The results of the European Commission's "public consultation on the Euro VI emissions limits for heavy-duty vehicles" have been published on the Commissions website. 55 replies from industry stakeholders and governmental bodies were received, with the majority supporting 'Scenario A' and single-stage implementation. Key respondents included ACEA, AGU-CEFIC, IRU and JAMA.

Generally, the automotive industry - represented by ACEA - is supportive of the Commission's efforts to cut pollutant levels in heavy-duty exhaust and accepts the pressure to bring limits in line with the US. However, ACEA stresses the need for balance. Balance between the costs to industry necessary to implement the emissions reductions and the resulting benefits to public health and the environment. Another consideration outlined by ACEA is the effect of high-rate EGR on fuel efficiencies, and the resulting increase in CO2 associated with some of the scenarios. ACEA is also adamant that Euro VI should be "the final stage" and that there is no need for a Euro VII.

Having outlined its concerns, ACEA chose to support Scenario A, a single-stage Euro VI and implementation dates of 1 October 2013 for new type-approval and 2014 for all new registrations. Scenario A has limits that are equivalent to those selected by the EPA for its US2010 legislation. However, ACEA has warned that any comparisons between US and European emissions limits should take into account US complexities including 'engine family averaging'. ACEA's comments confirm the industry's preference for the world harmonised duty cycle (WHDC) for Euro VI over the existing European transient cycle (ETC).

Part of the motivation behind ACEA's decision to support Scenario A limits for Euro VI may lie in the desire of global and multi-regional OEMs to harmonise their engine families and develop a common platform for use in the triad markets (US, Europe and Japan). Indeed, in a move towards a global engine strategy Daimler recently announced plans to move North American engine production over to its Heavy Duty Engine Platform (HDEP) family. The HDEP will eventually reduce Daimler's eight engine families to three, where 90% of the components are global common parts. This kind of streamlining will result in significant cost savings as the scale of common-component orders increases.

Feedback from other interested parties and stakeholders was varied, but the majority of respondents favoured a single-stage implementation and either Scenario A or D. The logistic and transport associations favoured fuel-neutral Scenario D to minimise the impact of Euro VI on their fuel costs. However, the IRU was most concerned with confirming the implementation date so members can adjust their order books appropriately, and public bodies can arrange incentive schemes. AGU-CEFIC, an association of automotive-urea producers (ADP, AMI Agrolinz, Fertiberia and Yara), is in favour of a two step approach and less stringent limits. The CEFIC group cites increased CO2 emissions, and the threat to the AdBlue infrastructure that will result from high-rate EGR as its reasons.

Given the political pressure on the Commission not to fall behind the US, and the automotive industry's desire to harmonise global legislation, it is likely that a single-stage Scenario A will be presented to the European Parliament. Both industry and regulator agree that it is becoming necessary to implement the WHDC under the UN-ECE and this will be an important consideration for the Commission.