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After years of negotiation between OEMs and the authorities, EURO 7 emissions regulations will be implemented from the end of November but why is the aftermarket concerned? Rob Marshall asks leading brake friction firms to find out.
While many technicians curse the often troublesome emission systems mandated for EURO emissions compliance, this is typically the only involvement independent workshops have with Whole Vehicle Type Approval. This changes with EURO 7. Not only is the UK Government tightening real- world compliance with these standards, but EURO 7 will also include emissions from sources other than the tailpipe.
Brakes and Euro 7...
Comline explains that EURO 7 will focus on particles being shed from the brakes, with a size of 10 microns, or less. These PM10 particles are critical, because they are most likely to lodge in the lungs. Yet, waterway pollution is related to the type of brake particles, rather than their size. Copper fragments, which are washed from the road into streams and rivers, are lethal to some forms of aquatic life. This is one reason why many quality braking providers (such as Comma and febi) have been selling copper- free pads for some time. Additionally, Comma highlights its compliance with REACH, the EU regulation governing chemical safety, and Delphi’s friction materials are manufactured without hazardous heavy metals such as lead, cadmium, and mercury.
We should be unsurprised, therefore, that quality friction brands have been working hard for many years to mitigate the environmental impact of their products and tend to support future efforts. Even so, compliance with EURO 7 is not achieved simply by changing a friction formula to produce fewer particles. This is not how engineering works. Delphi explains that key metrics of the brake system performance, such as stopping power, noise, wear and brake dust, work together. This means that maximising stopping power, for instance, might be achieved at the expense of greater brake noise and/or higher particulate emissions. Therefore, each ingredient in a friction material is selected carefully to achieve the desired performance across a variety of conditions. Tweaking the mix will upset the balance.
Behind the Scenes...
For the last decade, TMD Friction has been involved with the Particle Measurement Programme working group of the United Nations Economic Commission for Europe (UNECE) to support the methodology, test cycle, and test bench construction to measure brake dust emissions for what would become EURO 7. Its representatives attended all working groups and both advised and commented on the development of legislation regarding brake particle emissions.
Yet, work is ongoing. TMD Friction is confident that it will deliver fully compliant parts on time. This has not been easy. The firm has invested €1.5 million in its own emissions dynamometer to get compliant parts to market faster and to gain total control over the development and validation processes.
A problem for the aftermarket...
TMD Friction reports that EURO 7 will apply to both OE and aftermarket. The 29th November 2026 will see it introduced for new model Type Approvals, with new examples of current models being given a further year to catch up. Yet, while R179 will cover OE homologation, the aftermarket regulation is still under development. Until it has been released, no aftermarket solution can be homologated. This, understandably, has raised serious concerns within the aftermarket community. Febi has found that emission information has not been forthcoming from the OEMs. Despite these challenges, its parent company (the bilstein group) has been proactive and has forged close relationships with FIGIEFA to ensure that any information it receives is as accurate and recent as possible.
TMD Friction dispels the common misconception that the aftermarket will still have several months to prepare once the legislation comes into effect. While it is true that most new vehicles are unlikely to need replacement parts for some time, it is worth noting that certain high- mileage corporate users will need replacement fast-fit parts to be available immediately.
How will Euro 7 change fast-fit brake repairs?
Interestingly, around 80% of brake emissions originate from the brake disc, not the pad. TMD Friction explains that the interaction between the pad and disc creates a complex system in which material properties, surface characteristics, and thermal behaviour all influence particulate emissions. Friction manufacturers, including TMD Friction, are developing pad-disc sets that meet emissions regulations, while balancing performance, comfort, and cost-effectiveness.
Comline is undertaking significant research to determine whether pad friction formulations alone can achieve low emissions, while meeting the performance requirements for both OE and aftermarket (R90) braking approvals. Should this prove impossible, concurrent strategies are in place to evaluate different metallurgical and/or coating options to reduce wear on the disc surface. These reformulated discs may require a new type of friction compound in the pads. Delphi thinks a potential premium aftermarket option could be an NAO (Non-Asbestos Organic) ceramic-type high-performance friction material, with its more expensive ingredients mix. Currently, Delphi reports that the aftermarket is leaning towards a ‘low- metallic’ brake pad compound. Clearly, work is ongoing.
While TMD Friction acknowledges that renewing pads and discs together remains best practice, it predicts this will become essential once EURO 7 comes into effect. Febi agrees, theorising that pads and discs may need to be sold together in one box to ensure compliance. This brings logistical, packaging and labelling considerations to the fore.
EURO 7 has had a tricky gestation period and it is poised for a difficult birth. While the OEMs have taken years to pressure legislators into compromise, the aftermarket faces a similar uphill struggle. We shall await future developments with interest.
What the aftermarket representatives have to say...
Understandably, aftermarket trade bodies are concerned. The IAAF is not satisfied that regulatory clarity is provided only to original equipment manufacturers, not the independent aftermarket. The result, it says, is an uneven playing field and risks disrupting the availability of replacement brake parts, especially from November 2027. The IAAF predicts that this situation will increase costs for consumers and businesses, while distorting the vehicle maintenance market throughout Europe.
The IAAF reasons that, without swift EU level action, European aftermarket manufacturers and distributors risk being excluded from this market, leading to greater dependence on a limited number of suppliers. The result could be the €1.7 billion EU market for replacement brake parts on younger vehicles being reshaped significantly, because competition is being undermined.
A further issue, the IAAF highlights, is that aftermarket parts manufacturers lack access to the essential technical interoperability information required to develop EURO 7-compliant parts, putting them at a structural disadvantage. This is unhelpful because developing and approving EURO 7 brake particulate emission-compliant parts can take up to two years and the capacity of independent test facilities is limited.
The IAAF sees the November 2027 implementation deadline for all newly registered vehicles to comply with the emission values (set without any impact assessment for the aftermarket) as extremely tight for brake component producers. Therefore, any delay in the EU institutions' decision-making on the release of the required information will hinder preparation needed for the 2027 deadline. It will prevent the development of competitive aftermarket brake components to the detriment of both consumer drivers and fleet operators.
The Independent Garage Association (IGA) has also participated in the government’s consultation on EURO 7, representing the interests of independent garages nationwide. It emphasises that independent garages must continue to have secure and workable access to information and data that they need to conduct cost-efficient and effective repairs.
Tyre shedding...
Over fifteen years ago, Emissions Analytics reported that tyre pollution can be a thousand times more harmful than particulates emitted from tailpipes. As with brake friction material, particulates from tyres harm lungs and waterways. Unsurprisingly, manufacturers have been researching tyre particulates in readiness for EURO 7. The shedding of microplastics is a major focus; ADAC, Europe’s largest motoring organisation, conducts particle wear tests annually. Aside from their performance in use, quality tyre manufacturers are improving recycling, using more sustainable materials and removing harmful ingredients. 6PPD, for instance, is added to tyres to bolster UV and ozone resistance. Without it, tyres would harden and crack quickly, especially when exposed to sunlight. Unfortunately, 6PPD is released as the tyre rotates, and the particles react with ozone to form 6PPD-quinone, which kills certain fish species within several hours of exposure.
Retrofitting...
It seems as though pre-EURO 7 cars will not be required to have EURO 7 brake friction parts. Yet, it may be possible to upgrade older vehicles, especially when the owner prefers not to have dust all over their alloy wheels.
Delphi advises that it will be possible, in theory, to use the new EURO 7-approved friction material on older applications. Yet, it foresees a regulatory difficulty, because the older part number would have to be re-homologated for a new ECE R90, which would generate significant additional costs.
Euro 7 overview...
A. Brake and tyre particulates – the focus of this piece. Brake dust limits are higher for BEVs (3 mg/km), and hybrids/ICE cars have a higher limit of 7mg/km. Quite reasonably, febi questions how this can be enforced and who would be held responsible.
B. More rigorous tailpipe test procedures – these will include short journeys, high ambient temperatures and town/city conditions.
C. High-voltage battery life – they must last longer and retain at least 80% capacity after 60,000 miles, or five years and 72% after eight years and 100,000 miles
D. Tailpipe emission control system longevity – these will be expected to last twice as long (a decade or 124,274 miles). The UK Government is looking actively at enforcement. See the upcoming filters feature for more information.
E. Higher onboard monitoring – more sensors will likely feature to monitor tailpipe emissions. Theoretically, this will make the system more sensitive to elevated emissions levels.
