Briefing: TTIP and Vehicle Safety
What is TTIP?
The European Union and the United States are currently negotiating a joint trade agreement known as the Transatlantic Trade and Investment Partnership (TTIP)
The EU’s stated goals[1] are:
- opening up the US to EU firms
- helping cut red tape that firms face when exporting
- setting new rules to make it easier and fairer to export, import and invest overseas.
What has TTIP got to do with vehicle safety?
The car industry is hoping to be one of the biggest beneficiaries from a TTIP agreement, partly by removing tariffs on imports, but mainly by removal of so-called non-tariff measures (NTMs). One example of NTMs is the fact that car manufacturers have to meet two separate sets of safety and environmental standards for the EU and US markets.
“Implementation of an ambitious TTIP by the year 2027 is expected to increase annual US motor vehicle exports to the EU by $84.7 billion, a rise of almost 650 percent from 2012 levels. A slight majority of these gains would from NTM reductions, although tariff reductions are also significant. In both absolute and relative terms, expected increases for US motor vehicles exports are larger than for any other industry.”
“Automakers say that if regulators were to accept equivalent standards from their counterparts across the Atlantic, the companies could trim hundreds of millions of dollars in costs.”
Automotive News, December 2013
http://www.autonews.com/article/20131217/OEM/131219876/automakers-call-for-backup-in-quest-to-align-u.s.-eu-safety-standards
What is the car industry’s position?
Carmakers on both sides of the Atlantic have argued that safety standards are equivalent, i.e. not the same, but offer similar outcomes. The European Commission’s trade team has also made this claim.
“Overall, there is little doubt that the levels of safety required by both sides are broadly comparable.”
EC DG Trade position paper May 2014 – http://trade.ec.europa.eu/doclib/docs/2014/may/tradoc_152467.pdf
“Regulators tend to believe that their standards are the best. They have ‘not-invented-here syndrome,’” said Gloria Bergquist, a spokeswoman for the Alliance of Automobile Manufacturers, a Washington-based lobbying group whose members include General Motors, Toyota and Volkswagen. “We want to show them that our standards may differ in some modest ways, but the ones that we’re looking at harmonizing are essentially equivalent.”
Alliance of Automobile Manufacturers (US) – quoted in Automotive News, December 2013
http://www.autonews.com/article/20131217/OEM/131219876/automakers-call-for-backup-in-quest-to-align-u.s.-eu-safety-standards
“Manufacturers currently face unnecessary redesign and redevelopment costs to produce cars for export to the US in order to meet safety standards which differ to those in the EU,” explained ACEA Secretary General Erik Jonnaert. “ This does not add additional safety protection.
ACEA (EU automotive industry lobby), website article, 2 February 2015
http://www.acea.be/press-releases/article/ttip-the-common-position-of-the-transatlantic-automobile-industry
What is the case that the EU and US standards of vehicle safety are equivalent?
The standards have not been shown to be equivalent.
In fact, the most comprehensive, independent, international study of this question was carried out by the University of Michigan, Chalmers University in Sweden and others including the UK’s Transport Research Laboratory (TRL) in 2014 and 2015. The study was commissioned by the US and EU car industries. They jointly announced the launch of the study in 2013:
http://www.autonews.com/article/20131217/OEM/131219876/automakers-call-for-backup-in-quest-to-align-u.s.-eu-safety-standards
The study was published online recently, though there was no formal announcement or press release: http://deepblue.lib.umich.edu/handle/2027.42/112977
The study did not find that EU and US standards offer equivalent outcomes and recommended a number of areas for further analysis.
One of the main conclusions in the executive summary is of particular concern:
“Overall risk across the US front-side crash population (given the selection criteria for this study) is likely lower for EU vehicles. Though the range of estimates is wide, the best estimate of the risk difference is -0.012.”
Page 39 of the study offers a more detailed explanation:
“When applied to the US front-side standard population, the mean estimated risk for the US-vehicle model is 0.035 with a standard deviation of 0.012, and the mean estimated risk for the EU-vehicle model is 0.023 with a standard deviation of 0.016. The most likely risk difference is -0.012, indicating that risk would be lower on the US front-side population when the EU model is applied. The standard deviation of the risk difference is 0.020 and the 95% CI is (-0.051, 0.027). This mean risk difference represents a 33% reduction in risk for EU vehicles over the US mean injury rate.” (Our emphasis)
In other words, taking the example of a typical EU specification car on US roads, the EU vehicle is 33% safer than a typical US model in the case of the risk of serious injury in common front-side crashes.
The European Commission has also published two pieces of research, one on the specific example of seat-belt anchorages, and another on lighting and mirrors. Both of these studies were only put into the public domain after they had been discussed by US trade officials.
http://trade.ec.europa.eu/doclib/docs/2015/january/tradoc_153023.pdf
These studies outline some cases of safety standards that could be considered equivalent, and others that cannot – but they do not examine the crucial issue of crash protection.
ETSC’s priorities for TTIP
Road safety in the European Union has been a success story over recent years. Over the last decade the number of annual road deaths in the European Union fell by around a half[2], in the US they fell only by around a quarter[3].
The EU and US have developed their separate vehicle safety standards over several decades, based on local traffic conditions, their particular fleet makeup and the regulatory environment. These all have a role in the overall level of safety.
ETSC believes that the top priority with regard to vehicle safety is that the highest standards are maintained and there is no opportunity now or in the future to weaken them, or delay tighter standards.
We consider that the work done until now, is not comprehensive enough to justify recognition of ‘equivalence’ today in full or in part. That situation is unlikely to change within the deadline for the TTIP negotiations i.e. the end of this year.
We also consider the process by which the current work is being done lacks the necessary transparency and openness required for an issue of public policy as important as vehicle safety, which is quite literally a matter of life and death.
One example of this problem is that the EU’s own research and position papers on vehicle safety for TTIP have only been made available for public and expert scrutiny after they have already been discussed by trade negotiators.
The appropriate and precautionary approach would be to remove vehicle safety harmonisation from the TTIP negotiations.
For further information
ETSC position paper on TTIP (March 2014)
http://etsc.eu/wp-content/uploads/ETSC_contribution_to_the_TTIP.pdf
[1] http://ec.europa.eu/trade/policy/in-focus/ttip/about-ttip/
[2] http://etsc.eu/wp-content/uploads/ETSC-9th-PIN-Report_Final.pdf
[3] http://www.nhtsa.gov/About+NHTSA/Press+Releases/2014/traffic-deaths-decline-in-2013