Improving air quality in urban areas

Strategy and concepts

Reduction of airborne pollutants — vehicle-related and in production operations

In order to reduce the pollutant emissions of our vehicles, we specify certain properties and necessary measures in the concept and/or the requirement specifications for major assemblies. These concept and requirement specifications are approved by the Committee for Model Policy and Product Planning. This is Mercedes-Benz Cars’ highest body and determines all product-related topics.

We have set ourselves the following goal for Mercedes-Benz’s entire new car fleet: The fleet shall no longer have any relevant impact on NO₂ emissions in urban areas from 2025. In addition, we want to develop further measures in order to reduce the particulate pollution due to our vehicles.

But not only our vehicles are a source of air pollution emissions — our plants also contribute. Lowering the airborne emissions from our plants is a constant task and a challenge — for our plant and facility planning teams and our daily operations.

Depending on their type and size, the plants in Germany are legally obliged to appoint an Immission Control Officer. Depending on the material in question, the maximum values and requirements for emissions and immissions are set by law. These values are the standard for our production plants and product developers. During the reporting year we adopted an internal standard covering the creation of an Air Emission Inventory applicable throughout the Group for production and sales locations and repair workshops. This contains the definitions of the principles of how we avoid, minimise or eliminate airborne pollutants, noise and odours that arise from our plants or facilities.

Volatile organic compounds (VOCs), in particular those produced in our paint shops, are especially important in this regard. In addition, our furnaces and energy generation systems release nitrogen oxides and sulphur oxides as well as particulate matter. The latter also occurs in the extraction of welding smoke from the bodyshell areas. All three are also significant air pollutants that must be reduced.

Technical Compliance Management System

Reducing or completely eliminating air pollutants requires exact knowledge of the processes and the framework conditions. For this reason, Mercedes-Benz Cars & Vans supports its employees in the automotive divisions with a technical compliance management system (tCMS). Its objective is to safeguard compliance with all legal and regulatory requirements throughout the product development and certification process. The tCMS defines values, principles, structures and processes in order to provide our employees with guidance and orientation especially with regard to challenging questions on how to interpret technical regulations.

Mercedes-Benz Cars & Vans has also created dedicated expert units for technical compliance in the development departments of vehicle-related divisions. Among other things, these expert units manage a network of technical compliance contact persons within development and certification departments. This network serves as a link between operating units and the compliance organisation. It supports the development departments in matters of technical compliance. Complex questions regarding technical compliance are evaluated and then decided in an interdisciplinary process that takes into account technical, legal and certification-relevant criteria (tCMS committees).

Our BPO whistleblower system is also available as a contact partner for reporting technical compliance violations. We have been operating the BPO since 2006. We urge the employees of the Group as well as external parties to report any suspicious facts relating to violations of the laws or of our internal regulations via this system. Examples of such violations include infringements of technical provisions or environmental protection regulations.

Measures

Measures in the development and production processes

Product design is a central starting point for the Mercedes-Benz Group to improve our performance from the ground up in the area of air pollution emissions. We are continually working on and investing in technologies and measures in order to further improve air quality.

New emissions laboratory in operation

The new emissions laboratory in Immendingen (ELI) at the Mercedes-Benz AG Testing and Technology Centre commenced regular operation at the beginning of 2021. Construction of the laboratory had started in summer 2018.

In the ELI, Mercedes-Benz car and van models are metrologically tested on roller test rigs. Conventional emission measurements are carried out on hybrid and combustion-engine vehicles; we test electric vehicles with respect to their electrical parameters such as electricity consumption and range. In addition, mountain drives at altitudes of up to 4,000 metres above sea level and at temperatures ranging from -30°C to +50°C can now be simulated — it is no longer necessary to carry out expensive extreme tests on the road.

The ELI also has additional laboratory and workshop areas that are used, for example, for tests of on-board diagnostics systems and to prepare for Real Driving Emissions (RDE) test drives with the portable emission measurement system.

The test stands initially ran in single-shift operation; this was changed to two-shift operation in September. Approximately 6,000 roller test rig hours are available per year.

Diesel engines cause less nitrogen oxide emissions

The Mercedes-Benz Group has further reduced the NO_X emissions of its diesel engines. This was possible thanks to an innovative overall package of engine and exhaust gas aftertreatment. We have consistently introduced this solution to the market in the form of the current engine generation OM 654 and 656, and have been continuing its further development since then.

Vehicles with diesel engines of the latest generation have low NO_X emissions in real driving operation — on many journeys they actually record values according to the RDE measuring process that are significantly lower than the current laboratory threshold limit of 80 mg/km. They achieve average NO_X emission values of around 20 to 30 mg/km in long-term operation over many thousands of kilometres under RDE conditions.

Replacing the fleet of existing old diesel vehicles with vehicles with the latest diesel technology, which is certified according to the Euro 6d-TEMP or Euro 6d standards, is an effective measure to further reduce NO₂ emissions in road traffic. This is shown by our internal study. For this study we installed measuring points at various locations in Germany and carried out detailed modelling of the emission behaviour of our Euro 6d vehicles. This enabled us to very precisely investigate how the emissions effected the NO₂ pollution. The measurements were carried out at what are known as NO₂ hotspots, i.e. locations with particularly high emission levels.

At Mercedes-Benz Cars, the entire new car fleet for Europe has been certified according to the Euro 6d-TEMP standard or better since June 2019 and according to Euro 6d since the fall of 2020 — and thus before this was legally required. As of 1 January 2021 all newly registered cars must conform to the Euro 6d emissions standard. This was made possible by the expanded exhaust gas aftertreatment system using an additional underfloor SCR catalytic converter, as well as other measures.

Reduced solvent emissions in production

The Mercedes-Benz Group seeks to be a leader in dealing with the production-related emissions of VOCs in the automotive sector. ⁠VOCs⁠ — volatile organic compounds — are a group of highly volatile organic hydrocarbons. These substances can easily pass from the liquid to the gaseous phase and are frequently harmful to human health. In automobile production VOCs are primarily released in the vehicle painting process. Different countries use a variety of methods to define and record VOCs; as a result, it is difficult to achieve uniform worldwide documentation. Moreover, the documentation of these emissions must comply with various legislative limit value specifications.

In order to minimise its VOC emissions, Mercedes-Benz AG has concluded a public-law contract with the City of Sindelfingen. This contract stipulates that at the Mercedes-Benz Sindelfingen plant, we may not release emissions of more than 20 grams of VOCs per square metre of painted vehicle surface. Measurements show that the emissions actually released in our plant are much lower than this limit.

Measures in the use phase

IT solutions and intelligent integrated use concepts enable both an efficient drive system and exhaust gas cleaning in addition to a further reduction in pollutant emissions. The Mercedes-Benz Group has also developed comprehensive concepts for air quality in the vehicle cab for the protection of the driver and passengers.

Software update improves nitrogen oxide emissions

The Mercedes-Benz Group develops software updates for all of its diesel vehicles in Europe that are certified according to the Euro 6b and Euro 5 emissions standards. These updates improve the vehicles’ nitrogen oxide emissions in real driving operation by an average of between 25 and 30 per cent.

As early as 2017, the Mercedes-Benz Group announced that it would offer voluntary software updates for several million diesel vehicles in Europe. We have in addition been carrying out recalls — during which software updates are also applied — at the order of Germany’s Federal Motor Transport Authority (KBA) since 2018. The recalls ordered apply to a number of vehicle models (cars and vans) that comply with the Euro 6b or Euro 5 emissions standards. The voluntary service measure for vehicles that are not included in the recall is meanwhile continuing as planned.

Hardware retrofit supported

Mercedes-Benz Group AG is participating in a hardware retrofit programme for diesel vehicles that was initiated by the German federal government. Specifically, Daimler has agreed to provide a financial subsidy of up to €3,000 (gross) per vehicle for hardware retrofitting if certain conditions are met. The hardware retrofitting must be developed and offered by a third-party supplier and approved by Germany’s Federal Motor Transport Authority (KBA). The offer is aimed at private holders of affected Mercedes models whose primary residence is in a priority region. These regions were defined by the German Ministry of Transport and Digital Infrastructure in 2017.

In the summer of 2019, the KBA approved retrofit solutions for various vehicle models. The retrofitted vehicles must comply with the NO_X limit value of 270 mg/km in real driving operation under specific conditions. This is intended to guarantee that the retrofitting significantly reduces NO_X emissions in permanent operation.

In 2019, we set up a special website to make it as simple and fast as possible for our customers to apply for the subsidy. Interested parties can visit this website in order to carry out a non-binding check as to whether they fulfil the precise requirements for receiving the subsidy. Customers can also use this website to request payment of the subsidy after the approved retrofit hardware has been installed.

The air quality in the 15 priority regions has improved demonstrably since 2017. At the Neckartor measuring point in Stuttgart, for example, the annual average NO₂ value for 2020 was below the EU limit of 40 µg/m³. The programme will continue until further notice despite the fact that demand for the hardware retrofit has dropped considerably.

Mercedes-Benz SUSTAINEER actively improves air quality

Particulate pollution levels due to road traffic play an important role in urban air quality. The SUSTAINEER technology platform from Mercedes-Benz Vans, which is based on the eSprinter, was presented in 2021. It brings together a large number of innovative solutions for more sustainable delivery transport — and actively contributes to improved air quality in cities in the process. In addition to a battery electric drive system, the SUSTAINEER features two particulate filters on board. These filters compensate for the particulate emissions up to a particle size of ten µm in the vehicle’s immediate surroundings by more than 50 per cent — 35 per cent while charging and 15 per cent in driving operation. The underbody particulate filter is positioned close to the rear axle, at the location of one of the highest concentrations of particulates in the vehicle’s surroundings. This filter captures the particulates that are stirred up by the SUSTAINEER and other vehicles while driving. The second filter is integrated into the front module and, together with the extractor fan already fitted in the vehicle, filters particulates out of the air. This enables it to also filter the surrounding air at low driving speeds and during the charging process. In addition, low-emission and low-wear brake discs and low rolling resistance tyres with less wear reduce the technology platform’s own particulate emissions.

Local measures for improving air quality

Intelligent mobility and logistics concepts can also help to improve the air quality in cities. To this end, the Mercedes-Benz Group has launched some local measures on its own initiative.

We have set up a Corporate Mobility working group at the Sindelfingen location. This group, which meets regularly, deals with the employees’ environmentally friendly mobility. The working group met once in each quarter during the reporting year and will be continued in 2022. Internal experts from the technical service (employee mobility), factory planning, works council and plant security have discussed innovative sharing solutions and shuttle services as well as how tried-and-tested solutions can be improved.

A CarSharing app for the fleet was introduced at the Sindelfingen location during 2021. As part of this pilot project employees are able to borrow and return the vehicles in the plant exclusively via the app, without the need for a key handover. The app will be introduced at further plant locations in 2022.

In addition, the working group joined representatives from the Cities of Böblingen and Sindelfingen to examine the accessibility of the Mercedes-Benz plant, i.e. how travel to and from the plant could be made more environmentally friendly for the employees. As a result, several municipal bicycle paths now extend to the gates of the Sindelfingen plant and traffic lights switch more favourably for pedestrians and cyclists.

As part of the local “Mobilitätspakt Rastatt” (Rastatt Mobility Pact) we have above all concentrated on improving the services offered by local public transport. One project addressed the cross-border commuting of employees between Rastatt and the Alsace region as well as the conditions that have to be created so that the plant can provide cross-border shuttle bus transport for about 700 shift employees. The plans for these shuttle buses are expected to be drawn up by mid-2022.

Furthermore, since October 2021 our employees have also been able to hire electric scooters from an external provider for the journey to the Rastatt plant. The scooters can be parked at the cycle parking facilities outside the plant site — the plant has made this possible specially for the provider. The conditions for the hire of the electric scooters are determined by the provider. More and more employees have now made use of the electric scooters. Because this reduces the number of road kilometres driven, it can also contribute to reducing pollutant and CO₂ emissions and ensuring a smoother flow of traffic within cities.

Reducing internal emissions and allergens

Clean air and allergy-tested surfaces in vehicle interiors are very important for the safety and comfort of the occupants. During the model development stage, the Mercedes-Benz Group therefore makes sure that emissions in the interior and allergens are reduced. We also use filters in the air conditioning system to prevent the intake of allergens. Since 2016, many of our car model series have borne the seal of quality of ECARF, the European Centre for Allergy Research Foundation, for their interiors. The ECARF seal is awarded to products whose anti-allergenic properties have been demonstrated in scientific studies.

The following measures are also helping to reduce interior emissions and allergenic substances in our vehicles:

• Further development of the delivery specifications with regard to emissions and odours in vehicle interiors — including limit values for suppliers
• Continuous component optimisation and further development of the materials and manufacturing processes used for interior components
• Monitoring of interior emissions by means of measurements in the in-house vehicle testing chamber

Effectiveness and results

The effectiveness of our management approach

The Mercedes-Benz Group regularly checks the plants’ compliance with the internal and external environmental protection requirements and reporting obligations as part of the environmental management activities at its production facilities. Among other things, checks are carried out to see whether the plants’ operations are in compliance with the laws regarding airborne emissions. In the event of any incidents relevant to environmental protection occurring, we document them and take all necessary measures to eliminate possible damage. The management system is monitored both by external auditors as part of the certification process (ISO 14001, EMAS) and by internal environmental risk assessments (environmental due diligence process).

The Mercedes-Benz Group takes the pollutant emissions of its vehicles into account at an early stage of the development process. We specify particular characteristics and target values for every vehicle model and every engine variant in the documentation that accompanies the development process. We also use these specifications to assess the milestones we reach in the course of product development. For this purpose, we compare the current status of a project with the target values and take corrective measures if necessary.

Results

Due to their low emissions, our current Mercedes-Benz vehicles that comply with the emissions standard Euro 6d only have an extremely small effect on NO₂ pollution in cities. The results are based on measurements of NO_X emissions and detailed modelling of the NO₂ immission in local areas subject to high traffic. One point shown by the data is that if every one of the 60,000 vehicles that pass the Neckartor in Stuttgart every day were replaced by a Mercedes-Benz vehicle with emissions standard Euro 6d, the NO₂ emissions from the year 2019 would be reduced from 28 µg/m³ to below 2 µg/m³.

Settlement of the legal dispute concerning diesel emissions

During 2020, Mercedes-Benz Group AG — formerly Daimler AG — and its subsidiary Mercedes-Benz USA LLC (MBUSA) took another important step toward legal certainty in connection with various diesel-related proceedings in the United States. After the US regulatory authorities approved a settlement of civil and environmental claims in September 2020, this settlement was approved by the United States Federal Court for the District of Columbia in the course of the reporting year. With this court approval, the settlement has now taken effect. The regulatory proceedings regarding the emission control systems of approximately 250,000 diesel vehicles in the United States have thus come to a conclusion.

Mercedes-Benz Group AG has cooperated with the United States regulatory authorities to the fullest extent during the investigation of these events. We did not receive any Notice of Violation from the EPA or the CARB in the course of these proceedings. In contrast to the settlement agreements of other manufacturers, we were also not placed under the supervision of an external compliance monitor.

As is specified in the settlement agreements, Mercedes-Benz Group AG and Mercedes-Benz USA LLC contest the allegations of the authorities and the claims of the consumers participating in the class action and do not admit to any liability to the United States, California, the plaintiffs, or in any other way. The settlements conclude the pending civil proceedings against Mercedes-Benz Group AG by the US authorities without establishing whether functionalities in the vehicles are inadmissible defeat devices.

On the basis of the existing compliance programme, Mercedes-Benz Group AG consolidated its existing processes and structures into a Group-wide technical Compliance Management System (tCMS) in 2016, and has since then instituted a series of measures to reinforce technical compliance. We have invested in the necessary resources and created positions in order to carry out these measures. The elements of the tCMS are listed in the Compliance Operating Plan, which is an annex to the settlement agreement with the US government. As part of the settlement with the US authorities, Mercedes-Benz Group AG promised to continue developing its present tCMS.

A detailed description of the institutional proceedings related to diesel emissions can be found in the company’s risk reporting.

The European Commission, Mercedes-Benz Group AG and other German car manufacturers also agreed on a settlement during the reporting year and thus concluded the proceedings regarding anti-competitive behaviours in connection with the development of SCR catalytic converter systems for cars with diesel engines. The proceedings related to the period between 2009 and 2014.