Renewable and Sustainable Energy Reviews 86 (2018) 1–21

Contents lists available at ScienceDirect

Renewable and Sustainable Energy Reviews

journal homepage: www.elsevier.com/locate/rser

A review of the European passenger car regulations – Real driving emissions T

vs local air quality
⁎,1
Nils Hooftman , Maarten Messagie1, Joeri Van Mierlo1, Thierry Coosemans1
Electrotechnical Engineering and Energy Technology, MOBI Research Group, Vrije Universiteit Brussel, Pleinlaan 2, Brussels 1050, Belgium

A R T I C L E I N F O A B S T R A C T

Keywords: Europe's regulation of passenger car emissions has been proven to have failed when it comes to nitrogen oxide
Euro emission standards emissions (NOx) by diesel engines. Due to historical decisions favouring diesel technology, Europe has become a
Diesel diesel island with no equal worldwide. As a result, virtually every European citizen breathes in air which is
RDE deemed harmful to human health. Real driving emissions (RDE) testing by means of portable emissions mea-
WLTP
surement systems (PEMS) can potentially eliminate the discrepancy between lab and road tests, and will com-
PEMS
LEZ
plement the dynamometer type-approval procedure from September 2017 onwards. Despite the significant
NOx potential of PEMS testing, the emission assessment has been watered down through politics to provide the
automotive manufacturers with additional lead-time. In this way, the lab to road gap is not eliminated but only
decreased. This means that diesel cars will continue to over-emit NOx until the 2020s at earliest. This has
consequences for effectively bringing down local air quality issues, especially in low emission zones (LEZ).
This paper presents a review of the European emission regulation history up to date and makes a comparison
with the approach in the other important car markets globally. One can conclude that a substantial update of the
European regulatory framework concerning automotive emissions is required, while ambitious post-2021 targets
should be set if Europe does not want its automotive industry to lose its competitive position in the global
market. In addition, an equilibrium should be sought for between sustainable personal transport in the form of
zero-emission vehicles (ZEV), and a sustainable economic climate for the automotive industry. The former is
needed if LEZs are to effectively bring down pollutant levels in cities.

1. Introduction
Reports on poor air quality throughout virtually all of Europe's cities
have amassed at an increasing rate during the last years, as knowledge
on its adverse effects on human health and ecosystems is expanding
[1–6]. For the main polluting sectors, i.e. industry, energy production,
households, transport and agriculture, significant emission reductions
have been achieved in the last decades. Despite these achievements,
local air quality targets put forward in the European Union's (EU) Air
Quality Directive [7] remain a challenge. This leads us to two possible
conclusions; either the previously implemented limits were not ambi-
tious enough, (and/) or there is a mismatch between the objectives and
what is monitored in the field, e.g. due to the application of outdated
and/or inappropriate measuring techniques.
The road transport sector is a major contributor of carbon dioxide
(CO2), nitrogen oxides (NOx) and particulate matter (PM2.5 and PM10).
The sector's contribution to NOx and PM is of particular concern in
cities, as large numbers of people are directly exposed. Considering NOx
emissions, Chen et al. showed that NOx emissions by European diesel
cars haven’t decreased at all, over the various emission standards [8].
Moreover, emission reduction systems were found to degrade over time,
as discussed by Chen and Borken-Kleefeld et al. in [9,10]. For petrol-
fuelled passenger cars, NOx emissions were effectively found to have
reduced over the various emission standards, following Carslaw et al. in
[11–13]. The adverse effect of NOx is in addition strengthened by an
increase in the primary share of nitrogen dioxide (NO2) emissions, as
indicated by Kurtenbach et al. in [14], Williams et al. in [15], O’Driscoll
et al. in [16] and finally by Degraeuwe et al. in [17]. Concerning CO2,
passenger cars represent approximately 62% of road transport's total
[18]. Throughout the last two decades, the European Commission (EC)
has focussed especially on the reduction of CO2 emissions for passenger
cars, to reduce its impact on the noticeable climate change [19]. The
need for this reduction is highlighted by the fact that CO2 emissions
from road transport have increased by 17% between 1990 and 2014.
This evolution can be assigned to the growth in both personal and
freight transport and is accompanied by an increased fuel consumption

⁎
Corresponding author.
E-mail address: nils.hooftman@vub.be (N. Hooftman).
1
VUB-MOBI Group is member of Flanders Make.

https://doi.org/10.1016/j.rser.2018.01.012
Received 30 March 2017; Received in revised form 8 July 2017; Accepted 31 January 2018
Available online 22 February 2018
1364-0321/ © 2018 The Authors. Published by Elsevier Ltd. This is an open access article under the CC BY-NC-ND license (http://creativecommons.org/licenses/BY-NC-ND/4.0/).
N. Hooftman et al.
Table 1
Overview of the percentages of the EU28 urban population exposed to air pollutant concentrations above thresholds set by the European union and the world health organisation (based
on (EEA 2016).
Pollutant EU Ref. Interval (Conc.)
PM2.5 Year (25 µg/m3)
PM10 Day (50 µg/m3)
O3 8-h (120 µg/m3)
NO2 Year (40 µg/m3)
BAP Year (1 µg/m3)
SO2 Day (125 µg/m3)
of 23% over the same time span [20]. This increasing trend is not ex-
pected to come to a halt shortly, as a 40% and 58% increase in pas-
senger kilometres and freight kilometres is expected by 2050, respec-
tively [21]. This increase in driven kilometres has a detrimental effect
on both the ongoing effort for higher fuel efficiency and on local air
quality. More kilometres result in an increase in absolute emissions of
both regulated and unregulated pollutants. The effect on local air
quality levels of reducing traffic volumes is discussed in Flicstein et al.
in [22] and Keuken et al. in [23]. Although modern emission reduction
technologies such as oxidation catalysts and particulate filters have
successfully brought down the average emission factors (in grams/
kilometre), they do not cover important pollutants such as benzo-a-
pyrene (BaP) or non-exhaust PM originating from tyre, brake and road
wear. For a detailed impact assessment of non-exhaust emissions on
both human health and ecosystems, refer to Hooftman et al. in [24].
Vehicle emissions for European passenger cars have been regulated
by means of the Euro emission standards since 1992 [25]. With these
successive standards, important reductions of the regulated pollutants
carbon monoxide (CO), unburned hydrocarbons (HC), NOx, PM and the
particle number (PN) have been targeted. In this way, the European
Union (EU) has challenged and continues to push the automotive in-
dustry to develop auxiliary emission control devices (AECD) and stra-
tegies for their cars to pass the type-approval process. The latter is
based on the New European Driving Cycle (NEDC), which is found to
poorly represent modern vehicle usage [26–31]. Therefore, Euro 5 and
Euro 6 regulation for diesel cars has failed when it comes to NOx, while
there is an increasing discrepancy between laboratory test results and
reality when it comes to CO2. This puts a significant pressure on pas-
senger car technology as it is known to date and triggers debates on the
future of combustion-based personal transport.
This paper presents a review of the emission-related European
regulations for passenger cars and how they have significantly con-
tributed to the current air quality situation in Europe (chapter 2). An
overview is given of how Europe became a diesel stronghold in an at-
tempt to become the world leader in CO2 reductions by passenger cars.
Despite these ambitions, an outdated and unrealistic driving cycle for
type-approval fuelled a growing gap between official emissions and
what is measured by means of portable emissions measurement systems
(PEMS, chapter 3). As an answer to this discrepancy, a new test pro-
cedure is to be introduced in September 2017, complemented by PEMS
testing for NOx and PN. The on-road testing procedure is consolidated
in four regulatory packages, of which the last one represents market
surveillance and in-use testing by independent organisations. The road
towards full implantation of the complete set of packages however re-
mains unclear up to date. This is discussed in chapter 4. Chapter 5
presents the weak points in the current type-approval process and
compares the European situation with the U.S.’s approach. As will be-
come clear during this overview, certain decisions made in the past
have resulted in poor air quality in virtually every European city. In a
game of ‘who did what’, both policymakers and original equipment
manufacturers (OEM) of passenger cars allege each other as the main
cause for this ongoing issue, while strong lobbying from the OEMs
proves to be an important cause of delay in the process of changing the
way passenger cars contribute to the air one breathes today and
Renewable and Sustainable Energy Reviews 86 (2018) 1–21
Exposure Estimate (%) WHO AQG Exposure Estimate (%)
8–12 Year (10 µg/m3) 85–91
16–21 Year (20 µg/m3) 50–63
8–17 8-h (100 µg/m3) 96–98
7–9 Year (40 µg/m3) 7–9
20–24 Year (0,12 µg/m3) 88–91
<1 Day (20 µg/m3) 35–49
tomorrow. This is of importance as cities all over Europe are im-
plementing so-called ‘Low Emission Zones’ (LEZ) based upon the
emission standards, which have been proven to have failed up to date.
2. Air quality in Europe
The European Environment Agency (EEA) annually publishes an
update of the air quality levels throughout its Member States. The most
recent report presents the analysis of the situation from the year 2000
until 2014, and reviews the progress made towards meeting the air
quality standards which were established in two Ambient Air Quality
Directives 96/62/EC and 2008/50/EC [6]. In addition, it compares the
latest achievements with regards to the long-term objectives that focus
on a sustainable situation for both human health and the environment.
Concerning human health, an important indicator is population ex-
posure to the regulated pollutants, for which a comparison is made
between the World Health Organisation's Air Quality Guidelines (WHO
AQG) and the more relaxed European thresholds. The most recent re-
sults for Europe's urban population's exposure are given in Table 1. The
table should be read as following: the reference concentration intervals
are given in the second and fourth column, while the exposure estimate
columns indicate which percentage of the EU urban population is ex-
posed to higher concentrations per reference time interval. An im-
portant difference can be noticed between the threshold limits for
safeguarding human health for the two sources. This is indicated by the
fact that per EU references virtually all EU28's urban population lives in
acceptable ambient air conditions, while per WHO guidelines practi-
cally every city dweller breathes in air that is deemed harmful to human
health. These guidelines are essential as PM, NO2 and ground-level O3
cause about 436.000, 68.000 and 16.000 premature deaths due to long-
term exposure throughout the EU per year, respectively [6].
Although the emissions of PM2.5, PM10, NO2 and ground-level ozone
(O3) have decreased over time, road transport remains a significant
contributor, especially for BaP and NOx. Considering PM, non-exhaust
PM emissions represent roughly half of the measured primary PM10 and
nearly one fourth of primary PM2.5. As non-exhaust PM is not regulated,
it is expected to dominate the future automotive PM emissions, as ex-
haust PM has been successfully reduced by more than 99% since the
Euro 5 emission standards of 5 mg/km [32,33]. In the light of im-
proving urban air quality concerning non-exhaust emissions, electric
vehicles (EV) are found to be a more sustainable alternative
[24,34–38].
Even though the Air Quality Directives target nitrogen dioxide
(NO2) concentrations, the emission standards for passenger cars target
NOx as the combination of both nitrogen monoxide (NO) and NO2. This
mismatch between the two regulations can be seen as a missed chance
as so-called ‘primary NO2 emissions’ by diesel have increased sig-
nificantly over the last two decades [14,39]. Regulating only NO2 in-
stead of NOx would not serve as the ideal solution, though, as complex
atmospheric interactions between NO, NO2 and ground-level O3 known
as titration reactions create secondary NO2 as well. This is especially
the case in urban regions, due to the substantial contribution of traffic
to the ambient NO concentrations, which react with O3 to form NO2.
Therefore, the only remedy for improved urban air quality would be to
2
N. Hooftman et al.
reduce NO and NO2 emissions simultaneously [14].
As will become clear in this paper, diesel-based road transport is a
major cause of the European urban air quality issue. Whereas the
transport sector represents 46% of the total EU28 NOx emissions, 80%
of these emissions originate from diesel-powered cars, vans, trucks and
busses [6,40]. According to field measurements in and around London
based on remote sensing techniques, Carslaw et al. reported a sig-
nificantly reduced NOx emission by the diesel fleet. Most these reduc-
tions, however, are to be attributed to heavy-duty transport [39]. This
is confirmed by on-road testing by the International Council on Clean
Transportation (ICCT), indicating that Euro VI trucks have become
substantially cleaner than diesel cars, considering NOx emissions.
Whereas trucks emit on average 200 mg/km, Euro 6 cars typically
produce 500 mg/km [41]. This symbolizes the systematic problem that
has characterised the light-duty diesel fleet during the last two decades.
3. Europe as a diesel stronghold
3.1. Europe vs the world
So why is diesel so prevalent in the EU while it does not manage to
break through in markets such as the U.S., China or Japan, where the
latest annual diesel sales shares added up to 0,81%, 0,04% and 3,7%,
respectively [42–44]? These mentioned markets have emission policies
in force, but there are differences to be noticed among them.
In Japan's Tokyo for example, a ban on diesel-powered vehicles in
the metropolis lasted for nearly 13 years; the technology has gained
modest popularity only recently [45–47,44]. Next to its metropolis
banning diesels, Japan pushed its national automotive industry towards
petrol technology by means of stringent NOx regulation and reduction
on tax advantages for diesel 20 years ago [48]. In addition, Japan's
frontrunner program for energy conservation has also led to a strong
‘greening’ of their car fleet, as in 2015 27,1% of the newly registered
cars were either hybrid, plug-in hybrid, (fuel cell) electric or ‘clean’
diesel vehicles. The latter refers to DPF-equipped diesel cars, which
contributed for 13,5% of this so-called ‘next-generation’ passenger car
fleet [44,49]. China, on the other hand, aims for significant air quality
improvements in and around its megacities and for virtually bypassing
diesel with electric vehicles (EV) to attain this goal. This ambition has
led to the fact that the country has been investing billions of Euros in
the promotion of EVs, as well as to funding of research and subsidising
OEMs for cars and battery systems. In this way, China aims to become
the world leader when it comes to electromobility [50].
3.2. Vehicle emission regulation
Ambitious automotive emission regulations by the European Union
launched Europe as a worldwide leader in the late 1990s. Therefore,
other global markets (except for the U.S. market) would simply adopt
European law, which made it possible for European OEMs to gain easy
access to foreign markets. To date, the global car markets remain
dominated by EU law or derivatives from it, although this situation is
no longer a certainty. Over the course of the last years, European law is
slowly losing its credibility and hereby the competitive advantage for
its car manufacturers worldwide. The pole position is being handed
over to the U.S., as it defined a longer-term vision with objectives for
2025, whereas the EU fails to do so. The recent NOx emission scandal
(discussed further on) also showed the world how Member States have
failed to overview their own industry and to apply significant penalties.
As a result, markets such as China are moving towards U.S.-based
emission regulations (see [51]). This will in turn make it more difficult
for EU OEMs to export their products, such as base diesel technology,
without sophisticated after-treatment systems [52]. In other emerging
markets such as Brazil (and India) adopt U.S. law as well, its stringent
NOx regulation will also mean that the European diesel industry loses
potentially important export markets. Time will thus tell if Europe's sole
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Renewable and Sustainable Energy Reviews 86 (2018) 1–21
focus on diesel will backfire as the competitors take off with hybrid and
zero-emission technologies. When it comes to electric vehicles, China
has entered the world stage as well. In 2016, 46% of all electrified cars
registered worldwide were sold in China. For the total sales shares, this
equals 1,43%, compared to 0,8% in the U.S. and 1,3% in the EU [53].
As this paper considers both the dominating combustion-based and
emerging technologies, it is important to have a look at the differences
between both EU and U.S. emission regulations. When comparing, one
should start with the reasoning behind the original automotive laws, as
they are known to have resulted from different points of view. Although
both markets aimed for a reduction of automotive emissions, the EU in
1970 prioritised coherency among its Member States and strived for
them not to take unilateral measures that would disrupt the early in-
ternal European market. In those early days, vehicle safety and fuel
consumption were more important than concerns about the air quality.
Nevertheless, an urban driving cycle was developed for dynamometer
testing, characterised by a maximum velocity of 50 km/h, slow accel-
erations and low engine loads. This was the ECE-15 [54].
In the U.S. on the other hand, several cities suffered from smog
episodes in the 1950s and 1960s, which emphasised the need for
curbing measures. At U.S. federal level, this resulted in the Clean Air
Act of 1963, of which an amendment in 1970 authorised the U.S.
Environmental Protection Agency (US EPA) to set air quality standards
and relevant regulations to protect human health and the environment
[55]. The road towards federal regulations, however, was paved by the
state of California, which, due to its unique climatologic situation and
multimillion car stock, suffered from smog nuisance much sooner, as
early as the 1950s. This is the reason why up to date, California is
authorised to depute its own, stricter emission regulations. It is up to
the other states to choose whether to follow the Californian, or the
slightly more relaxed federal regulations.
Contrary to the U.S. situation, where the EPA works as a stand-alone
authority, specific vehicle emission regulations in the EU result from
politics and rely on decisions from the European Council and
Parliament. The main difference here is that the European
Environmental Agency (EEA) has an indirect (limited) voice in the
regulatory process as an advisory organ, i.e. as a knowledge provider.
Another difference between the EU and the U.S. in terms of environ-
mental rulemaking is that the former is a decentralised system in which
Member States authorities are responsible, whereas the latter is largely
centralised and e.g. has an own laboratory, i.e. the National Vehicle and
Fuel Emissions Laboratory (NVFEL). The EEA on the other hand has
neither the inspection capacities nor has it got any role in the testing or
monitoring of vehicle emissions [56]. Instead, the EU's Joint Research
Centre (JRC) performs independent vehicle emission tests for mostly
exploratory reasons.
Concerning the impact on local air quality, EU emission targets for
passenger cars are found to be less stringent then the U.S.’s. This is
reflected in the allowance for EU diesel engines to produce more NOx
than is the case for petrol engines. In the U.S., such a difference is not
made as fuel-neutrality is in place. Moreover, current federal and
Californian NOx emissions are limited to 40 mg/km, compared to
60 mg/km and 80 mg/km for European petrol and diesel cars, respec-
tively. As will be discussed further on in this paper, EU regulators have
decided to allow diesel cars an exceedance of 2,1 times the 80 mg/km
limit until 2020. By the same year, all passenger cars and light trucks in
the U.S. should comply with combined limit of 40 mg/km for non-me-
thane organic gasses (NMOG) and NOx. This is stipulated in the US EPA
Tier 3 and California Low Emission Vehicle (LEV) III programmes,
which will gradually phase in the limit to approximately 19 mg/km by
2025 [57]. This is one of the major reasons why diesel technology only
started to get a foothold in the U.S. since technological advances such as
lean NOx traps (LNT) and selective catalytic reduction (SCR) systems
were commercialised for passenger cars in the late 2000s. These tech-
nologies allow compliance with the strict 40 mg/km NOx limit, given
the right engine calibration to cover practically every driving situation's
N. Hooftman et al.
Fig. 1. An overview of the various CO2 emission targets in NEDC-equivalents (based upon [59]).
NOx production [58]. China recently approved its so-called ‘China 6’
emission standard for a two-staged introduction in July 2020 and July
2023, respectively. Based upon both EU and U.S. regulation, a fuel-
neutral approach targets 60 mg/km NOx emissions by 2020, to be re-
duced to 35 mg/km by 2023. Unlike the EU, China approved ongoing
PM restrictions as well, as the 4,5 mg/km limit by 2020 will be brought
down further, to 3 mg/km by 2023. In addition, both methane (CH4)
and nitrous oxide (N2O) are targeted separately. Concerning CO and
NOx emissions, China will implement stricter limits than is the case
under Euro 6 regulation [51].
On the other hand, the EU regulation is more demanding when
greenhouse gas emissions are considered. This is reflected in the in-
troduction dates for CO2 targets as shown by the International Council
for Clean Transportation (ICCT) in Fig. 1 [59]. In this graph, an over-
view is given of the different fuel consumption targets of important
automotive markets from all over the world, after a conversion has been
made from the national targets into NEDC equivalents. Note that the EU
had a frontrunner role by means of the most ambitious fleet average
CO2 emission target of 95 g/km by 2020, but postponed this target by a
year under pressure from the German automotive industry [60]. Thus,
South Korea will finally be market leader as it aims for an average 97 g/
km limit to come into force from 2020 onwards. In the U.S., where the
average light-duty vehicle (car/truck) is considerably heavier and more
powerful, a longer phase-in period is chosen to reach a 97 g/km target
by 2025 in NEDC terms [61]. China and Japan prove to be less ambi-
tious towards 2020, as their targets comprise 117 g/km and 122 g/km
by 2020, respectively. Japan's high share of hybrid vehicles, however,
may bring its fleet average well below the 2020 target.
In the U.S., CO2 emissions for all light-duty vehicles (cars + light
commercial vehicles/trucks) are based on the vehicle's footprint, i.e. the
surface in between the four wheels, and in addition consider the CO2-
equivalents for nitrous oxide (N2O) and methane (CH4). In Europe, only
CO2 is regulated, as N2O and CH4 have only a minor influence on the
total greenhouse gasses (GHG) by transport (approximately 1,2% [18]).
Methane emissions aren’t negligible for natural gas vehicles, though. In
addition, the European CO2 limit is based upon the average vehicle
weight of a manufacturer's fleet. The heavier the average fleet weight,
the higher the CO2 level that is allowed [55]. The disadvantage of the
latter approach is that it does not incentivise the use of light-weight
materials, whereas a footprint-based approach does.
So far for the differences in emission limits, as another great con-
trast lies in the application of them, i.e. by means of the testing
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Renewable and Sustainable Energy Reviews 86 (2018) 1–21
procedure. Whereas in Europe the European New Driving Cycle (NEDC)
has been the benchmark for more than two decades, new vehicle
models in the U.S. are tested over the Federal Test Procedure 75 (FTP
75). Since 2000, supplemental cycles have been added to address ag-
gressive, high-speed driving (US06) and the impact of using air con-
ditioning (SC03). A dedicated highway driving cycle (HWFET) is used
in combination with the FTP 75 for the calculation of the corporate
average fuel economy. Finally, the aforementioned cycles are combined
in the ‘5-cycle test mode’ which came into force from 2008 onwards,
with an inclusion of a cold temperature FTP 75 (− 6,7 °C) cycle to the
cycles [62]. This set of dynamometer test cycles secures a closer rela-
tion to realistic driving, while in Europe the gap between laboratory
results and reality have been increasing since the early 2000s
[63,64,29]. This will be discussed further on, in subchapter 3.3. Fuel
taxation.
CO2 has historically been an important driver for the EU's passenger
car emission policies. In the framework of the 1998 Kyoto Protocol, the
Association of European Automobile Manufacturers (ACEA) reached a
voluntary agreement with the European Commission to bring down the
average CO2 emissions from new cars down to 140 g/km by 2008 (cf.
Regulation 443/2009 [65]). Diesel cars were given a prominent role in
this effort, which resulted in growing annual sales shares. Whereas
approximately 25% of the EU car sales consisted of diesels in 1998, this
share began to start hovering around the 50% mark from 2004 onwards
[66]. Japan, for example, agreed upon a similar voluntary concession as
well, but took other measures to reach higher fuel efficiency, i.e. by
means of hybridisation of petrol engines. Given the relaxed NOx emis-
sions for diesel cars, European OEMs significantly invested in ever more
powerful diesel technology but nevertheless failed to reach the 2008
target. Therefore, a legally binding target was imposed, targeting a
2015 new car average of 130 g/km. This significant lead-time was ob-
tained by the automotive lobby, as threats of job losses and industry
relocation were expressed to tip the balance in their favour [67,68].
In December 2015, an agreement was reached to limit the global
temperature increase to 1,5 °C, with 2 °C set as an absolute maximum,
at the Conference of Parties to the United Nations Framework
Convention on Climate Change (COP21 [69]). These ambitious com-
mitments, however, still need to be converted into concrete action.
Sustantial changes will be imposed on transport as it significantly
contributes to the GHG emissions. Without any doubt, a shift towards a
sustainable, hence zero-emission, transportation system will be the
outcome. What remains unclear, though, is the timeline for this
N. Hooftman et al.
paradigm shift.
3.3. Fuel taxation
Another driver for the high sales share for diesels, which in coun-
tries like Belgium, France and Luxembourg once peaked above 75%,
has been the diesel price at the pump [66]. High fuel taxes in Europe
are the reason why 60% less fuel is used per capita compared to the U.S.
[70]. Taxation thus results in lower consumption and offers several
opportunities, ranging from industrial innovation stimuli (e.g. the
promotion of car electrification) over job creation (by lowering labour
taxes) to a boost of domestic spending for Europe.
The differentiation in taxes between petrol and diesel however, is
unique for Europe and dates back to post-war times when governments
needed tax revenues from products that were widely used. Petrol was
one of those products. This difference remains to date, and comprises
on average 30% in favour of diesel [70]. Consequently, diesel car
owners in fact receive indirect subsidies compared to petrol car owners,
estimated to add up to €2.600 over the car's lifetime. This ‘margin’ has
resulted in more powerful and heavier cars gaining popularity. More-
over, low-cost diesel-based mobility has induced the trend to drive
more kilometres, which in its turn has a detrimental effect on the
adoption of alternative technologies such as electric vehicles. This trend
is only strengthened by the low oil prices which were reported during
the last years [71]. Moreover, certain Member States are experiencing
high shares of company car registrations. For Belgium in 2015, for
example, the percentage of company car registrations exceeded private
car registrations by 50,03% to 49,97%, respectively. As many company
cars come provided with company-paid fuel expenses, a trend towards
more powerful engines can be reported as well. This is one of the rea-
sons why more than 78% of the Belgian company cars registered in
2015 were diesel-fuelled, next to procurement policies which remain
mostly based on diesel options only [72]. Therefore, levelling the price
difference for petrol and diesel fuel could serve as an important
leverage to nudge consumers towards alternatives for diesel tech-
nology. This would not impact the fuel cost for the heavy-duty sector as
the latter already enjoys significant diesel rebates through bulk pur-
chase discounts and VAT reclaims. EU Member States also profit from
low diesel prices for the haulage industry, as it generates certain fuel
tourism, which is in turn beneficial for domestic tax revenues [70]. In
other regions in the world, taxes on fuel are typically lower than in the
EU. This has led to an increased European demand for more fuel-effi-
cient cars, which brings us to diesel technology. The reason for this is
that diesel historically proved to operate more fuel-efficiently, a trend
which lasted until direct injection petrol technology managed to equal
diesel fuel economy, since the early 2010s. On the other hand, this has
led to high investments in diesel technology, accompanied by increased
costs to assure diesel vehicles remain in compliance with the emission
legislation. Whereas three-way catalyst (TWC) technology for petrol
cars has reached maturity and is implemented at a low cost, ever more
sophisticated auxiliary emission control devices (AECD) are needed for
diesel exhaust gasses to be scrubbed from NOx and PM. The exhaust
after-treatment systems applied in recent diesel cars have an average
cost of €2.000 [73]. For this same investment, a full hybridisation of a
petrol car could be possible, together with the potential of bringing
down its CO2 emissions by 25%. This indicates diesel does not have to
be crucial for reaching the European CO2 targets for 2020 [71]. On the
other hand, it is exemplary of how political decisions shape the industry
and vice versa. A non-technical adverse effect of high diesel shares is
the external cost to society due to the induces health care costs and lost
working days, caused by poor local air quality.
3.4. Failing type-approval test procedure
Due to the introduction of the three-way catalyst (TWC) for petrol
engines from Euro 1 onwards, HCs, CO and NOx have been significantly
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Renewable and Sustainable Energy Reviews 86 (2018) 1–21
reduced to fractions of what uncatalysed petrol engines produced [74].
The same is true for the diesel oxidation catalyst (DOC) for the con-
version of HCs and CO, as well as for the diesel particulate filter (DPF),
which reduces more than 99,9% of the engine's PN and 99% of the
engine-out PM [33,75]. Next to these AECDs, diesel cars are equipped
with an ‘in-engine’ NOx control by means of exhaust gas recirculation
(EGR). As mentioned earlier, two main AECDs are available for con-
verting NOx to date, i.e. the lean-NOx trap (LNT) and selective catalytic
reduction systems (SCR). Whereas U.S.-bound diesel cars are typically
fitted with a combination of both, European variants could in some
cases pass type-approval solely with EGR, or fitted with either a LNT or
an SCR system. This indicates the striking differences between the EU
and U.S. regulation, and explains the unsolved air quality issue in
Europe's cities. Whereas U.S. bound diesels are required to emit no
more than 40 mg/km of NOx during every driving situation, many times
more is emitted on European roads. The reason for this is that the en-
gine control units are tuned for type-approval only, while during
normal operation the engine control unit (ECU) switches over to an-
other mode, focussed on drivability and performance.
The first indications of tampering during the test procedure reg-
ulations already date back to the end of the 1990s. NGO Transport &
Environment reported in 1998 that OEMs applied so-called ‘cycle-
beating’ techniques by engaging the vehicle's AECDs only when the
NEDC cycle was performed [76]. This case echoed a U.S. emission
scandal in the heavy-duty vehicle (HDV) fleet of that same year. The
U.S. EPA fined OEMs for violating the Clean Air Act by means of AECDs
which were effectively switched off during highway driving [77]. Cycle
recognition, as it was revealed by Kågeson, could be applied in various
ways, as shown in [78,79]. Moreover, the flexibilities in the EU reg-
ulation have been exploited at an increasing pace and in various ways,
as shown in [27]. Following the 1998 report, the gap between type-
approval fuel consumption and what is measured in reality is found to
be following an increasing trend as well [63,64,29]. Based upon real-
world fuel consumption data from consumer organisations and fleet
managers (of company cars), the gap was approximately 9% back in
2001, while it has risen to approximately 42% in 2015. Exceptions to
the rule are certain brands which easily surpass the 50% mark, while
other brands manage to keep the discrepancy below 35% [80]. Based
upon NEDC testing, a continuation of the current practices would result
in a gap of 50% before 2020.
As innovations in diesel technology took place and higher injection
pressures allowed better fuel economy, European OEMs started
building bigger and more powerful diesel cars, while complying with
the lenient NEDC procedure. By means of re-testing stock cars over
more demanding driving cycles such as the Common Artemis Driving
Cycle (CADC), however, indications were given that, next to higher CO2
emissions, European car makers experienced difficulties for complying
with the regulations for diesel NOx during ‘off-cycle’ test conditions
[81]. Further evidence on the exceedances over various driving cycles
other than the NEDC followed in the years to come [82–85]. Own
measurements by the authors of this report date back to the 2013–2015
period and were performed in the framework of the periodic technical
inspection (PTI) in Belgium. Tests were based upon garage-type gas
analysers, i.e. the MAHA MPM 4 for PM2.5–10 and MAHA MET 6.1 for
CO2, CO, O2, NO and HC, which were used during a dynamometer-
based test campaign. In total, 37 passenger cars, of which 26 Euro 5
certified diesel cars, were tested over the IM240 cycle under 6 different
ambient conditions, to assess their suitability for PTI application. Re-
sults from this qualitative research are given in Fig. S1 in the Appendix I
of this paper and show a discrepancy by a factor of 6–12 for the NOx
emissions by the tested diesel cars, confirming findings from literature.
In fact, tests revealed that over the sequence of the different Euro
emission standards barely any reduction of NOx emission took place for
diesel cars. Concerning the most recent Euro 6 limit of 80 mg/NOx per
kilometre, dynamometer tests with 73 Euro 6 diesel cars with various
NOx treatment systems showed that on average, an exceedance factor of
N. Hooftman et al.
Fig. 2. The evolution of diesel NOx emissions PER the official test cycle (NEDC), the more realistic Common Artemis Driving Cycle (CADC) and the Worldwide Harmonised Light Vehicle
Drive Cycle (WLTC, class 2) for the Euro 6 diesels. Based on [65,66,88,86].
roughly 5 times the limit was found [86]. This factor results from
comparing tests over the NEDC with the Worldwide Harmonised Light
Vehicle Test Procedure (WLTP), which will gradually replace the
former between September 2017 and the start of 2021. The differences
between both test cycles will be scrutinised in 3.4.1. NEDC versus
WLTP. The NOx test results for the different diesel Euro emission
standards are given in Fig. 2 and represent both the official NEDC va-
lues, accompanied by the CADC and WLTC (Class 2) results. Please note
that the Class 2 WLTC variant applied in [86] is a less demanding cycle
than the Class 3.2 cycle, which will be effectively applied for European
type-approval from September 2017 onwards. Whereas Class 2 re-
presents a more relaxed velocity profile (and lower top speeds), NOx
emissions are in fact underrepresented in Fig. 2. Therefore, the Euro 6
error bars indicate that emissions over the WLTC class 3.2 cycle can
exceed 800 mg/km, based upon research performed by the Dutch Or-
ganisation for Applied Scientific Research (TNO) by [87]. The results
shown in Fig. 2 show that Euro 6-certified diesel cars underwent a
significant reduction of NOx emissions, based upon dynamometer test
results. Despite the reductions, the average emission factor presented
here remains a multitude of the 80 mg/km limit for Euro 6 diesels. The
presented Euro 6 error margins indicate on the one hand that there are
vehicles on the market which effectively respect this limit, while others
substantially exceed the limit, on the other hand.
Test results indicating growing discrepancies between the NEDC
and more realistic driving cycles did not go unnoticed by the European
Commission. Their perception at the end of the 1990s and the 2000s,
however, was not that OEMs exploited or cheated the test procedure's
flexibilities, but rather that the procedure itself proved to be weak. In
fact, the NEDC was known to be outdated before it went into regulation
in its most recent form, i.e. with the introduction of the Euro 3 emission
standard in 2000 [89]. More pressing measures in the first half of the
2000s, however, needed to be taken against poor urban air quality due
to exhaust PM, predominantly by diesel cars. This drastic reduction of
diesel PM was prioritised above a review of the NEDC, as a new driving
cycle would delay the introduction of Euro 5 beyond desire.
3.4.1. NEDC versus WLTP
Up to date, different vehicle emission regulations are applied all
over the world. This requires OEMs to modify their products according
to the regional needs. If emission regulations are more lenient, vehicles
with less efficient after-treatment can be exported. The other way
around, more demanding regulations require OEMs to over-perform
their domestic market's requirements and to cut profit margins for
compliance.
With the aim of harmonising emissions testing worldwide, the
6
Renewable and Sustainable Energy Reviews 86 (2018) 1–21
United Nations’ World Forum for the Harmonisation of Vehicle
Regulations (WP.29) launched a project in 2007 to develop the
Worldwide Harmonised Light Vehicle Test Procedure (WLTP) and Test
Cycle (WLTC). This was no pioneering work, as the working party on
pollution and energy (GRPE), i.e. the technical working group re-
sponsible for this project, had already successfully developed harmo-
nised cycles for motorcycles and heavy duty vehicles (cf. UNECE's
Global Technical Regulations (GTR) 2 and 4, respectively) [90]. A ‘one
size fits all’ driving cycle would make it possible for OEMs to market
their products worldwide with one type-approval procedure and thus
bring an economical benefit. Besides that, the objective was to create a
realistic test, reflecting actual car operation.
More realistic CO2 emissions, and thus fuel consumption figures,
could in the short-term serve to restore the blemished European con-
sumer confidence, while on a longer term it could help to determine
new, realistic CO2 emission targets after 2021. Although initially sup-
ported by stakeholders from industry, governments and non-govern-
mental organisations (NGO) from all over the world, the U.S. EPA opted
to withdraw from the concern in 2010 due to resource-intensive pre-
parations for its upcoming 2012–2016 and 2017–2025 greenhouse gas
(GHG) standards [91]. Hereby the ‘worldwide harmonised’ aspect of
the WLTP lost its true meaning, however, the EU, Japan, India and
South Korea continued as active consortium partners. China was also
involved as a contracting party and uses UNECE Regulations – to a
certain extent – as a reference in its domestic legislation [92]. On De-
cember 23, 2016, China adopted the WLTP for passenger car type-ap-
proval from 2020 onwards [51].
As the different adopting regions over the world do not have iden-
tical average driving characteristics, the WLTP allows a certain degree
of differentiation among them. Therefore, three ‘power-to-weight’
classes were developed, of which the most demanding class 3.2 will be
used for the EU, representing the highest maximum speeds and engine
loads. The WLTP package was approved by the WP.29 group for
adoption by the various UN members in March 2014. Final approval by
the European Union of the new testing procedure occurred in March
2016 and the introduction was agreed upon for September 2017.
Parallel with the WLTP, the Euro 6d emission standards will be in-
troduced in September 2017 as well, comprising real driving emissions
(RDE) testing. This will be discussed in chapter 4.
With the introduction of the WLTP, the EC hopes that an end – or at
least a significant reduction – will come to the exploitation of the many
flexibilities in the type-approval procedure. Although the known ex-
ploitations in the NEDC framework aren’t illegal, they counter the spirit
of the NEDC's original objectives. The differences the WLTC will bring
are given in (Marotta et al., 2015), of which the most important are
N. Hooftman et al.
summarised below:
• A near doubling of the dynamometer trip distance (from 11,03 km to
23,27 km)
• A far more dynamic driving profile, resulting in higher engine loads
• Higher average and maximum speeds, shorter stop durations
Next to the driving cycle, the ambient test conditions are described
in the test procedure (for a detailed overview see [91]). The changes
with the biggest impact are summarised below:
• A realistic road load determination, ensuring that the test vehicle
resembles the eventually marketed vehicle as closely as possible.
The new determination method results in a higher vehicle test mass
• Lower temperatures at cold start. Ambient testing temperatures are
brought down from the ideal upper part of the [20 °C–30 °C] range
for the NEDC to [14 °C–23 °C] for the WLTP. The lowest threshold of
the latter temperature range sits closer to the European average
temperature of 9 °C, although the upper threshold will most likely
have only a minor effect on the CO2 emission during testing. Due to
the longer cycle length, cold start contribution will be approxi-
mately half of the contribution it had in case of the NEDC
Note that the WLTP's requirements per se aren’t significantly dif-
ferent from its predecessor's, albeit that the level of detail in the reg-
ulatory description of them differs significantly. This is done so that what
is not covered in the legislative texts cannot be used against it, hence
diminishing the potential for exploitation. Nevertheless, the WLTP will
prove to be no holy grail either, as laboratory driving cycles tend to
provide in skewed representations of reality. This was already advised
by the JRC in 2007, when the first testing by means of portable emis-
sions measurement systems (PEMS) took place. Concerning CO2, the
WLTP will induce higher emissions, as it is proven by the JRC in [93].
They analysed the CO2 spread according to the applied test vehicle
characteristics. Three types are distinguished; (1) the NEDC reference
characteristics; (2) the heaviest and worst aerodynamics model of a
vehicle family (WLTP-H) and; (3) the lightest, most aerodynamic one
(WLTP-L). A vehicle family consists of models with identical powertrain
configurations (engine capacity, fuel technology, gearbox type, etc.).
Results from testing 33 cars showed that in the worst case (WLTP-H) an
increase of 11% is measured, while in the best case (WLTP-L) only 1%
extra CO2 is emitted. Note that the JRC's NEDC tests resulted in 8%
higher emissions on average, compared to the official NEDC results.
This percentage should be added to the WLTP-H and –L results. The
influence of more realistic test vehicle configurations hence results in
an average 15% higher fuel consumption. The minor differences be-
tween WLTP-L and NEDC are to be explained by the higher engine ef-
ficiencies which are reached during the longer WLTP cycle [93]. Other
sources confirm that there will be no elimination of the CO2 gap due to
the introduction of the WLTP: ICCT expects a 23% discrepancy by 2020,
which is to increase up to 31% by 2030 as the WLTP gets exploited
[94].
An increase in CO2 emissions could have consequences for the 2021
CO2 target of 95 g/km, however, this issue has more of a political
nature than a technical one. As OEMs are assigned specific fleet average
targets in the 2020 GHG reduction strategy, a sudden increase of CO2
emissions is not warmly welcomed as significant fines are to be paid in
case of non-compliance [95]. Although Regulations 443/2009 and 510/
2011 state that an OEM who manages to perform well on one testing
procedure (in this case the NEDC) should also be able to comply with a
new procedure, the exact correlation between both test cycles is not
clear yet. Therefore, a re-calculation to the NEDC-equivalent CO2
emission will take place by means of the so-called CO2mpas simulation
tool. By means of this tool, testing can already occur under the WLTP
procedures, while the NEDC-based 95 g/km target remains applicable.
For all other regulated pollutants, no correlation will be calculated
[96]. Up to date, the CO2mpas tool has been validated by means of 21
vehicles and results indicate an error margin lower than 5%. The
7
Renewable and Sustainable Energy Reviews 86 (2018) 1–21
question remains whether these 21 vehicles sufficiently reflect what's
being driven on European roads and, more importantly, whether the
error margin will be compensated in favour of better NEDC results.
The timeline for the adoption of the WLTP is as following:
• Up to September 2017: NEDC + OEMs prepare for the transition
• September 2017 – December 2019: NEDC + WLTP for new vehicles
o For monitoring purposes, the legally binding CO2 values remain
based on the NEDC
o OEMs may as well correlate the WLTP results to NEDC by means
of CO2mpas
• From 2020: only WLTP
o Equivalent WLTP value for the 95 g/km NEDC target to be de-
termined
o 12-month phase-in period for the industry; 5% of the highest CO2
emissions will not be counted for the OEMs fleet average
4. Portable emissions measurement systems and European
legislation
The discrepancy between the NEDC, more realistic dynamometer
driving cycles, and reality got evident as soon as tests were performed
with portable emissions measurement systems (PEMS). These were first
used in the earlier mentioned U.S. diesel truck scandal in the mid-
1990s, which eventually resulted in heavy fines, new emission limits,
and the implementation of on-road testing by means of PEMS for trucks
in the U.S. since 2003. The European heavy-duty vehicle (HDV) sector
started with PEMS testing one year later and this resulted in Regulation
595/2009 on the type-approval for HDVs and engines with respect to
Euro VI emission limits, covering in-use and off-cycle emission testing.
The HDV Euro VI standard went into force on the 31st of December
2013. Appendix II of this paper, a timeline is presented for the devel-
opment of the European PEMS framework.
A European on-road testing programme with PEMS for the light-
duty vehicle (LDV) sector was started by the European Joint Research
Centre (JRC) in 2007, although it was only intended for exploratory
purposes. Due to dimension and packaging constraints, PEMS applied in
the HDV field required significant downsizing and hence innovations in
the field of measuring and sensing techniques. Furthermore, the
European automotive industry was not very eager to tighten emission
controls at short notice. This is one of the reasons why LDV-PEMS took
longer to be tested and validated. Nonetheless, a 2011 publication of
the JRC test results revealed considerably high NOx emissions for the 12
tested diesel cars of different Euro emission standards [97]. In the on-
road testing studies following the aforementioned publication, these
findings were confirmed [98–101]. Whereas the earlier mentioned
dynamometer tests on Euro 6 diesels by [86] found an average ex-
ceedance factor of 5 for NOx emissions, real-world PEMS testing by
[102] revealed that this average in fact lies around 6–7 times the limit,
with exceptions up to 20 times the limit (see also [103]). Thomson et al.
revealed that diesel cars available on the U.S. market emitted up to 35
times the federal limit [104]. Based upon this evidence, the U.S. EPA
forced OEM Volkswagen to admit it had been using so-called ‘defeat
devices’ in its diesel cars since 2009. This triggered the exodus of diesel
technology out of the U.S. The Dieselgate scandal, as it got named, will
be discussed further on.
Before the revelations of 2015, the 2011 JRC publication strength-
ened the Commission's previous viewpoint that the test procedure was to
blame, which triggered the introduction of the so-called Real-Driving
Emissions for Light Duty Vehicles (RDE-LDV) working group in that
same year. The group's objective was to develop a complementary test
procedure for the WLTP, which was still in the early stages of devel-
opment. The Commission hereby strived to ensure that vehicles put on
the European roads would comply with the NOx emission regulations
both during type-approval and on the road. Its implementation was
determined to be combined with the introduction of the Euro 6
N. Hooftman et al. Renewable and Sustainable Energy Reviews 86 (2018) 1–21

Table 2 packages have passed the approval. Although the four packages com-
RDE boundary conditions PER 2016/427/EC. plete the whole RDE testing procedure (including post-type-approval
testing and ‘market surveillance’), consolidation of the first two
Parameter Requirements per 2016/427/EC
packages suffice for the introduction of PEMS testing.
Altitude Moderate: 0 to 700 m (Extended: 700 to As will become clear during the overview of the RDE packages’
1300 m) timeline, both the influence of the industry representatives in the ru-
< 100 m altitude difference between start and finish
lemaking process, and the lobbying by the automotive industry have
The cumulative elevation gain is limited to 1200 m/100 kma
Ambient Moderate: 0 °C to 30 °C (Extended: −7 °C–0 °C watered down the striking power of the RDE concept. If the same
temperature and 30 °C–35 °C) parties are responsible for both developing and respecting the rules,
Dynamicsa Max: 95th percentile of v*a Min: RPA (relative conflicts of interest are unavoidable. Due to the intervention of the
(speed*positive acceleration) positive acceleration) automotive industry, RDE testing has been maximally postponed, i.e.
Maximum speed 145 km/h (160 km/h for 3% of the motorway driving time)
from September 2014 to September 2017.
Payload Maximum 90% of the maximum vehicle weight (driver +
equipment)
Stop percentage Between 6% and 30% of the urban driving time
Use of auxiliary Operated as in real life (air conditioning etc.), not to be 4.2.1. RDE package 1
systems recorded The first package describes the general features of the PEMS pro-
a cedure. This consists of test equipment requirements, test trip char-
Added by means of the 2nd RDE package.
acteristics, a description of the data evaluation tools, the concept of
PEMS vehicle families, and reporting requirements.
emission standard in 2014. In the following subchapters, an overview is
A PEMS test trip should be performed on public roads and in real
given of how PEMS testing will be applied in Europe from September
traffic. A set of trip requirements has been determined which consists of
2017 onwards, and thus three years behind schedule. Accompanied by
(inter alia) altitude boundaries, temperature ranges and dynamic con-
the timeline presented in Appendix II of this report, it highlights the
ditions. For both altitude and temperature boundaries a distinction is
different steps which were taken to consolidate a regulatory framework,
made between moderate and extended conditions. In case of the latter,
and what is still required.
the emission factor shall be divided by a factor of 1,6. In case the test
conditions exceed the extended range, the whole trip shall be deemed
4.1. Complementary testing for type-approval invalid. To prevent OEMs from selecting RDE test routes that allow only
minimal compliance to the requirements, at least 50% of the PEMS tests
In the early stages of the RDE-LDV development, four possibilities are to be performed by type-approval authorities (TAA) or their re-
were investigated for complementing the dynamometer-based type- presentatives. An overview of boundary conditions is given in Table 2,
approval procedure, being while the trip specifications are given in Table 3.
Once the trip is determined to have fulfilled all the above-men-
• multi-cycle testing; tioned conditions, the normality of the dynamics for both the urban,
• emission modelling; rural and motorway part will be verified by means of a post-processing
• running a random-cycle generator during type-approval's dynam- method. In this way, the PEMS test dynamics are in fact converted to
ometer testing, and; those of a type-approval test [107]. Trip dynamics are assessed for
• on-road emission testing by means of PEMS being not too ‘tame’ or too ‘high’ (i.e. aggressive). This aspect results
from an amendment to the 1st regulatory RDE package in the 2nd
As modelling was not feasible at that time, the option was ruled out package.
in an early phase. Multi-cycle testing resembled the U.S. type-approval In October 2013, a task force was created to define which evalua-
and was favoured by the OEMs, although it was found to be susceptible tion of the RDE test data would be performed. Three methods were
to cycle recognition and thus tampering. In [105] random-cycle testing analysed for this purpose, i.e. by means of a) speed-binning; b) power-
and on-road testing were further scrutinised. This option provided the binning and; c) moving average windows (MAW). A brief overview of
advantage that the knowhow for dynamometer tests and the laboratory these options is presented below.
equipment was already established, while PEMS testing would allow a
wider range of driving conditions to be covered, and would be the best
measure against defeat devices or other forms of tampering. What be- 4.2.1.1. Speed-binning. In this method, which was developed by TNO,
came clear from the Member States was that a complete RDE test all emission data is collected and subdivided per speed intervals of
procedure was desired, which is why the further development of PEMS 5 km/h. The assessment of NOx is then made against the ratio of the
testing was supported. Random-cycle testing was nevertheless retained emitted mass of CO2 during the test to the emitted mass during type-
as a backup option. approval. This approach was not retained for further development. For
more information refer to [107].
4.2. RDE packages
Table 3
One central argument from the car industry against PEMS testing SPecification of the RDE trip concerning speed and driven distance PER 2016/427/EC.

was that on-road testing barely allows repetition, due to the exogenous Trip Characteristics Requirements per 2016/427/EC
variables that influence the test results. For the sake of reproducibility
and comparability of the PEMS test data, the PEMS test procedures Average Speeds Urban 15 to 40 km/h
were decided to be consolidated into four regulatory packages. Each of Rural 60 to 90 km/h
Motorway > 90 km/h
these packages is prepared and validated by the RDE-LDV, which Distance Urban > 16 km
consists of technical experts, but is dominated by stakeholders from the Rural > 16 km
automotive industry [106]. Once a package is finalised, it is proposed to Motorway > 16 km
the Technical Committee for Motor Vehicles (TCMV), which is re- Trip Composition Urban 29% to 44% of the total distance
Rural 23% to 43% of the total distance
presented by national experts from the various Member States. In the
Motorway 23% to 43% of the total distance
end, it is the European Parliament that has the final authority to accept Total Trip Duration 90 to 120 min
or reject the TCMV's decisions. Up to date, three of the four RDE

8
N. Hooftman et al.
Fig. 3. An example of the power-binning method for two vehicles. The bin weights should
lie between the minimum and maximum tolerance for the trip to be valid (based on
[108]).
4.2.1.2. Power-binning. By means of power-binning, the instantaneous
test results (in grams/second) are evaluated by normalisation to a
standardized (wheel) power frequency (SPF) distribution (or load
cycle). This method was developed by the Technical University of
Graz (TUG) as the CLEAR method.
The CLEAR software classifies the different emission masses into
maximum nine different wheel ‘power bins’. These are in turn weighted
to obtain emission values for a test according to a normal power dis-
tribution. The wheel power is either measured or calculated from the
instantaneous CO2 emissions. Three-second moving averages are used
to even out possible time alignment issues between mass flow and
wheel power. The power class frequencies should be represented for
both urban and total trip driving, according to percentages given in
Appendix 6 of Regulation (EU) 2016/427.
Fig. 3 shows an example for the power-binning method as it can be
found in [108]. Certain normality checks are built-in, e.g. verifying that
at least 10 emission values are represented in each relevant power bin.
The distribution of the emission masses in the different bins is com-
pared to a target curve, outliers from the minimum and maximum are
deemed non-representative of ‘normal’ driving.
4.2.1.3. Moving average window (MAW). The moving average window
method consists of sub-dividing the RDE test results in windows based
upon a reference CO2 mass. The length of each window is defined by
50% of the CO2 mass measured during WLTC type-approval test for the
specific vehicle. Depending on the sampling frequency, a new window
will start with each time increment, unless the vehicle is idling
(v < 1 km/h). Once all windows are completed, a statistical treatment
takes place to eliminate the windows that do not represent ‘normal’
driving conditions. From the remaining windows, the cumulated mass
is calculated and a g/km emission factor is defined per window.
Depending on the driving behaviour, the length and time of the
windows can differ significantly [109].
Once the different window masses are plotted as a function of test
speed, reference points are determined to define the vehicle char-
acteristic curve based on the WLTP's Low, High and Extra High Speed
averages. These points are shown as red dots in Fig. 4. Next, a primary
tolerance of ± 25% is defined, based on the characteristic curve, re-
presenting the ‘normal’ driving boundaries. A secondary tolerance
of ± 50% is then applied, forming the boundaries for acceptable
window masses. Based upon reference speeds, the results are segmented
into an urban (v < 45 km/h), rural (v ≥ 45–80 km/h) and motorway (v
≥ 80–145 km/h) trip window. This software tool was developed by the
JRC and is described in Annex 5 of Regulation 2016/427/EC as the
EMROAD method. Like the CLEAR method, both urban and total trip
emissions are dealt with.
The test is found complete if at least 15% of the windows comprises
urban, rural and motorway driving. In addition, normality is obtained
when at least 50% of all windows is within the primary tolerance. If the
9
Renewable and Sustainable Energy Reviews 86 (2018) 1–21
window's average sits between 25% and 50% of the tolerance, a
weighting factor is applied, ranging from 1 for 25% to 0 for 50%. For
the calculation of the total trip emissions, the three trip windows are
weighted as follows: urban 34%, rural 33% and motorway 33%.
4.2.1.4. Vehicle selection and PEMS test family. Like the NEDC and
WLTP type-approval procedures, vehicle test families are determined
to reduce the number of required tests. Such families comprise similar
emission characteristics and are identified by to the following
requirements: a) an identical powertrain configuration, b) the same
fuel type, c) the same cylinder configuration, and d) the same engine
volume. Concerning the latter, a certain margin is allowed, as the
variance in cylinder content may reach up to 22% if the engine is larger
than 1500cc, and up to 32% if the engine is smaller than 1500cc. At
least one type of each engine should be tested by means of PEMS.
This first RDE package was adopted by the European Council in May
2015 [111] and was consolidated in Regulation (EU)2016/427 in
March 2016. Meanwhile, an RDE monitoring period started on April
1st, 2016. Both EMROAD and CLEAR are prescribed in the RDE legis-
lation and provide a single emission factor that can be compared to the
type-approval value in turn. OEMs can decide which of both software
tools is applied for the normalisation. A preliminary comparison of the
two normalisation tools performed by the Association for Emissions
Control by Catalysts (AECC), however, showed that both tools have
different impacts. Compared to the raw NOx emissions, the normal-
isation results vary from −24% to +42% for EMROAD and CLEAR,
respectively [108]. This is confirmed by [87], who indicate that the
possibility for the OEM to choose between the two tools can induce
selectivity.
What should be kept in mind from package 1 is that although PEMS
testing will address real driving emissions, the automotive industry
succeeded in excluding extreme engine operation conditions.
Nevertheless, these are found to add considerably to the total NOx (and
other pollutant) emissions. Regulation 2016/427/EC does not quantify
nor limit the share of the boundary conditions to be excluded. Hereby
the emission behaviour of a diesel car in e.g. a Scandinavian country
during wintertime, is not represented by the real driving emissions
framework. The same is true for emission testing in extremely warm
conditions.
4.2.2. RDE package 2
The second RDE package consists of not-to-exceed (NTE) emission
limits and their respective application dates. As the NTE limits de-
termine the overall strength of the RDE procedure, significant re-
sistance was to be expected at the time of approval by the Technical
Committee on Motor Vehicles (TCMV), and eventually the reassessment
by the EU Parliament. The reason is that NTE determines to what extent
the European OEMs would have to cut in their profit margins, as tighter
limits require the implementation of AECDs, such as lean NOx traps
(LNT) and/or selective catalytic reductions (SCR) systems. This is in
fact similar to the reduction of PM by diesel cars below 5 mg/km, as
described in Regulation No. 715/2007, which forced every manu-
facturer to implement DPF technology.
As mentioned earlier, the representation of the Member States in the
TCMV has got a strong political edge. National experts do not only
represent their respective Member States, but also their respective na-
tional industries. This is an important drive to water down regulations,
to keep the automotive industry competitive compared to the other
automobile-producing Member States and markets around the world.
Moreover, the automotive industry is an important pillar for the
European economy. Tightening diesel emissions to similar levels as seen
in the U.S., would result in dwindling diesel car sales, and thus in de-
creasing revenues for the European vehicle market as the technology
would become too expensive for e.g. small cars. This should be con-
sidered when overviewing the 2nd RDE package development.
For the automotive industry to be allowed sufficient lead-time to
N. Hooftman et al.
Fig. 4. Graphical display of the vehicle CO2 characteristic curve (thick black line), based upon the three reference points representing the average speeds of urban (P1), rural (P2) and
motorway (P3) driving over the WLTC. Notice that window mass vj is located within the 25% tolerance and is hence retained as a ‘normal’ driving window average (based upon [110]).
Fig. 5. Overview of the diesel emission limits for NOx since Euro 3.
adapt her strategies, a two-phase approach would be implemented to
bring down the RDE NOx emissions. Instead of imposing compliance
with the 80 mg/km limit, conformity factors (CF) – or multipliers –
would be introduced. By doing so, a Euro 6d temp and a Euro 6d limit are
developed for 2017 and 2019, respectively. Whereas the original set of
CFs proposed by the Commission comprised a multiplication by 1.6 by
2017 and 1.2 by 2019, strong lobbying by the industry representatives
prevented this [112]. Instead the TCMV watered down the 2017 CF to
2,1, postponed the 2019 deadline to 2020 and increased its CF to 1,5.
Due to the approved 2017 conformity factor, only minor improvements
will occur concerning real-world NOx emissions. The reason for this is
that the limit would only outperform the Euro 5 NOx ceiling of 180 mg/
km by 7%, although the former was agreed upon in 2007. An overview
of the NOx limits from Euro 3 until Euro 6d is given in Fig. 5. Despite a
draft motion for a resolution from the Environment Committee, pro-
posing to veto the TCMV's decision, the European Parliament rejected
this request [113]. As a compromise the 2020 CF is to be reviewed
annually, to keep up with the technical improvements to the testing
equipment. The ACEA's argument for the application of these more
relaxed CFs are the proclaimed technical uncertainties of the PEMS,
which results in the 2020 CF of 1 + 0,5 (i.e. the uncertainty margin)
[114]. Evidence against these accuracy arguments were well known to
the Commission, as it was advised by the JRC in 2015 that the un-
certainty ranged from 20% to 30% (or 15–21 mg/km in case of an
80 mg/km limit). Moreover, PEMS manufacturers could effectively re-
duce the uncertainty to 10–15% in the short-term [115]. In the same
context of type-approvals, laboratory equipment that is used in the
current NEDC procedure is subjected to measurement uncertainty as
10
Renewable and Sustainable Energy Reviews 86 (2018) 1–21
well. In this case, though, the Commission adopted the regulatory need
for OEMs to comply with the specific limit plus the equipment's un-
certainty. The finalisation of the second RDE package was thus a win for
the OEMs, given that current PEMS are in line with the stationary la-
boratory equipment that is used nowadays, in terms of reliability and
accuracy [116].
Complementary to the conformity factors, the Not-To-Exceed
emission limit is characterised by an extra transfer function (TF), as can
be seen in Eq. (1). This second multiplier is set to 1 unless the severity
of driving conditions would require extreme emission control. Reg.
(EU) 2016/646 indicates that if the transfer function would be applied, it
should not lead to the weakening of the environmental effect and the ef-
fectiveness of the RDE procedures. This is an extra means for the OEM to
water down the NOx emission results, in case driving conditions cannot
be categorized as ‘normal driving’. The TF is deemed necessary ac-
cording to the ACEA, to meet the political request to cover 99% of the
engine's operation range and ambient conditions. Without it, a higher
overall CF would be needed [117]. As the controversial transfer function
has made it into the official publication of the 2nd RDE package, a total
of four filters is applied on the raw RDE data. Firstly, driving conditions
not categorized as ‘normal’ are excluded; secondly the data evaluation
further brings down the average NOx emission, before, thirdly, the
conformity factor is applied. Finally, the transfer function could be
applied to water down potential emission peaks even further.
NTE = CF × TF × Euro 6 (1)
The approved conformity factors, together with the potential
transfer function, thus undermine the potential of the entire RDE ap-
proach, and thus curb the chance for the EU to finally start improving
N. Hooftman et al.
the urban air quality levels. The margin that OEMs are granted for the
coming years is especially striking when they are compared to what
Emission Analytics (EA) claims to be feasible. Based upon hundreds of
PEMS tests they already performed on European cars, EA states a CF of
1,25 would already be feasible, as there are diesel cars on the market
which effectively respect the 80 mg/km limit [118]. So, whereas this
package was in fact originally meant to serve as the backbone for the
credibility of the whole RDE approach, it allows OEMs to continue on
their path of incompliance for NOx emissions. Dynamometer and later
RDE testing has shown that this path leads us back to the introduction
of the Euro 2 emission standard in 1996. The second RDE package was
voted in October 2015 and published in April 2016 under Regulation
(EU)2016/646.
China's 6th emission standard, which was approved in December
2016 for introduction in July 2020, also includes RDE testing. The
framework is primarily based upon RDE package 2, as it is described
above. The main difference with the EU's approach is the introduction
date, as between 2020 and 2023 the Chinese RDE testing will be only
applied for monitoring purposes. From 2023 onwards, a conformity
factor of 2,1 will be applied for both NOx and PN measurements, al-
though this factor will be evaluated by July 2022. Moreover, China will
apply a maximum speed of 120 km/h whereas in Europe this is set to
145 km/h. Altitude boundaries are extended further to 2.400 m, al-
though this is accompanied by an increased correction factor (1,8) as
well [51].
4.2.3. RDE package 3
By means of the third RDE package, the focus was put on the in-
clusion of cold start emissions, particulate number emissions by petrol
cars, the definition of a test procedure for hybrid technologies, and
provisions for the event of an AECD regeneration.
Whereas diesel cars are imposed to the limit of 6.0 × 1011 particles
per kilometre since the introduction of Euro 5 in 2009, this will also
become the rule for all petrol cars from Euro 6d onwards. This limit is
relevant as direct-injection petrol engines (GDI) are quickly gaining
market share as their inherent fuel efficiency nearly equals the effi-
ciencies obtained with diesel technology. The downside of GDI however
is that they emit up to a thousand times more particles as the con-
ventional, port-injected petrol engine. Compared to filtered diesel cars,
GDI technology emits on average 10 times more particles [119]. For
this reason, GDIs will become submitted to the same PN limit from
September 2017 onwards. As these emissions will also be measured
during RDE testing, the automotive lobby urged to be granted two more
years to comply with the limit. This request was nevertheless rejected
by the TCMV, although a conformity factor of 1.5 is approved for the
RDE testing of GDI cars. This ensures that GDI cars will be equipped
with a gasoline particulate filter (GPF) [120,121]. Like its diesel
counterpart, the GPF is known to largely reduce the GDI's PN and PM
emissions over the entire range of engine operation [122].
A major accomplishment in the framework of RDE NOx testing is the
inclusion of the cold start in the post-processing of raw PEMS data.
Originally the first five minutes of registration were excluded from the
data, however cold starts contribute significantly to the overall vehicle
emissions [123]. Moreover, 30% of the trips made by car in the EU
cover distances of less than 3 km, while 50% are shorter than 5 km
[122]. By including cold start emission monitoring in the RDE testing,
OEMs are enforced to make sure catalysts warm up quickly to get cold
start emissions under control as soon as possible. The cold start effect is
characterizing for urban trips, during which the exhaust gas tempera-
ture mostly does not reach the threshold for lighting off the SCR cata-
lyst, which compromises the NOx conversion. By adding the cold start
to the total PEMS data, contributions to NOx by diesel cars can reach up
to + 38% [108]. Cold starts also affect PN emissions, which are found
to contribute to up to 86% of the PN emissions in case of an unfiltered
GDI [124]I.
At the time of writing this paper, no further details were disclosed
11
Renewable and Sustainable Energy Reviews 86 (2018) 1–21
on hybrid RDE testing or DPF regeneration. Neither has the Commission
announced when the measures approved in package 3 will be in-
troduced. This is another potential weakness in the regulation, as more
lead-time for the OEMs concerning cold start emission conversion will
postpone the delicate improvement of local air quality. The 3rd RDE
package was approved on the 21st of December 2016. In China's variant
of RDE program, cold start emissions are currently excluded from the
test evaluation [51].
4.2.4. Package 4
The final regulatory package for the RDE PEMS testing consists of
in-service testing and market surveillance. As discussions on these to-
pics still have to start, little is known about when and how they will be
implemented. In-service conformity (ISC) testing was introduced in the
heavy-duty vehicle sector in 2014, and is an essential tool to gauge the
effectiveness of a regulation. In the U.S., ISC is not new either, as it is
part of a far more robust regulatory system of type-approval and sur-
veillance program.
Whereas the vehicle testing program prior to mass production is
more or less similar for the U.S. and the EU, it is the random re-testing
by independent authorities in the U.S. that make the difference. ISC has
proven to be an effective incentive for OEMs to guarantee that their
product complies with the regulations. Up to date, there is no such re-
retesting by an independent authority foreseen by the EU regulations. It
is for this reason that the next chapter is dedicated to the potential
improvements of the European type-approval process, based upon the
lessons learned from its U.S. counterpart.
5. Potential for the EU Type-approval
The European type-approval process is found to have failed, as RDE
testing has revealed. To get a thorough understanding of where the
legislative framework leaves ‘room for interpretation’, a comparison is
made with the robust framework developed by the US EPA. By means of
the 4th RDE package, in-service testing will close the final gaps in the
European type-approval system, as the first three packages refer to the
development of pre-production vehicles. Although these are deemed to
be representative of the eventual end products, the proof will be in the
testing of these cars once many kilometres have been driven.
5.1. From concept to production
Before a prototype of a new vehicle type can go into mass produc-
tion, it will need to demonstrate compliance with all the technical and
administrative requirements to be sold in the EU. Type-approval of a
new vehicle type is authorised by the national type-approval authority
(TAA) and/or by the technical services (TS) they have accredited.
Germany, for example, has over 80 independent technical services
listed, while other technical services abroad might be certified to per-
form testing in Germany as well. Once the TAA and TS are chosen, the
OEM can either have the vehicle tested at the TS’ facilities or at its own
premises, given the infrastructure and a witness from the TS are pre-
sent. The OEM is free to choose between any TAA of the EU28. There is
a distinction between whole vehicle type-approvals (WVTA) and the
certification of subsystems or components. In this way, the vehicle's fuel
consumption and emissions can be certified in country A, while the
WVTA certification takes place in country B [125].
Prior to dynamometer testing, the road load of the vehicle is de-
termined by means of a coast down test. Road load parameters are
necessary to simulate the vehicle's inertia, rolling, and drag resistance
on the dynamometer. Once the dynamometer input is known, emissions
over the NEDC can be measured. Concerning the testing of the regu-
lated pollutants, just one variant of a new vehicle type is tested, pre-
ferably the one of which one expects the highest emissions. For CO2
however, every variant of the new type is tested, as their emissions are
required for the calculation of the OEM's fleet average CO2 emissions.
N. Hooftman et al. Renewable and Sustainable Energy Reviews 86 (2018) 1–21

Pollutant and CO2 emissions do not necessarily need to be tested si- Table 5
multaneously, or on the same vehicle [125]. In-production testing in the EU and the U.S.
The so-called certificate of production (CoP) is the last step for the
Europe U.S.
OEM to take to guarantee every produced vehicle complies with the set
standards. Instead of proving this by sampling several cars from the Conformity of
production
• Random
OEM
sampling by the • Selective audit by
US EPA/CARB
production line, it suffices to demonstrate that the production process is
standardized and certified by means of an ISO norm. Random testing of (COP) • CO 2emissions may be 8%
higher than type-approved
in-production cars is required for CO2 certification, although their model
emissions can be 8% higher than the type-approval figure (cf. 3.4.1.
NEDC versus WLTP). Besides tests performed by the OEM, European
• ISO
COP
standard guarantees

legislation does not require confirmatory testing by independent orga- • No confirmatory testing
nisations. The type-approval certificate, together with the ISO norm, is
thus seen as the only needed proof of compliance.
performed by the OEM (at a rate of 3–20 vehicles per model family
Concerning the financial compensation for type-approval, there is a
every two years). TAAs aren’t incentivized to perform any further
direct link between the services and the OEM. Moreover, the OEM has
market surveillance, as the outcome cannot have any legal con-
the choice where to have the type-approval performed. This creates
sequences for an OEM. In the U.S., 1 to 5 low- and high-mileage ve-
selectivity in favour of the most lenient TAA, and a competition be-
hicles per model test group are tested per year per OEM. In the worst
tween the TAAs in a race to the bottom. If the vehicle fails the tests, the
case, a recall of vehicles in the market could be initiated. Concerning
OEM can address another TAA, as there is only limited communication
transparency, the U.S. EPA has the authority to request any relevant
between TAAs due to non-disclosure agreements with the OEMs. All
data from the OEMs. By means of fees collected from OEMs, the U.S.
these factors create a certain conflict of interest.
EPA covers the expenses for various certification applications and
Only in a few Member States testing of random cars takes place by
compliance programmes, while in-use testing takes place at the OEM's
independent institutions. The result of these tests, however, has only an
facilities, at its expense [125,128,129].
informative nature, as it cannot be legally held against the OEM in case
The European type-approval process will be redesigned based on the
of incompliance. In fact, if Member States were to take unilateral ac-
North American model. The proposed review of Directive 2007/46/EC
tion, this would entail the risk of creating obstacles for the free move-
was adopted in January 2016, and is under review by the European
ment of motor vehicles ensured by the framework legislation [126].
Parliament and the Council. Once adopted, it will be directly applicable
The U.S. approach differs from what is done in Europe. Firstly, the
and will repeal and replace the current Directive. This new framework
U.S. EPA is given the authority to verify that every vehicle on the road
is widely supported by the academia and NGOs. After more than two
meets the standards throughout its useful lifetime. This time is defined
decades of relaxed regulations and wrongfully relying on the respon-
to 241.000 km, whereas European law requires optimal AECD opera-
sibilities of the OEMs, Europe looks forward to a clean start. The pro-
tion until 160.000 km. In the latter case, this mileage is performed on
posed type-approval restructuring for Europe is discussed in sub-
dedicated engine test stands, whereas in the U.S., real vehicles are se-
chapter 5.3. 'A reviewed type-approval procedure’. This transition has
lected from traffic and are tested at 16.000 and 80.000 km. Another
proven not to be easy, and raises questions on which responsibilities
difference lies in the fact that the U.S. EPA can submit OEMs to fines in
should be allocated to either the Commission or the OEMs.
case of incompliance, whereas this responsibility in the EU is attributed
Interpretations of European law have led to a confidence crisis, which
to the Member State in which the vehicle was type-approved. In addi-
escalated in September 2015 as a European diesel car manufacturer
tion, no uniform penalising scheme is applied in Europe. A detailed
violated both U.S. and EU regulations. This triggered a round-up of the
overview of the differences between EU and U.S. regulations is pre-
other European OEMs. Based on the EU law, however, OEMs claim they
sented in [127], of which a summary is given in Table 4, Table 5 and
have not breached the requirements. This is discussed in 5.2. 'The use
Table 6.
and claimed authorisation of defeat devices’.
In the EU, most of the testing is performed by the OEM, during the
Considering the Chinese type-approval reform, the ‘China 6’ emis-
pre-production stage. The law requires no independent confirmatory
sion standard framework will include in-service testing by national
testing. In the U.S., most of the testing is performed by the OEM as well,
authorities. Whereas manufacturers are required to test their vehicles at
however, the regulator will double-check the OEM's results for the
both low (10.000–60.000 km), medium (60.000–110.000 km) and high
various steps in the type-approval and in-use process. In case of in-
(110.000–160.000 km) mileages and report their results to the reg-
compliance, financial penalties are effectively issued by the regulator,
ulatory agency, the latter can randomly perform in-use testing as well
as has been proven in the past. As the regulation for the execution of
[51]. In addition, manufacturers are to warrant a list of auxiliary
road load testing is vague in the EU, it leaves room for interpretation.
emission control devices (AECD) for a minimum of 3 years or
This is reflected in measured emissions that are no longer re-
60.000 km, whichever occurs first.
presentative for normal vehicles, as an idealisation of the vehicle
weight and road load parameters takes place (“golden cars”). As certain
European test results aren’t publicly accessible, no comparison is pos- 5.2. The use and claimed authorisation of defeat devices
sible between different, independent laboratories (i.e. ‘round robin
testing’). The European variant of in-use testing consists of a few tests In September 2015, the so-called ‘Dieselgate’ triggered a worldwide

Table 4
Type-approval testing in the EU and the U.S.

Europe U.S.

Coast-down/road load testing
Laboratory testing
• Test results not publicly available • Public test results
• No confirmatory testing • Periodic confirmatory testing by US EPA/CARB
• ‘Golden car’ is tested over NEDC (i.e. optimised for testing) • Highest emitting production model tested over 5 cycles
• Vehicles are tested per type/family: same inertia mass, engine and • Approx. 15% of production cars tested by regulator
vehicle characteristics • ≥90% of the different vehicle configurations tested for CO
• No confirmatory testing
2
emissions per model year

12
N. Hooftman et al.
Table 6
Post-production testing in the EU and the U.S.
Europe
In-use surveillance • Informal testing in some Member States
• No legal consequences
• Durability tests during type-approval process, not for CO
scandal concerning diesel passenger cars. These were found to be pro-
grammed to deliberately cheat the type-approval procedure, to keep the
true diesel NOx emissions under the radar. Triggered by findings of the
ICCT, tens of millions of diesel cars worldwide were found to be
equipped with malfunctioning NOx conversion systems. The culprit in
the U.S. car market turned out to be Volkswagen, which is now subject
to multibillion-dollar claims. This scandal has most likely announced
the end of light-duty diesels in North-America [130–132].
In a 2016 study, Transport & Environment reported that
Volkswagen is in fact the cleanest among the collective of European
OEMs when it comes to diesel NOx emissions [79]. These cars, never-
theless, do not necessarily represent U.S. bound diesel cars, due to the
different legal framework compared to the EU situation. Even though
the base engines are the same, they require different calibration and
after-treatment strategies. For example, U.S. diesel cars are typically
equipped with SCR/LNT/both, in combination with EGR. In Europe,
some manufacturers only apply EGR, as it proves to be sufficient to
comply with the EU regulation. As mentioned earlier, European OEMs
who import ‘clean diesel’ technology into the U.S. market, are required
to fully disclose auxiliary emission control devices (AECD). This in
sharp contrast to the situation in the EU, where the same OEM claims
that such a disclosure is an infringement on intellectual property
[131,133,134].
Dieselgate launched the term ‘defeat device’ among the broad
public. A defeat device is described in Reg. (EC) 715/2007 to “sense
temperature, vehicle speed, engine speed, transmission gear, manifold va-
cuum or any other parameter for activating, modulating, delaying or deac-
tivating the operation of any part of the emission control system, that reduces
the effectiveness of the emission control system under conditions which may
reasonably be expected to be encountered in normal vehicle operation and
use”. This definition originates from Regulation 98/69/EC on Euro 3
and 4 vehicle emission regulation and in fact remained unaltered up to
date. In U.S. regulations, this description is nearly identical. The dif-
ference lies in the way OEMs are granted exemptions to the rules.
Concretely, EU regulation is provided with far less detailed steps and is
more general. For example, it neither assigns an authority to review the
application AECDs nor does it collect all relevant information for the
exemption of them. In addition, no terms are defined on which approval
or denial should be based [41]. This leaves an open playing field for the
OEMs to bend the law into their favour.
Whereas U.S. regulation elaborately describes emission reduction
systems and their application, EU regulation provides a rather vague
description of the ‘emission control system’ (onboard diagnosis or OBD);
the electronic control units (ECU) and any emission-related component in
the exhaust or evaporative system which provides input or executes output
from the ECU. This general definition is exploited by various European
OEMs as e.g. the exhaust gas recirculation (EGR) is not deemed to be
part of the exhaust control system when strictly following the regula-
tion. Moreover, EU regulation specifies that the prohibition of defeat
devices shall not apply in case the AECD is justified for engine protection
against damage or accident and for safe operation of the vehicle [135]. As
an EGR system is claimed to clog the engine intercooler at low inlet air
temperatures and to reduce engine cooling at high loads, the statement
is rigorously exploited in the EU. This is shown in [136], which com-
pares the average European temperature of 9 °C to the temperatures at
which OEMs shut off pollution control, ranging from below 5 °C to
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Renewable and Sustainable Energy Reviews 86 (2018) 1–21
U.S.
• In-use compliance testing by OEM at 16.000 and 80.000 km
• About 2000 tests/year over the entire industry
• Random testing by independent organisations/regulator
• Financial consequences in case of incompliance
2
below 17 °C; in case of high speeds; and when the car is fully loaded
(physically by passengers). In addition, systematically higher emissions
after a ‘hot restart’ of the engine are reported. This indicates that most
likely not all applied defeat devices are known yet.
The term ‘normal engine use’ was/is widely interpreted by the
OEMs as the need for engine protection is overexploited to comply with
the regulations, albeit only during type-approval. This situation has
escalated in such a way that the assessment of high exhaust gas emissions
and their attribution to illegal defeat devices is no longer a matter for en-
gineers and technicians but of jurisprudence and the legislators who must
seek a legislative solution [137]. This indicates that a fundamental review
of the type-approval framework is urgently needed. By doing so, a clear
distinction should be made between the responsibilities for the OEMs
on the one hand, and the European Commission as a supervising organ
on the other hand.
5.3. A reviewed type-approval procedure
The whole process of pushing through a entirely new regulation for
the automotive industry is not made easier by the fact that both air
quality and the transport industry are represented by two different EU
Commission departments, i.e. one for climate and one for the industry.
In the U.S., the EPA represents both, as the two subjects are closely
related. Contrary to the U.S.’ centralised authority, the national TAAs
are responsible for the compliance of their countries’ products, while
the Commission provides guidance. The same is true for market sur-
veillance. Due to this lack of authority, the Commission has not got the
possibility to withdraw type-approvals, especially as the current reg-
ulation does not stipulate a test procedure for the detection of defeat
devices. As the Member States are reluctant to penalise their industry, a
conflict of interest stands in the way of effectively acting against
emission fraud. Moreover, how can an OEM be accused of fraud if its
products comply with the NEDC procedure? A ‘regulatory moratorium’
that was called into life in 2012 did not ameliorate the situation either,
as unnecessary regulation and red tape for the automotive industry was
reduced as much as possible, to avoid relocation of the industry and the
job losses resulting from it [138].
The proposed review of Directive 2007/46/EC for the type-approval
process was already in an advanced stage of development when the
diesel emission scandal was published. The latter, however, served as a
catalyst to speed up its finalisation. In the proposal, the Commission
recognises that differences in the interpretation and strictness in ap-
plication of the requirements across the Member States have a detri-
mental effect on the effectiveness of the framework. Therefore, the
following is proposed [126]:
• To introduce a market surveillance framework to complement the
type-approval requirements
• To stipulate the procedure for recalls in case of incompliance
• To harmonise type-approval and conformity of production proce-
dures applied by the national type-approval authorities (TAA) and
technical services (TS)
For this last issue, the Commission needs to ensure that commu-
nication between the different technical services is obliged. This would
prevent OEMs from ‘shopping’ between TAAs/TSs by means of a
N. Hooftman et al.
uniform approach. By monitoring the TSs at a minimum time interval,
one hopes to guarantee that they can keep up with the technological
developments, and remain competent to carry out the required tests.
This monitoring would be designated to the Member States, while the
Commission overviews the process in its supervisory role by means of
independent audits and verification testing by the JRC. In addition, TSs
will be granted the right to do unannounced factory inspections and
conduct laboratory tests. The Member States should cover the funding
of the TSs via a type-approval fee. TAA performance should be regularly
checked by means of peer-review to ensure a uniform quality level
across the Member States. Next to these compliance checks, the
Commission should also organise ex-post compliance verification tests
and inspections.
Concerning penalties for the infringements of the regulation,
Member States should lay down their rules and ensure adequate im-
plementation of them, to be reported annually to the Commission.
Nonetheless, this means no uniform penalty system is proposed, al-
though a list of infringements should be covered. In-service conformity
(or in-use testing) is seen by the Parliament as part of the market sur-
veillance framework, and consists of test stand and on-road measure-
ments carried out by the market surveillance authorities. These are
national authorities that are independent of any TAA, and are to be
regularly audited. The market surveillance results should be publicly
available within one month of conclusion. An important authority that
is proposed to be granted to the Member States is that they should be
able to take measures against incompliant vehicles sold in their national
market, without having to wait for the TAA that certified the vehicle to
take action (as it is the case now) [126,139].
5.4. Discussion
As has become clear over the last two decades, OEMs should no
longer be given the freedom to interpret legislation. The different ap-
proaches on the U.S. and EU markets did not only result from stricter
NOx emission limits by the former but mainly by the level of detail in
the restrictions imposed by its regulator. While the EU Commission
trusted the automotive industry to follow the spirit of a rather ‘general’
regulation, this trust backfired and created a European ‘diesel island’
with no equal worldwide. The European automotive industry thrived on
the relaxed limitations for diesel cars, and even tried to export this
expertise to new markets (U.S., Japan, South Korea, etc.). Due to the
Dieselgate revelations, these ambitions were quenched [140,141].
Nevertheless, the European consumer does not appear to worry too
much about excessive NOx emissions or its adverse effects, although the
European diesel car sales have dropped by 2,6% to 49,3% in the first
nine months of 2016 [142]. This is the lowest level since 2009 and the
fastest decline in a decade. Even though diesel cars are forecasted to
lose terrain in the coming decade, it still is the most crucial technology
to reach the 2021 CO2 targets according to the car manufacturers
[142,133].
In the VW case, the interpretation of the regulation was reported by
the Committee of Inquiry into Emission Measurements in the
Automotive Sector (EMIS). The concern's representative indicated that
cycle recognition is necessary to allow comparability and reproduci-
bility of the test results. Moreover, it was clear from the start (for them)
that the imposed emission limits only targeted the test procedure. As
the regulation required no declaration of software interventions to
prevent the AECDs from proper conversion, they see no illegal practice
in it. Contrary to the approach in the EU, U.S. regulation considers
every different engine mapping to be a defeat device unless proven
otherwise. This contrasts with the situation in Europe, where such en-
gine strategies are defended as measures to protect the engine. This tide
has started to turn, as from 2016 EU OEMs have to declare their aux-
iliary emission strategy/base emission strategy (AES/BES), as in the
U.S.’ case. This happens during type-approval and ensures that AECDs
are not illegally turned off. The negative side of this regulation is that
14
Renewable and Sustainable Energy Reviews 86 (2018) 1–21
TAAs are burdened with hundreds of pages of explanations [133,134].
In addition, RDE forces OEMs to recalibrate their engines, e.g. to widen
the EGR operation from a temperature range of 17 °C–35 °C, to a range
between 5 °C and 60 °C. Despite the delays which the OEMs managed to
be granted through extensive lobbying [143], RDE testing will force to
bring down the real-world driving emissions by passenger cars sig-
nificantly. Although relaxed conformity factors have been approved,
excessive emissions with conformity factors ranging from < 1 to over
20 will be drastically brought down to CFs of 2.1 and 1.5 by 2017 and
2020, respectively. Given the average lifetime of passenger cars of
about 15 years, complemented by the fact that it will take several years
before the complete set of four regulatory RDE packages will be in
force, the contribution by diesel passenger cars to poor local air quality
levels will remain significant in the coming decades.
Concerning market surveillance/in-service testing of the active
passenger car fleet, the periodic technical inspection (PTI) in Europe
has a strong potential. To date, every car within the European Union
should be presented for PTI at the age interval 4-2-1, meaning a first
inspection will take place when the vehicle is 4 years, then when it
becomes 6 years old, and subsequently every year. The current PTI
system focuses on filtering out the “high-emitters”, although the latter
term dates back to the days when diesel cars with a particle filter were
an exception to the rule. Typically, diesel cars with black carbon ex-
haust plumes were targeted, as spark-ignited vehicles were less sus-
ceptible to emission test failures. In se, the PTI regulation for emission
testing has not changed substantially over the last three decades. By
means of a fleet turnover which causes the outflow of the oldest ve-
hicles, and thus the evolution of a fleet to higher Euro emission stan-
dards, the outdated approach of targeting black smoke for diesel cars no
longer makes sense. As became clear through elaborate testing of diesel
cars in the discussed studies, PM emissions are largely overshadowed by
NOx as a pollutant that is emitted in dangerously high levels. However,
no PTI testing is performed on diesel NOx emissions.
Nonetheless, cities throughout Europe are starting to implement low
emission zones (LEZ), which force the remainder of the oldest and thus
most polluting cars out of circulation. This is an opportunity for pol-
icymakers to innovate the entire PTI process and to make it relevant to
contemporary needs, i.e. the monitoring of the real emissions and the
assessment of these over time, as the vehicle ages. Performing RDE tests
on every single vehicle that must undergo PTI by means of PEMS,
however, would be unrealistic and would be significantly expensive. A
combination of remote sensing the on-road emissions and a call-back
procedure to assess the worst emitters by means of PEMS effectively
could prove to be a solution here. In this way, the static emission tests
during PTI could be dismissed, while its revenues could be applied to
cover the PEMS testing expenses.
Considering the mismatch between the CO2 emissions measured
during type-approval and what's measured on-road, a significant side-
effect is plausible for ‘National total GHG emissions’ inventories [18].
European Member States report their annual emissions to the UNECE
following the Convention on Long-range Transboundary Air Pollution
(CLRTAP). Concerning the national road transport emissions, three
methodologies are available depending on the level of detail on trans-
port statistics, as described in [144]. These methodologies have only a
limited representation of real-world fuel consumption and pollutant
emissions as they are based on average speeds and a limited set of
dynamometer/on-road test campaigns [145–147]. Thus, generalised
CO2 emission factors are used, which introduce uncertainties and
thereby an underestimation of the fuel consumption discrepancies dis-
cussed earlier. This negatively impacts the national emission levels and
presents a skewed outcome of relevant policy measures. Assuming a
breakthrough of zero-emission vehicles (ZEV) is about to happen on the
short-term, another method for assessing the efficiency and environ-
mental impact of the European transport system is recommended. Ex-
emplary for this cause is the exergy approach following the idea of
Georgescu-Roegen [148] further elaborated by Lucia et al. in [149,150]
N. Hooftman et al.
and Byers et al. in [151]. As electrification of the road transport sector
will have substantial effects on both the emission of GHG and electricity
consumption, an exergy analysis becomes interesting to assess the im-
provements in useful work that is delivered (and hence less energy is
lost due to inefficient propulsion technologies such as combustion-
based ones). In the light of a carbon-neutral society by mid-century (cf.
the Paris Agreement), EU policy should actively invest in technologies
which allow the highest share of useful work. ZEVs allow the desired
cuts in GHG emissions if its electricity production is based on renewable
sources.
5.4.1. Low emission zones
Since several years, more and more cities worldwide have started to
act on their behalf to curb traffic-related health risks. This can be done
through various measures, e.g. by means of so-called low emission
zones (LEZ), by levying urban road tolls, by creating traffic-limited
zones, or just by traffic restrictions.
In the case of LEZs, the most polluting vehicles are either denied
access to the specific zones or are subjected to tolls to enter them. The
objective of applying LEZs is to bring down local PM10, PM2.5 and NOx
emissions, as well as the secondarily formed street-level ozone (O3).
Most LEZs affect heavy-duty vehicles, while a growing number of cities
also target passenger cars and light-duty commercial vehicles (LCVs). In
European cities, the criteria for LEZ entrance are based upon the Euro
emission standard, the year of first registration as a proxy, or by means
of the presence of retrofitted emission control devices, in most cases a
DPF. In 2016, Europe counted more than 200 LEZs, of which the ma-
jority are situated in Germany and Italy [152]. Urban road tolling has
the primary objective of reducing congestion, although it is also
thought to affect local air quality, as the absolute amount of pollutant
emitted into the atmosphere is brought down. The same is true for noise
pollution.
The city of London rolled out its first LEZ regulation in 2008. It
targeted heavy-duty diesel vehicles with a gross vehicle weight ex-
ceeding 3.500 kg. Though the London government targeted drastic
improvement of local air quality levels, a 2015 study proved that this
effect was not reached at all. Wood et al. analysed the city's first three
years of air quality data and revealed the LEZ has had no effect at all.
The applied methodology consisted of measuring the respiratory health
of 1.800 children attending elementary schools near known pollution
hot spots in the East of London [153]. The leading cause for this in-
variability of pollution levels is the growing number of diesel cars,
which the city experienced during the period of investigation. In ad-
dition, the share of primary NO2 emitted by diesel vehicles is found to
have peaked in the same period as well [12,154,39]. Next to traffic as a
primary NO2 source, secondary NO2 is formed atmospherically under
the influence of sunlight, the presence of nitrogen monoxide (NO) and
ground-level ozone (O3). A so-called titration reaction between NO and
O3 is responsible for approximately 70% of the NO2 measured in cities.
As these three pollutants keep each other in balance, no benefit will
come from reducing only NO2 or NO. Instead, the only solution is a total
reduction of NOx [14]. A similar trend of passenger car dieselisation is
reported in most Western Member States the EU, indicating the plau-
sibility of similar effects of LEZs in these countries.
In terms of air quality monitoring, NO2 is of importance as it serves
as a proxy for the impact on human health, according the World Health
Organisation (WHO) and the European Union. For petrol cars, the
amount of primarily emitted NO2 has remained very low over the
various Euro emission standards (i.e. about 2–4%), while for diesel cars
this share balanced around 50% in the first decade of this century.
Recent PEMS testing on 39 Euro 6 diesel cars showed a decreased
average primary NO2 emission of 44 ± 20% [16]. This decrease is
confirmed by Carslaw et al. in [39], who have been performing remote
sensing of exhaust gasses in and around London for many years. They
saw a primary NO2 peak around 2010, while reductions seem to have
taken place during their 2014 testing campaign. Diesel cars tend to emit
15
Renewable and Sustainable Energy Reviews 86 (2018) 1–21
high shares of this (for passenger cars unregulated) pollutant, due to
their after-treatment technologies for exhaust gasses, which oxidise CO
and HCs and produce NO2 to regenerate DPFs. The results from Carslaw
et al., however, indicate that the most significant reductions came from
the heavy-duty fleet, while no such signs were reported for passenger
cars. The ratio NO2/NOx was found to decrease as a Euro 4/5 diesel car
ages.
A Dutch LEZ study by TNO confirms that concerning NOx, hardly
any difference is to be reported, although it does affect the emissions of
elementary carbon (EC). Emission measurements in the LEZ of the city
of Utrecht showed that EC concentrations were found to have been
reduced by 16% [155]. This pollutant was selected, as its relation to
traffic is more straightforward compared to PM10/PM2.5. The reason for
this is that the allocation of PM is very complicated, as it has many
other contributing sources. In Munich, a similar study took place, which
focused on the reduction of PM10 by means of a LEZ and a heavy traffic
ban. The results show a decrease by 13% on average at a traffic mon-
itoring site, while a reduction of 4,5% was measured in the urban
background [156]. Older studies concerning heavy-duty traffic re-
strictions show that PM reductions in the range of 2,5–30% are at-
tainable [157–159]. Studies In congestion charge areas -requiring an
entrance fee from non-compliant vehicle users – showing an NOx re-
duction ranging from 0–12%, were found in literature [160,161]. Also
for these studies, the focus was on heavy-duty charges. To the knowl-
edge of the authors of this review paper, no studies have yet been
published which assess the impact of passenger car restrictions to LEZs.
The reason for this is that most cities have only recently started reg-
ulating passenger car access [152].
Basing LEZ access requirements on Euro emission standards proves
to be problematic, despite relatively strong reductions for PM. The
reason is simply that for diesel NOx, the Euro standards have failed.
Furthermore, the assessment of changes in PM emissions proves to be
very complex, due to the allocation issue for the emission sources at
roadside measurement stations. Next to transport, significant con-
tributions to PM and NOx emissions may originate from household
heating or industrial activities, sometimes many kilometres away.
Meteorological factors have a considerable influence on the emission
results as well [162]. Disregarding the powertrain technology, non-
exhaust PM emissions from transport represent 50% and 22% of the
primary PM10 and PM2.5, respectively [6]. This means that even with a
complete ban on combustion-based cars, harmful PM emissions will
remain. An impact assessment of three different powertrain technolo-
gies (petrol, diesel and electric) in a Belgian urban context is discussed
in [24].
Concerning NOx as an important ozone and PM precursor gas, LEZs
have the potential for a more significant impact, because road transport
contributes approximately 46% of the total NOx emissions. 80% of
those emissions is represented by passenger cars [163]. Typically, the
oldest engine technologies are targeted first when it comes to exclusion
from a LEZ, e.g. Euro 1, 2 and 3. No real RDE reductions in NOx
emissions are measured between Euro 1 and Euro 5 for diesel cars,
however, while the current Euro 6 diesel cars continue to exceed the
80 mg/km limit by a factor of 5–7. RDE testing will not significantly
change this in the coming years if urban emissions are considered. The
reason for this is that cold-start emissions aren’t yet mandatory to assess
in the type-approval process. As low engine loads typically characterise
urban driving, the resulting low exhaust temperatures cannot guarantee
optimal NOx conversion. This indicates that no significant improve-
ments in local air quality due to NOx reductions are likely to be reached
by banning the majority of diesel cars that are sold up to date. Con-
cretely, as NOx emissions by diesel cars will only be ‘under control’ from
(e.g.) 2020 onwards, it would make more sense banning diesel vehicles
entirely in LEZs. This is recognised by the local authorities of Paris, as
they will ban diesel cars from 2020 onwards, and by those of Athens
and Madrid, which will introduce the ban from 2025 onwards [164].
N. Hooftman et al.
6. Conclusion
The European passenger car fleet has a significant share in the local
air pollution issues. Although diesel exhaust gasses have been found to
be carcinogenic by the International Agency for Research on Cancer
(IARC) [165], Europe's roads remain dominated by diesel cars due to
past decisions in favour of the technology [48]. This dominance is not
expected to end on the short-term, as concessions given by the EU
Parliament allow the car manufacturers lead-time until 2020 to bring
down the official diesel NOx emissions to 1,5 times the 80 mg/km limit.
Post-Euro 6 emission targets are yet to be discussed, which contrasts
with both the U.S. and the Chinese approaches, which target fuel-
neutrality on the one hand, and stricter overall NOx limits, on the other
hand. Despite longer-term objectives set out by the U.S., the EU stalls
when it comes to post-2021 CO2 targets and post-Euro 6 emission
limits.
At least for diesel NOx, the European emission limits have failed due
to an unrealistic driving cycle and a lenient framework that allows in-
terpretation. Real driving emission (RDE) testing by means of portable
emissions measurement systems (PEMS) has the potential to change this
situation drastically and to force car manufacturers to ensure com-
pliance with the emission regulation over the engine operation range. A
legal framework for RDE testing is to be consolidated into four reg-
ulatory packages, of which the first three have been approved up to
date. While discussions on the fourth and final RDE regulatory package
are yet to commence, three preceding packages consolidate both the
PEMS test route and the equipment requirements, determined the post-
processing procedure and – most importantly – the conformity factors
(CF) concerning NOx and particle number (PN) emissions. Whereas
from September 2017 onwards, diesel NOx emissions are limited to
168 mg/km (CF 2,1), the limit will be decreased further, to 120 mg/km
by 2020 (CF 1,5). Criticisms to this approach are that these CFs are too
lenient on the one hand, and require compliance only after exclusion of
‘extreme’ test route conditions and normalisation of the test results, on
the other. Thus, the real-world CFs are expected to be about 3–4 before
post-processing [40]. Another criticism deals with the fact that the
approved CFs rather result from politics than from technical expertise,
as Members of European Parliament (MEP) not only represent their
Member State but also its national industries. This causes conflicts of
interest as they are thus biased to safeguard national interests. Finally,
as the third emission regulation only got approved in December 2016, it
remains unclear when the cold-start test data will be implemented in
the overall emission assessment, and which provisions will be taken for
RDE testing for hybrids.
In parallel with RDE testing, the introduction of the Worldwide
Harmonised Light Vehicle Test Procedure (WLTP) will take place si-
multaneously, from September 2017 onwards. For the sake of main-
taining the 2021 CO2 target of 95 g/km, the measured WLTP emission
factor will until then be recalculated to an NEDC equivalent by means
of the CO2mpas correlation tool, developed by the Joint Research
Centre (JRC). Although CO2 will be monitored during RDE testing (as is
also the case for HCs, and CO), the benchmark for CO2 reporting re-
mains the dynamometer-based WLTC test. This to ensure repeatability
and comparability between vehicle models [137]. Since no laboratory
test can perfectly mimic uncontrollable exogenous influences which
occur during RDE testing, the discrepancy between WLTP CO2 emis-
sions and reality is forecasted to lie between 20% and 30% [94,166].
Although the WLTP testing conditions will differ significantly from
those applied in the NEDC framework, there will remain optimal set-
tings for OEMs to obtain the most opportunistic emission results.
Moreover, software tampering with the RDE testing is possible as well,
as driving situations which are not categorised as ‘normal’ driving can
lead to uncontrolled and excessive emission behaviour [48]. As the
engine control units (ECU) can detect increased backpressure in the
exhaust line due to the presence of a PEMS, auxiliary emission control
devices (AECD) might still be switched in an optimal conversion mode
16
Renewable and Sustainable Energy Reviews 86 (2018) 1–21
[167]. The fact remains that if original equipment manufacturers
(OEM) experience ‘downsides’ to fully operational AECDs, there will be
an incentive to try and bend the rules [168]. Downsides can be an in-
creased fuel consumption due to more frequent catalyst regenerations,
or shorter refill intervals for DeNOx fluids due to an increased injection
in the SCR system.
In parallel with the fourth RDE regulatory package, a revision of the
type-approval Directive 2007/46/EC has been proposed by the
European Commission [126]. This review consists of implementing a
market surveillance system, an improvement of enforcement practices
and more opportunities for incompliant vehicle recalls [139]. Contrary
to the U.S.’ situation, where the Environment Protection Agency (EPA)
centralises authority, the European Commission will supervise its
Member States and will perform additional independent tests on in-use
vehicles by means of the JRC. For the national type-approval autho-
rities (TAA) and the accredited technical services (TS), a periodic peer-
review process is proposed, so that their practices are benchmarked and
remain up-to-date. This will drastically change the current situation in
which the 28 different TAAs can have 28 different interpretations of the
regulations. In addition, national TAAs will be given authority to take
legal action against incompliant vehicles sold within the respective
Member State, whereas currently this authority is only given to the TAA
that accredited the type-approval of the specific vehicle model. Fi-
nancial ties between a TAA/TS with the car manufacturer will be cut to
improve the independent nature of testing, and to eliminate conflicts of
interest. What is found to be missing in the Commission's proposal is a
uniform penalty scheme, which is criticised as a missed opportunity.
Instead, a list of infringements should be covered by the Member States.
The fourth RDE package is closely related to the type-approval Directive
review, as it will cover in-use testing of passenger cars as well. This final
step will close the circle of compliance testing, as the first three
packages focus on the pre-production phase for passenger cars. In ad-
dition, the fourth RDE package will discuss light commercial vehicle
(LCV) PEMS provisions.
The road for the automotive sector towards RDE compliance has
proven to be long and full of obstacles, especially in contrast with the
European heavy-duty vehicle sector. Here, the development of a con-
solidated RDE regulation took only five years, giving the manufacturers
another two years’ lead-time for the implementation of it. Thus, heavy-
duty vehicles (HDV) reduced their real-world NOx emissions from an
average of 4,5 g/km during Euro V regulation, to 0,2 g/km since the
introduction of Euro VI from 2014 onwards [169]. The more industrial
stakeholders proved to be cooperative in the development of HDV
regulation, the greater the industry's resistance proved to be to clean up
light-duty vehicle (LDV) exhaust gasses for NOx. Whereas it remains
unclear when and to what extent in-service testing will be applied for
the LDV fleet, it has already been in force for the HDV market since
2014. One potential solution for implementing an in-service testing
campaign is to merge it with the existing periodic technical inspection
(PTI), as it monitors virtually every passenger car on Europe's roads.
Despite watered-down conformity factors, EU car manufacturers will be
the first worldwide to impose RDE testing of passenger cars by means of
PEMS during type-approval. China has based its RDE testing program
primarily on the European second regulatory package and will impose
PEMS testing from 2023 onwards. In addition, China will adopt the
WLTP from July 2020 onwards. The combination of both the WLTP and
RDE would bring both the Chinese and the EU's new car fleet another
step closer to the high level of requirements passenger cars have been
subjected to in the U.S. for more than ten years. This is especially be-
cause in-use testing has already been applied in the U.S. since the
phased-in introduction of Tier 2 regulation between 2004–2009
[131,128].
The entire RDE regulatory development process reads as an enu-
meration of conflicts of interest, as the automotive industry has had a
significant influence. Through extensive lobbying, the desired effect of
RDE testing has been weakened, by means of several normalisations
N. Hooftman et al. Renewable and Sustainable Energy Reviews 86 (2018) 1–21

and the watering down by conformity factors. The concessions given to
the automotive industry through lead-times and lenient NOx limits for
diesel cars will continue the isolation of Europe in the global picture as
a ‘diesel island’. Moreover, it blocks the path for alternative technolo-
gies, such as hybrids and zero-emission vehicles (ZEV) [71]. Whereas
U.S. Federal law stipulates a phase-in of a fuel-neutral NOx limit of
about 19 mg/km by 2025, to date no discussions have been started
concerning a successive limit for Euro 6d (60 mg/km and 80 mg/km for
spark ignition and compressed ignition engines, respectively). This in-
dicates that the EU's priority is focused on keeping the highly developed
automotive industry in the saddle, rather than on its adverse effects on
human health and the environment. This point of view is weakening the
EU's position globally, as emerging markets such as China have shifted
focus to electromobility, for which it has the ambition to become the
global leader for both production and knowhow.
Finally, the failed Euro emission standards for diesel NOx undermine
the effectiveness of low emission zones (LEZ), mainly if these are based
solely on the Euro standards. Whereas most LEZs around Europe in-
itially targeted heavy-duty vehicles, several cities recently started reg-
ulating passenger car access. However, there are no uniform guidelines
for the application of LEZs, as a European overview is missing. Most
studies of the effect of LEZs on air quality refer to the pre-car regula-
tions. Results show that PM reductions up to 30% are feasible, while
NOx reductions up to 12% were reported. The latter is linked to an
increased share of diesel passenger cars on European roads, which are
characterised by substantial primary nitrogen dioxide (NO2) emissions.
A regulation of NO2 emissions for road transport would not result in
significant improvements in local air quality, though. The reason for
this is that nitrogen monoxide (NO) is an important source of secondary
NO2 emissions as well. A total NOx regulation remains the most effec-
tive measure hereto. To the knowledge of the authors of this paper, only
limited scientific work presenting a detailed assessment of LEZ reg-
ulation including passenger cars is currently available. When it comes
to PM assessments, specific care should be taken due to the high level of
complexity in allocating its sources. Traffic restrictions, for example,
will bring down PM emissions, not only as less is emitted, but also as
less PM is resuspended. Resuspension is independent of powertrain
technologies, as is the case for tyre and brake wear as well.
Furthermore, the influence of non-exhaust PM emissions will grow as
exhaust PM is successfully being reduced to fractions of pre-DPF results.
This indicates the need for a European regulation for non-exhaust PM
emissions. Ideally, LEZs should place a total ban on combustion-based
vehicles, given that an abundance of alternative means of transporta-
tion is present, e.g. public transport. In addition, this requires financial
incentives for motorists to make the transition towards zero-emission
technologies.
Concerning zero-emission technologies, a positive trend has been
reported over the last years. Whereas car manufacturers make bold
statements on electrifying a large share of their models on short-term,
consumers are starting to pick up the new technology, despite persistent
barriers such as range anxiety. This anxiety is partly relieved as a roll-
out of charging infrastructure has started all over Europe. For the mo-
ment, the success of ZEVs remains dependent on financial incentives,
until the technology costs equal those of conventional vehicles. This
breakeven point is forecasted to occur by 2022 or sooner [170,171].
Governments should, therefore, be convinced that the price for these
incentives should notbe considered a cost, but rather an investment in
future improvements of local air quality. This, in turn, results in re-
duced societal costs for health care. Furthermore, innovative ZEV
technology and its infrastructure create jobs and economic growth, if
Europe decides to follow the path of sustainable transport now, instead
of watching how China takes over the worldwide ZEV industry.
Acknowledgements
We acknowledge Flanders Make for the support to our research
group. In addition, we are grateful to the ICCT for allowing us to re-
produce graphics initially created by them.

Appendix I

See Annex Fig. S1

The results presented here originate from a test campaign by the author of this report for the Belgian periodic technical inspection (PTI)
organisation GOCA. A fleet of 37 test vehicles was tested, of which the presented 26 were diesel-fuelled. Concerning the test procedure, six variants
of the IM240 cycle were performed, indicated in the legend (i.e. from ‘Eco’ to ‘Consumers ON’). Each IM240 sub-cycle consisted either of different
ambient conditions (cold start vs hot start), driving styles (Eco driving vs sportive driving) or loading (simulated load on a dynamometer or higher
engine load due to air-conditioning and others, referring to ‘Loaded’ and ‘Consumers ON’, respectively.
As the objective of this study was to find a cost-effective alternative for the current emission test during PTI, garage-type gas analysers were
applied. These were the MAHA MET 6.1 for NOx, O2, CO2, HC and CO and the MAHA MET 6.2 for PM2.5–10. As a reference the g/km to g/kg
conversion factors from [172] were used. Results show that none of the tested diesel cars complied with the Euro emission standard, while the

Fig. S1. NOx results of own measurements over the IM240 driving cycle.

17
N. Hooftman et al.
exceedances ranged from a factor 6 to 16.
Appendix II. : PEMS testing timeline
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