Strengthening the road safety aspects of the EU Roadworthiness Package
Roadworthiness testing is part of a wider regulatory scheme, governing vehicles throughout their lifetime. This scheme covers vehicle type- or individual approval, performed before the vehicle is permitted to enter the single market via registration, its use on the roads, and until it is considered as an “end-of-life vehicle” and scrapped or exported.
During the type- or individual approval, compliance with the current highest level of safety and emission requirements must be secured before the vehicle gets an authorisation to be used on public roads.
The goal of roadworthiness testing is then to check the functionality of safety components, the environmental performance, and the vehicle safety requirements.
New technologies in road transport are increasingly based on IT and communications, which raises issues related to the consistency of vehicle IT systems. Consequently, cybersecurity must be in the focus of road transport policies, too.
EU regulations and directives provide for a comprehensive list of requirements for road safety and the emission behaviour of new vehicles. However, since relevant components of vehicles during their service life continuously deteriorate, it is necessary to carry out periodic vehicle inspections in Europe, adapted to the level of susceptibility of use, in order to ensure long-term road safety and low emissions.
The latest review of the Roadworthiness Package has already led to a partial harmonisation of vehicle inspection rules across the EU Member States. Yet, there are still certain discrepancies in the way States have implemented the Directives into their national legal systems (status of inspection centres, testing tools, provision of relevant PTI data, etc.).
In order to ensure better consistency of laws, standards and practices within the EU, it would be useful to consider an increase of the minimum level of harmonisation in the upcoming review of the Roadworthiness Package.
This would result in an overall improvement in vehicle inspection and allow Member States to improve their systems individually.
Since one of the primary goals of roadworthiness tests is to ensure road safety, it is not logical that certain categories of vehicles are inspected periodically, while others are excluded from this obligation. As CITA has already concluded in its 2019 study, mandatory inspections of two-, three-wheelers, and light trailers would have a positive cost-benefit impact. Considering that the European motorcycle fleet consists of 24.7 million of units, many lives could be saved by inspecting additional categories of vehicles.
With the growth of shared mobility and the use of individual vehicles for public transport purposes, the frequency of inspections on these vehicles should likewise increase. CITA proposes to subject these M1 and N1 vehicles to a roadworthiness test one year after the initial registration date of the vehicle and then annually thereafter. The same frequency of testing could also be extended to L-category vehicles used in the context of shared mobility or public transport.
Under the new General Safety Regulation (EU) 2019/2144, motor vehicles will have to be equipped with safety features, such as intelligent speed assistance, driver drowsiness and attention warning systems, and many others.
To ensure road safety, during the periodic technical inspection, it must be possible to detect any damage or manipulation of these safety-relevant systems over the entire vehicle life cycle. Hence, periodically and after the repair of a heavily damaged vehicle, a technical inspection shall be mandatory to guarantee full functionality of ADAS and to identify any potential changes made to the safety components.
The focus should be to inspect the in-vehicle technologies/systems regarding conformity, effectiveness and damages using the benefits of system self-diagnostics plus relevant additional PTI scopes.
CITA proposes to include also eCall, the emergency call system mandatory since 2018, in the scope of periodic technical inspection and test it via the electronic vehicle interface.
A comprehensive roadworthiness framework must ensure that automated vehicles are regularly tested to evaluate safety performance: a system self-diagnosis cannot replace an impartial PTI and a physical inspection. Conversely, testing the self-diagnosis itself must be part of a PTI to ensure that the vehicle is still able to recognize its odd boundaries.
Software is increasingly becoming a key component of a vehicle safety and environmental relevant systems as well as for automated driving functionalities. Hence, CITA is committed to ensuring that future verification of software integrity during periodic technical inspections is implemented during the development and revision of international and European vehicle type-approval regulations. Technical inspection companies need non-discriminatory and independent access to the original data of modern vehicles. Both at the testing station and by means of digital remote access via wireless interfaces.
The regulatory framework must allow appropriate stakeholders to verify that vehicles are using approved software with the right version, to ensure cybersecurity. The EU type-approval legislation already foresees adoption of an implementing act prescribing technical specifications for vehicle cybersecurity. This must, consequently, be reflected in the roadworthiness tests.