commentaires de la grande bretagne sur les propositions de l'union européenne (2001)

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Department for Transport,
Local Government and the Regions

European Commission Proposals on
Speed Limiters for Commercial Vehicles:
Invitation to Comment

F. Hackman
Head of European Driving Licence Legislation Branch
Licensing Roadworthiness and Insurance Policy Division
Road Safety and Environment Directorate
Department for Transport,
Local Government and the Regions
Zone 2/08
Great Minster House
76 Marsham Street
London SW1E 4DR
Direct Line: 020 7944 2461
Divisional Enquiries: 020 7944 2204
Fax: 020 7944 2459
GTN Code: 3533 2461
Web site:
Our Ref: VSE/797/37
17 August 2001

European Commission Proposals on Speed Limiters for Commercial Vehicles: Invitation to Comment

1. This letter invites you to give your views, together with any appropriate supporting information, on a proposal by the European Commission (EC) to extend the present requirement to fit top-speed limiters so as to cover goods vehicles over 3.5 tonnes maximum permitted weight and passenger vehicles having more than 8 passenger seats.


2. At present, a 1992 European Union (EU) Directive, Council Directive 92/6/EEC, requires top-speed limiters to be fitted to buses and coaches with more than 8 passenger seats whose maximum weight exceeds 10 tonnes, and to heavy goods vehicles (HGVs) whose maximum weight exceeds 12 tonnes. Current requirements in Great Britain (GB) are for top-speed limiters to be fitted to goods vehicles, buses and coaches weighing 7.5 tonnes or more. The relevant GB legislation is contained in Regulations 36A and 36B of the Road Vehicles (Construction and Use) Regulations 1986.

3. The EC's proposal would effectively require top-speed limiters to be fitted to minibuses and midi-coaches; also to the lighter HGVs (which are a size category larger than "Transit-type" vans: typically two-axle box-vans and skip-loader size trucks).

4. State of play. The EC's proposal, attached at Annex A,  (document inaccessible, le lien n'est plus valable)was published in mid-June this year. It will not become law until and unless agreed by the Council of Ministers, using qualified majority voting; and until agreed by the European Parliament (EP). Target dates for decision are December 2001 or (more likely) March 2002. However, we can expect serious negotiation with our fellow Member States through the autumn starting in September this year. We recognise the importance of full information as an input to this process, so we are hereby seeking your views urgently on the proposal.

Northern Ireland

5. In Northern Ireland, the Department of the Environment is one of the consultees, and is effecting a secondary distribution to key individuals and organisations in Northern Ireland, asking them to respond directly to the Department of Transport, Local Government and the Regions in London.

The Proposal

6. The European Commission's proposal. The European Commission's proposal (COM(2001) 318 final, volume II), if adopted as it stands, would extend in full to the lighter HGVs, buses and coaches and to midi-coaches and minibuses the requirements and the speed limits already applied to the heaviest classes. In particular, it would:

7. The European Commission's proposal excludes almost all Transit-type vans, whose maximum permitted weight is 3.5 tonnes or less. It also excludes motor vehicles used by armed forces, civil defence, fire and other emergency services and forces responsible for maintaining public order. In addition it excludes motor vehicles which:


8. Benefits and costs. In principle, the benefits of speed limiters would include fewer, less severe accidents, reduced emissions and fuel saving.

9. The EC's Report (COM(2001) 318 final, volume I), attached at Annex B, claims that the total combined benefit in the EU of its proposals for light trucks would be of the order of 3 billion euros, that is, about £2 billion, based on a study in the Netherlands. However,

10. In the UK, we do not have clear evidence to show how many accidents have been prevented by fitting top-speed limiters to the heavier vehicles. Nevertheless, the small reduction in mean speeds achieved since 1988 may have delivered reductions in the numbers killed and in the number and severity of injuries. It will also have delivered environmental benefits. It will therefore be similarly very hard to quantify the potential benefits for lighter vehicles. There should, however, be some in-principle environmental benefits through fuel and emissions savings. Equally, a reduction in speed limits for some of the vehicles (which is in effect part of the Commission's proposal) should reduce the number and severity of accidents. However, implementation of the proposal as it stands could lead to congestion effects, caused by more vehicles being trapped in long overtaking manoeuvres, for example. It would also impose additional costs on operators because of increased journey times.

Views and Comments

11. You are invited to give your views, comments and ideas on any aspect of this consultation, together with supporting information if appropriate. We regard these as important in enabling an informed UK contribution to the negotiations in Brussels, aimed at obtaining a good outcome.

12. When considering your reply, you might like to bear in mind that it would be very helpful to us not only to have your views on the proposal as it stands, but also if you could identify possible "fall-back" positions. This will help us to give Ministers a very clear account of the range of options they may need to consider. We should be particularly grateful for your views in response to the following questions.

Regulatory Impact Assessment

13. A draft regulatory impact assessment is attached at Annex C. This expands on some of the points made in this letter. We should welcome information which might help to improve the correctness and the precision of this analysis. We hope that the responses elicited by this letter will help us to complete the assessment.

Internet Access

14. A copy of this letter and its Annexes has been placed in the Road Safety section of the Department for Transport, Local Government and the Regions (DTLR) Internet site at

Where to Respond

15. If you wish to respond to these proposals, please would you forward your comments in any one of the following ways:

16. Please bear in mind that the Department may be asked to make public the contents of the replies that are received to this letter. Should you decide to send a response, it would be helpful if you would advise whether you would be content for a summary of your comments to be included if the Department is asked to divulge what was in the responses received.. The actual text of your reply would not be published.

17. If you have any questions on the proposals contained in this consultation letter, aside from responding formally to the consultation process, Colin Scogings will be pleased to answer them. Contact can be made directly by telephone, fax, or e-mail.

Code of Practice on Written Consultations

18. The criteria outlining the code of practice on written consultation are attached to this document at Annex D. Also included are details of the Cabinet Office website, which contains further information, and a contact point should you wish to comment or complain about any aspect of this consultation document or process.

Deadline for Responses

19. In view of the inevitably tight timetable for European Union business we are giving only a six week deadline for responses to this consultation. Ministers have agreed this departure from the usual 12 week period to ensure responses can be taken into account before negotiations begin again with other Member States in Brussels. Please would you respond as soon as possible, but in any event all responses should reach the Department no later than Friday 28 September.

Yours faithfully


The DTLR is not responsible for the contents or reliability of the linked web sites and does not necessarily endorse the views expressed within them. Listing should not be taken as endorsement of any kind. We cannot guarantee that these links will work all of the time and we have no control over the availability of the linked pages.

Published 21 August 2001

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