updated rules for safer roads, less air pollution, and digital vehicle documents. The two amended Directives rightly aim to adapt to new technologies and ensure safety and environmental standards, as the revisions will introduce requirements such as conditions for specific testing methods for electric…

With around 48,000 employees in around 60 countries on five continents DEKRA is one of the worlds largest independent and neutral automotive expert organization active in the testing, inspection, and certification ecosystem. Our vehicle and road safety experts have been at the forefront of advances in automotive developments since DEKRA was founded in 1925, as the German Vehicle Inspection Association.

Bologna, 18 July 2025 Ducati Motor Holding S.p.A. feedback on the revision of the EU’s roadworthiness package Ducati Motor Holding S.p.A. welcomes the opportunity given by the European Commission to express its views with regards to the revision of the EU’s roadworthiness package.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Remote Sensing Devices (RSD) are instruments that enable large-scale, real-time measurement of vehicle emissions in real-world, real-driving conditions. It is already used operationally in many countries worldwide, with exceptional results.

E-Mobility Europe welcomes the European Commission proposals to amend the Roadworthiness Package, which provides updated rules for safer roads, less air pollution, and digital vehicle documents. The two amended Directives rightly aim to adapt to new technologies and ensure safety and environmental standards, as the revisions will introduce requirements such as conditions for specific testing methods for electric…

We strongly support the revision of the Roadworthiness Package to implement additional emission reduction strategies in PTI and for roadside emission measurement. Based on our experience, we would like to highlight the following aspects that should be considered for the implementation: - Given that gasoline vehicles will account for the majority of combustion-based vehicles in the coming decades, we highly recommend…

HEAT believes that identifying the source of a problem is the first step in solving it. Therefore, we respectfully request that the EU Commission require and mandate the large-scale use of remote sensing technologies in member states by implementing the 30% threshold to achieve effective emissions reduction.

The following points are CAPELECs key positions and recommendations with the intention to support the initiative to achieve the targets of the proposal: 1. Emission Testing Support for Expansion We strongly supports the inclusion of Particle Number (PN) testing for all ICE (Internal Combustion Engine) vehicles, highlighting public health concerns and statistical evidence from pioneering Member States with PN test on…

AECA-ITV puts forward proposals to improve the new EU Directive on VRT so that they are taken into account and incorporated into the legislative text, in order to contribute to improving road safety and the environment, complying with and focusing on achieving the goal of zero road casualties. A document containing the content of the arguments developed is attached.

Filed in Spanish · English published by the European Commission

Bitkom supports the EU Commission's goal of further digitalizing the transport sector and making things noticeably easier for citizens and mobility providers in the EU by digitalizing vehicle registration documents and processes.

EGEA is the European Garage Equipment Association, representing the European industry from EU Member States and non-EU Member States, providing technical equipment and services to diagnose, inspect, repair, and maintain combustion engine, hybrid, as well as electric vehicles of all categories.

Submission to the EU Roadworthiness Directive: The Critical Role of Particle Number (PN) Testing The proposed inclusion of Periodic Technical Inspection (PTI) by particle number (PN) in the new version of the EU's Roadworthiness Directive represents a crucial advancement in identifying high-emitting vehicles (both Diesel and Petrol engines, with and without DPF/GPF).

Annual STK inspections: For M1 cars and N1 vans from 2 years to 1 year. We currently see no reason to tighten the checks unless there is a stronger link between roadworthiness testing centres and roadside inspections and the effectiveness of the STK system alone is not strengthened.

Filed in Czech · English published by the European Commission

RESPUESTA A LA CONSULTA PÚBLICA SOBRE LA PROPUESTA DE DIRECTIVA DEL PARLAMENTO EUROPEO Y DEL CONSEJO POR LA QUE SE MODIFICAN LA DIRECTIVA 2014/45 RELATIVA A LAS INSPECCIONES TÉCNICAS PERIÓDICAS, LA DIRECTIVA 2014/46/UE SOBRE DOCUMENTOS DE MATRICULACIÓN DE VEHÍCULOS Y LA DIRECTIVA 2014/47 RELATIVA A LAS INSPECCIONES TÉCNICAS EN CARRETERA DE LOS VEHÍCULOS COMERCIALES El marco normativo de las inspecciones técnicas de…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

RESPUESTA A LA CONSULTA PÚBLICA SOBRE LA PROPUESTA DE DIRECTIVA DEL PARLAMENTO EUROPEO Y DEL CONSEJO POR LA QUE SE MODIFICAN LA DIRECTIVA 2014/45 RELATIVA A LAS INSPECCIONES TÉCNICAS PERIÓDICAS, LA DIRECTIVA 2014/46/UE SOBRE DOCUMENTOS DE MATRICULACIÓN DE VEHÍCULOS Y LA DIRECTIVA 2014/47 RELATIVA A LAS INSPECCIONES TÉCNICAS EN CARRETERA DE LOS VEHÍCULOS COMERCIALES El marco normativo de las inspecciones técnicas de…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Feedback VEHICLE SAFETY – REVISING THE EU’S ROADWORTHINESS PACKAGE Comments to the proposal on technical roadside inspection of the roadworthiness of commercial vehicles CEOE Contributions The Spanish Confederation of Business Organisations (CEOE) represents and defends companies and entrepreneurs since 1977, and voluntarily integrates two million companies and self-employed people from all sectors of activity, who…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The attached LKQ Europe position paper highlights the critical importance of adapting regulatory frameworks to address the evolving challenges brought about by advanced vehicle technologies, particularly electric and automated vehicles.

The Modified Motorcycle Association of Finland ry (MMAF) is a Finnish advocacy organisation dedicated to motorcycle construction legislation. We will help policy makers by carrying out studies and providing information. We will raise awareness of the specific characteristics of motorcycles. Update of Directive 2014/45/EU on roadworthiness tests and Directive 2014/47/EU on technical roadside inspections.

Filed in Finnish · English published by the European Commission

FIVA calls on the European Parliament and the Council to: Maintain the current approach to historic vehicles, including the freedom of Member States to define and manage their inspection regimes; Introduce a requirement for all Member States to protect vehicles of historical interest, in line with the EU definition; Confirm the principle that vehicles must be assessed against the technical and environmental…

I think the initiative of bringing private cars into a main investigation every year, instead of every two years, is wrong: In order to drive cheaply, sustainably and environmentally friendly, many people move older vehicles that have purchased them second-hand. It is interesting to note that these older motor vehicles (i.e.

Filed in German · English published by the European Commission

Completely pointless. What percentage of accidents are due to technical defects in older vehicles? And how many per cent of accidents are caused by older drivers (e.g. > 65 years)? Would be interesting to know. Once the driving licence has been obtained, no longer asks about the fitness to drive and the state of health of the person. There can be a loose 50 years to go to the country.

Filed in German · English published by the European Commission

DEUVET Bundesverband Oldtimer-Youngtimer e.V. (President: Dr Ekkehard Pott) opposes the general reduction of HU deadlines in Germany. Vehicles bearing H-labels have a maintenance and conservation status of 3-5 years of second-hand cars based on the KBA Federal Motor Transport Authority’s deficiency rate.

Filed in German · English published by the European Commission

Dear, I am managing director of a motorcycle dealer with a workshop. In my view, the plan to test older vehicles once a year is not useful and ensures only verdruss among those affected. A further bureaucratic monster will be created, which costs citizens a lot of money and ensures minimal improvements in road safety.

Filed in German · English published by the European Commission

Road Safety Authority, Ireland – Contribution to Inception Impact Assessment (Roadworthiness Package) Ref. Ares(2021)6728802 - 01/11/2021 European Commission (Have your say portal) 1 November 2021 Subject: Call for Contributions – Revision of the Directives of the Roadworthiness Package – Inception Impact Assessment Dear Sir/Madam, Thank you for your invitation to provide a contribution on the revision of the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Deutsches Kraftfahrzeuggewerbe Zentralverband Position on the revision of the Roadworthiness Package Roadworthiness environment • The Roadworthiness Package must fit the related needs of the individual Member States to keep up functioning testing frameworks and to improve less effective testing frameworks.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

POSITION OF THE ATV ON THE REVISION OF THE EU ROADWORTHINESS PACKAGE Recurrent assessment: Audit system in Austria works reliably The audit system in Austria works reliably and has proved its worth. Assessment bodies authorised by the authorities shall ensure a nationwide network of inspection bodies. This ensures low-threshold access to the statutory periodic assessment of vehicles.

Filed in German · English published by the European Commission

Founded in 1904, the Fédération Internationale de l’Automobile (FIA) brings together leading national motoring organisations from 146 countries worldwide and is the governing body for world motor sport. The FIA Region I office, based in Brussels, is a consumer body comprising 103 Mobility Clubs that represent over 36 million members from across Europe, the Middle East and Africa.

Have your say, public consultation on the revision of the Roadworthiness Package – FIA contribution Founded in 1904, the Fédération Internationale de l’Automobile (FIA) brings together leading national motoring organisations from 146 countries worldwide and is the governing body for world motor sport.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Have your say, public consultation on the revision of the Roadworthiness Package – FIA contribution Founded in 1904, the Fédération Internationale de l’Automobile (FIA) brings together leading national motoring organisations from 146 countries worldwide and is the governing body for world motor sport.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Have your say, public consultation on the revision of the Roadworthiness Package – FIA contribution Founded in 1904, the Fédération Internationale de l’Automobile (FIA) brings together leading national motoring organisations from 146 countries worldwide and is the governing body for world motor sport.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Have your say, public consultation on the revision of the Roadworthiness Package – FIA contribution Founded in 1904, the Fédération Internationale de l’Automobile (FIA) brings together leading national motoring organisations from 146 countries worldwide and is the governing body for world motor sport.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Nordic Logistics Association (NLA) representing approximately 16.000 hauliers from the Swedish Association for Road Transport Companies (SÅ), the Danish Transport and Logistics Association (DTL), the Norwegian Road Transport Association (NLF) and its associated member Finnish Transport and Logistics (SKAL) is pleased to give its feedback to the roadmap on the revision of the Directives of the Roadworthiness…

Revision of the EU Roadworthiness Package Feedback by FSD Fahrzeugsystemdaten GmbH - Central Agency for PTI, Germany Version 1.0 Datum 2021-11-01 General Remarks We welcome the planned revision of the Directives of the Roadworthiness Package to improve Road Safety and ensure lifetime compliance of vehicles with emission and safety standards.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Association for Emissions Control by Catalyst (AECC) welcomes the opportunity to comment on the roadmap on the Revision of the Directives of the Roadworthiness Package public consultation. AECC fully supports the revision of the Directives of the Roadworthiness Package.

GOCA VLAANDEREN, the Flemish association of PTI enterprises in Belgium, believes that adopting the roadworthiness package should look to the current Directives and adopt where necessary or inconsistencies exist and on the other hand to be open for future technologies on the vehicles as well in the inspection methods.

The inspection of electronic- and softwarebased safety relevant systems (ePTI) becomes more and more important. For the revision of EU2014/45 it is requested to keep in mind and to regulate, that the technical and commercial independency for external (inspection) test equipment must be achieved. The PDF paper in this annex explains the complex relationship of the technology and stakeholders that can become involved.

Deficiencies not listed in this Annex shall be assessed in terms of the risks that they pose to road safety. Item Method Reasons for failure Assessment of deficiencies Minor Major 0. IDENTIFICATION OF THE VEHICLE 0.1. Registration number plates (if needed by requirements(1)) Visual inspection (a) Number plate(s) missing or so insecurely fixed that it is (they are) likely to fall off.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EGEA position paper on Revision of EU directives regarding Roadworthiness Oct. 2021 Introduction: EGEA is the “European Garage Equipment Association” representing the European industry providing technical equipment and services to diagnose, inspect, repair, and maintain combustion motor, hybrid as well as electric vehicles of all categories.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Hello More than 98 % of motorcycle accidents are not related to a technical failure. I have been slow for two years and the only thing that matters to me is to have a motorcycle fit for my own safety and that of others, I do not see the interest in imposing a roadworthiness test. Hopefully you will take these few words into account, and will understand that two-wheeled people are living in life. Kind regards

Filed in French · English published by the European Commission

Suomen Motoristit ry is not in favor of mandatory periodic inspections of motorized two-wheelers in all Member States. In line with current practice, Member States should be able to decide for themselves on effective road safety measures. Mandatory periodic inspections of motorized two-wheelers are not such. More detailed information can be found in the attached file.

ANCIA, representing most of the inspection centres in Portugal, provides the following contributions: FREQUENCY Increase the frequency of roadworthiness testing of shared mobility vehicles for logistical and/or passenger transport purposes, where traffic intensity is higher.

Filed in Portuguese · English published by the European Commission

Austria has a perfect private audit system — must be maintained. Coordinate type approval and tests — ECSS system Switch intervalves at the same time Access to data shall be free of charge and easily accessible to all. New propulsion systems!!!

Filed in German · English published by the European Commission

CNPA CONTRIBUTION TO THE EUROPEAN CONSULTATION ON THE ROADWORTHINESS PACKAGE Concerning the adjustment of the perimeter: Currently, all modes of mobility are covered by regulatory technical control: CARS and buses, industrial vehicles and their trailers, light vehicles, aircraft, vessels, etc.

Filed in French · English published by the European Commission

ÖAMTC Position on the revision of the Roadworthiness Package Roadworthiness environment • The Roadworthiness Package must fit the related needs of the individual Member States to keep up functioning testing frameworks and to improve less effective testing frameworks. • The coordination between type-approval and the roadworthiness package needs to be considered.

Directive 2014/45/EC on the periodic roadworthiness tests for motor vehicles:(2/2) 6. ADAS ADAS systems are making vehicle safer to the point that some of them are already mandatory. In order to maintain their advantages and to prevent malfunctions once the driver relies on them, their status need to be checked. - OBD testing is needed to assess the correct software version and system status.

Directive 2014/45/EC on the periodic roadworthiness tests for motor vehicles: 1. Performance and supervision standardization. Accreditation of testing centres under Regulation (EC) No 765/2008 of the European Parliament and of the Council should not constitute an obligation for the Member States.

Statement from GTÜ on the revision of the Roadworthiness Package Who is GTÜ? GTÜ is Germany's largest officially recognised inspection organisation of self-employed vehicle inspectors. More than 2,500 vehicle inspectors are active on hand at more than 11,000 inspection sites in workshops and car dealerships as well as at testing centres operated by GTÜ contract partners.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Position on the revision of the road safety package Safe environment • The roadworthiness package must meet the needs of each Member State in order to maintain functioning testing frameworks and improve less effective testing frameworks. This includes in particular the proven system in Austria of the assessment bodies authorised by the Provincial Governor in the form of the work contracted.

Filed in German · English published by the European Commission

A LA COMISION EUROPEA D. GUILLERMO MAGAZ PILAR, en nombre y representación de la ASOCIACIÓN ESPAÑOLA DE ENTIDADES COLABORADORAS DE LA ADMINISTRACIÓN EN LA INSPECCIÓN TÉCNICA DE VEHÍCULOS (AECA-ITV), en mi condición de Director Gerente, con domicilio en Madrid, C/Méndez Álvaro 20, C.P.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DEKRA is an international independent testing, inspection and certification company with almost 44,000 employees in 50 countries, which conducts more than 26 million inspections across 22 countries each year. Founded more than 95 years ago as the German Vehicle Inspection Association, vehicle inspection is at the heart of DEKRA.

Monitoring plays and will continue to play a crucial role in the mobility of tomorrow. It must evolve to take account of the following points: QUALIFICATION OF TECHNICAL CONTROLS Directive 2014/45 requires basic knowledge in certain disciplines, which in fact requires certain diplomas in maintenance of vehicles to be held.

Filed in French · English published by the European Commission

DEAR All, what I miss here very much is the checking of the tachograph calibration at the PTI. This is now possible with the introduction of the new SMART regulation and should therefore be included in the PTI test as a point of control. I don't underwhy no party has mentioned this yet.

Filed in German · English published by the European Commission

What still needs to be paid to citizens (motorcycles) for a fake service which is only there to teach roadworthiness lobbies, while maintenance of motorcycles is not at stake (2 %) in road accidents. The maintenance of our vehicles is seriously taken into account by motorcyclists, our lives depend on it, our physical protection is rudimentary compared to other road users.

Filed in French · English published by the European Commission

A CT for motorcycles would bring nothing in terms of road safety and the fight against noise and air pollution. Motorcycles keep their motorbikes because their lives depend directly on them; According to the MAIDS survey, only 0.7 % of motorcycle accidents cause technical failure.

Filed in French · English published by the European Commission

The braking test is sometimes run in the laden condition at a test station, otherwise the vehicle will be difficult to perform the brake test. If this vehicle is subsequently checked under the road and subjected to a brake test empty, this gives an incorrect picture. The vehicle can then be rejected without any technical defect. A fine is unduly imposed in this case.

Filed in Dutch · English published by the European Commission

I am a motorbike and an ancillary motor-mechanic. I repair, maintain and customise 2 wheels. I revisit old ones, make motorbikes tailored to my customers by recycling machines which, for some of them, are no longer in the taste of the day and deserve to finish in a cube. I do this by passion, may matter the budget, style or cylinder.

Filed in French · English published by the European Commission

Le contrôle technique pour les deux et 3 roues motorisés n est d'absolument aucunes utilités. L'accidentologie due aux défauts techniques sur les deux et trois roues motorisés est de 0.1%.... Le véhicule fait entre 3000 et 6000 km par an, et passe en révision tous les ans........

Hello, road safety argument: Roadworthiness testing, whatever its content, will not improve road accidents. Whether a new or old vehicle is being rerouted, whether it is maintained itself or by a mechano or by a dealer, no motor vehicle is running a dangerous or neglected vehicle. There is also no need for a dashboard tell-tale to see if our tyres are inflated!

Filed in French · English published by the European Commission

from my point of view of motard lambda, I see only motorcyclists who keep their machines loose and keep them in an impeccable condition, especially since it is also our safety to have a vehicle in very good condition. putting in place a roadworthiness test would be experienced like a brimade and a fric pump.

Filed in French · English published by the European Commission

Roadworthiness tests need not be extended to motorised two-wheelers, the accidents of which are only very rarely caused by a technical defect. This is still mostly due to excessive tyre wear, which is happening without having to go to an operator!

Filed in French · English published by the European Commission

Dear all, - Thank you for giving us the opportunity to comment on this review of the Roadworthiness package - Q1: Will this revision still be published as a European Directive or European Regulation? - Technical Impacts: Regarding Directive 2014/45/EC on the periodic roadworthiness tests for motor vehicles, the notion of "Type of Vehicle" must be defined.

Feedback on: Vehicle safety – revising the EU’s roadworthiness package; mandatory technical inspection for motorcycles FEMA welcomes the Sustainable and Smart Mobility Strategy (Mobility Strategy | Mobility and Transport) adopted on 9 December 2020. We have also read with interest the plans of the Commission to revise the Directives of the Roadworthiness Package.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

JULY 7TH, 2021 STRENGTHENING THE ENVIRONMENTAL AND ROAD SAFETY ASPECTS OF THE EU ROADWORTHINESS PACKAGE CITA aisbl | Rue du Commerce 123, B-1000 BRUSSELS (Belgium) TEL. [phone removed] | [email removed] | www.citainsp.org Consultative Status Category II to the Economic and Social Council of the United Nations 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

See attached file with facts, stats and arguments why compulsory PTI for motorcycles and mopeds in Europe will neither improve environment, nor road safety. Instead it will increase the risk of serious accidents among moped riders, it will create huge cost and unnecessary bureaucracy.