7 minute read
Introducing the Worldwide Harmonized Light Vehicle Test Procedure
Pierre Montebello Chief Officer Land Transport Directorate
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FOR LOWER REGISTRATION TAX AND ROAD LICENCES
One of the announced budget measures for 2021, effective from the 1st of January 2021, relates to a new vehicle registration tax and licence fee regime for vehicles with new CO₂ emission values.
New cars certified by the manufacturer according to the Worldwide Harmonized Light Vehicle Test Procedure (WLTP) and having CO₂ emission values of WLTP are to benefit from lower registration tax and licence fee rates.
The new vehicle registration tax and licence fee regime just introduced by Transport Malta, based on CO₂ WLTP values, will either have a neutral or positive impact (in terms of lower registration tax and licence fees) on consumers.
But what does WLTP stand for?
WLTP stands for Worldwide Harmonised Light Vehicle Test Procedure. It is a lab test that applies to all new vehicles registered since September 2018, to check how they perform in everyday driving conditions. It replaces what is called the NEDC test (also known as the ‘New’ European Driving Cycle).1
Last revised in the late 90s, the NEDC has been widely criticised for delivering figures that are not achievable in the real world. In fact, it is now established that the NEDC’s biggest flaws are its inclination towards theoretical driving and the unrealistic figures it produces. NEDC fuel consumption ratings are close to impossible to achieve in real-life traffic and most criticism is coming from this direction. This is not saying that the tests are intentionally misleading. It is that they are not exactly reflective of how a car would be used on a day-to-day basis by an average driver.
1 Source: https://www. automotivetestingtechnologyinternational. com/ Since the ‘Dieselgate’ scandal broke out in September 2015, the automotive industry has been under increased media and regulatory scrutiny for its contribution to the urban air pollution in our cities.
From the initial focus on the defeat devices fitted to particular vehicles in the US, the scandal spread globally to almost every company, and every market. In response, the EU has strengthened regulations, including introducing a new real-world emissions test (a strengthened system for approving cars). For two years, the focus has understandably been on how to tackle the noxious emissions from exhausts.
The WLTP has been introduced in the European type-approval process as from September 2017, in parallel with the introduction of the final Euro 6c emission limits. The WLTP test has been totally redesigned to provide a better
representation of ‘real-world’ CO2 emissions and fuel consumption. That means that the figures of emissions and fuel economy should be more accurate. The WLTP test takes place over a longer distance than the outgoing NEDC test, using higher top and average speeds, and lasting a greater amount of time. And unlike the NEDC test, the impact of all available optional equipment (such as bigger wheels or panoramic sunroofs) is considered in the WLTP cycle. The transition period from NEDC to WLTP started in September 2017. During the period of transition from NEDC to WLTP, cars approved before had their CO2 values as measured under the old NEDC test. When a new car was certified according to WLTP after September 2017, its official vehicle documents (the Certificate of Conformity) will have CO2 emission values from both the new lab test (WLTP) as well as the old one. This means that after September 2017, when the switch from the old NEDC test to WLTP was made, one might come across two different values for the same car. This might be quite confusing, making it difficult to compare cars.
From September 2018, all new cars must have WLTP-CO2 values. Manufacturers are required to ensure consistency between the CO2 emissions recorded in the certificates of conformity of their vehicles and the CO2 emissions of vehicles in-service measured according to the Worldwide Harmonised Light Vehicle Test Procedure (WLTP).2
This consistency shall be verified by type-approval authorities, in selected vehicles. The authorities shall also verify the presence of any strategies artificially improving the vehicle’s performance in the typeapproval tests.
On the basis of their findings, typeapproval authorities shall, where needed, ensure the correction of the certificates of conformity. They
2 Source: https://ec.europa.eu/clima/policies/ transport/vehicles/regulation_en
Source: https://www. wltpfacts.eu/from-nedcto-wltp-change/
Source: https://www. alphabet.com/en-lu/ worldwide-harmonizedlight-vehicles-testprocedure-wltp
may also take other necessary measures set out in the Type Approval Framework Regulation.
It is to be noted that type-approval is compulsory for all categories of whole vehicles, including those built in several stages.3 The related directive4 lays down:
• a harmonised framework with general technical requirements for the type-approval of new vehicles and of systems, components and technical units designed for such vehicles, so as to facilitate their registration, sale and entry into service in the EU; • rules regarding the sale and entry into service of vehicle parts and equipment.
In turn, the certificate of conformity is a statement by the manufacturer which shows that the vehicle conforms to EU type-approval requirements. The manufacturer has the responsibility to ensure the conformity of production with the approved type.
Deviations found in the CO2 emissions of vehicles in service shall be reported to the Commission, which shall take them into account for the purpose of calculating the average specific emissions of a manufacturer.
The WLTP will determine the CO2 emissions for a particular vehicle, and it is those CO2 emissions that determine how much registration tax upon purchase or circulation licence fees a vehicle is subject to.
Technically, whether the change from NEDC values to WLTP values means a rise or fall in the fees band a new vehicle falls into, will depend totally on whether the WLTP CO2 emissions measurement is higher or lower than the previous NEDC measurement.
Though it was anticipated from earlier on that most vehicles will move up to a higher band after the switch, as explained above, the Government is committed to the fact that the new vehicle registration tax and licence fee regime based on CO₂ WLTP values will either have a neutral or positive impact (in terms of lower registration tax and licence fees) on consumers. Correlation between WLTP and NEDC figures
Passenger cars and vans (‘light commercial vehicles’) are responsible for around 12% and 2.5%, respectively, of total EU emissions of carbon dioxide (CO2), the main greenhouse gas.5
The new WLTP testing procedure has had a massive impact on CO2 emissions data but the disparity between the WLTP, NEDCcorrelated, and old NEDC data has further complicated the issue.
Autovista Group analysis reveals that the average deviation between WLTP and NEDC-correlated (NEDC-c) CO2 emissions figures now stands at 21%.6
The average mathematical deviation of 21% is calculated from the emission figures for individually registered cars, and aligns with the expectations outlined in a European Commission study published early in 2018. This is a more accurate method than using manufacturers’ specifications, i.e., averaging the deviation of each model variant available on the market, as it would not factor in volume weighting.
3 Source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=LEGISSUM%3An26100
4 Directive 2007/46/EC of the European Parliament and of the Council of 5 September 2007
5 Source: https://ec.europa.eu/clima/policies/transport/vehicles/regulation_en
6 Source: https://autovistagroup.com/news-and-insights/wltp-focus-understanding-disparities-wltp-and-nedc-correlated-data, and https://publications. jrc.ec.europa.eu/repository/bitstream/JRC107662/kjna28724enn.pdf
Conclusion
According to the German Association of the Automotive Industry (VDA)7, on average, across the EU (weighted by unit sales), the switch from NEDC to WLTP will mean a numerical increase of the CO2 values by 22% in comparison with NEDC-certified vehicles. Nonetheless, there will be numerous cases where the WLTP figures will be lower than the NEDC ones. Especially in communications with customers, this has the drawback of one and the same vehicle having apparently worse figures, although there has been no change in technology.
Notwithstanding the overall increase in CO2 figures due to the new test system, customers are assured that the new vehicle registration tax and license fee regime based on CO₂ WLTP values, introduced by Transport Malta from the 1st of January 2021, will either have a neutral or positive impact in terms of lower registration tax and licence fees.
All in all, the WLTP provides end customers with a more realistic yardstick for comparing the consumption and emissions of different vehicle models. For the manufacturer, it provides a legally reliable basis for the certification of new vehicles. This test standard will also provide a significantly more realistic representation of the emissions and consumption of new model series.
7 Source: https://publications.jrc.ec.europa.eu/repository/bitstream/JRC107662/kjna28724enn.pdf
8 Source: https://www.daimler.com/sustainability/climate/wltp/wltp-part-2.html
