Report

Ever-higher: the rise of bonnet height, and the case to cap it

June 11, 2025

Report calls on European law-makers to cap bonnet height by 2035, recommending an 85 cm limit for further study

Executive summary

A growing threat

Vehicles with higher bonnets are more dangerous in crashes - but bonnet height continues to rise. Average bonnet height in newly-sold cars is increasing by half a centimetre (0.5 cm) a year, reaching 83.8 cm in 2024, up from 76.9 cm in 2010, according to T&E’s analysis of new registrations in the EU, the UK and Norway. Neither EU nor national laws limit the ongoing rise in bonnet height.

 Higher bonnets increase collision severity and impair vision

In crashes, high-bonneted SUVs and pick-up trucks typically strike adult pedestrians above the centre of gravity, often first hitting vital organs in the body’s core, with a higher likelihood of knocking them forward and down, and a greater risk of driving over them. On the other hand, low bonnets tend to hit pedestrians’ legs, giving them greater chances of falling towards the vehicle, or of being deflected.
High bonnets also reduce drivers’ vision of other road users - and can entirely compromise it. Drivers behind high bonnets can fail to see children in front of them, for example, when leaving a driveway or parking space. At junctions, compromised vision increases crashes, particularly when turning. Poor vision may also lead to more near-miss incidents, burdening all other road users with higher risks and increased danger.

According to Belgian crash data, a 10 cm increase in bonnet height (from 80 cm to 90 cm) raises the risk of death by 27% for pedestrians, cyclists and other vulnerable road users. And when high-fronted SUVs and pick-up trucks crash into regular cars, the higher-bonneted vehicles impose a 20 - 50% greater risk of serious injuries on the occupants of regular cars.

The higher the bonnet, the bigger the blind spot

Linked to work on child-friendly cities, T&E commissioned tests to examine the risks to children from high-fronted SUVs. This involved assessing the visibility of children standing in a central position to the front of popular high-bonneted vehicles. Seated behind the steering wheel of a RAM TRX pick-up truck, a driver of average European adult height cannot see children aged up to nine standing in front. Average height drivers in Land Rover Defenders cannot see children aged up to four-and-half standing in front.

Bonnet height cap will support electrification

The average bonnet height of new battery electric vehicles (BEVs) is 2.3 cm less than the average across all sales, according to 2024 data. This highlights that high bonnets are not necessary for vehicle electrification. In fact, lower bonnets reduce energy use, delivering more range for less battery. Enhancing road safety and producing cleaner cars go hand in hand.

Cap the height of new car bonnets by 2035, with 85cm recommended

T&E and the Clean Cities Campaign call on the EU and UK to cap the maximum height of car bonnets. We recommend a maximum height of 85 cm for new cars from 2035, subject to further study. An 85 cm limit aims to protect 95% of adult female pedestrians involved in crashes (only 5% of adult females in Europe have a centre of gravity lower than 86 cm). Being struck below one’s centre of gravity increases survival rates.

Urging the European Commission to publish proposals to cap and reverse bonnet height rise by July 2027, the deadline to review EU vehicle safety legislation, and asking UK to meet the same timeframe, the report also recommends:

  • Including bonnet height on the Vehicle Registration Certificates of newly-sold cars by 2030,

  • Adding the width, length and total vehicle height of new cars to vehicle registration certificates sooner under separate legislation (e.g. type approval), and

  • Adopt a Child Visibility Test to reduce vehicle blindspots, which we propose first for inclusion in Euro NCAP’s protocols before being brought into EU vehicle safety law.

Reform by countries and cities

  • Countries and cities are urged to make taxes and parking charges fairer by linking them to the weight and size of vehicles.

  • Across most of Europe, weight is the best available proxy until law-makers make size data more widely accessible.

The rise in high-fronted SUVs poses a clear and growing threat to public safety, especially for children. With no benefit to society and mounting evidence of harm, it's time for lawmakers at all levels to act. Capping bonnet height is a simple, effective step to protect all road users and curb the spread of oversized vehicles. It is neither safe nor credible to let bonnet height continue rising. At the same time, phasing the cap in over an 8.5-year lead time (with a proposal in mid 2027, and application from the start of 2035) helps minimise any disruption to existing production and designs.

Bonnet height in new cars rising by 0.5 cm a year

Vehicles with higher bonnets (or vehicle fronts) are more dangerous in crashes. Crash severity and road deaths increase in collisions with high-bonneted SUVs due to the higher point of impact at which pedestrians, cyclists and other vulnerable road users are struck.

Despite this, the evolution of bonnet height in new cars is under-studied. T&E is unaware of any previous Europe-wide assessment of bonnet height trends, and there appears to be just one in-depth national analysis to date.

Based on data provided by Euro NCAP, the safety rating programme for new vehicles, T&E analysed the evolution of bonnet height in newly-sold passenger cars in the 14 years to 2024. The data shows that average bonnet height is continually increasing in newly-sold cars.

Based on newly-sold cars in Europe (the EU, UK and Norway), average bonnet height has increased from 76.9 cm in 2010 to 83.8 cm in 2024 (see graph below). This is a rise of 7 cm (6.9 cm) over 14 years, an average yearly increase of half a centimetre (0.5 cm).

The rise in vehicle fronts closely matches the increase in SUV sales, a trend which dates to around 2010, and has been very significantly accelerated since 2015. In 2010 SUVs made up 11.5% of new sales, according to European Environment Agency data. In 2024 the comparable figure is 55.5%, according to T&E’s analysis of data provided by Dataforce. 

There is no legal limit on the bonnet height of new cars at European or national level. Without regulation, the bonnet height of new cars and SUVs is set to continue rising. Average bonnet height in newly-sold cars would reach 92 cm by 2040 based on the trend since 2010.  

If the average rises to 92 cm, a high proportion of bonnets would be more than one metre tall. For context, the bonnets of pick-up trucks average 106 cm (according to Belgian data), vehicles which are linked to greater collision severity and reduced vision, as further outlined below. 

Good practice vehicle design points to bonnet heights between 60 cm and approximately 75 cm. The risk of pedestrians sustaining serious head injuries in crashes increases as bonnet height exceeds 80 cm. Bonnets higher than 100 cm are “more aggressive”, linked to increased head injury risk (see further the literature reviewed below). 

Comparing bonnet height trends in large European countries 

Analysis of 2024 bonnet height in six major national markets - France, Germany, Italy, Poland, Spain and the UK - shows relatively little deviation from the European average (comprising the EU, UK and Norway; see graph below). In fact, average bonnet height in 2024 across all six countries lies between 82.3 cm (Germany) and 84.7 cm (Italy), with none of the six countries more than 1.5 cm above or below the European average of 83.8 cm. 

The respective figures for average bonnet height rise from 2010 to 2024 in the six countries shown in the graph below are as follows: France (77.3 to 84.3 cm), Germany (76.5 to 82.3 cm), Italy (76.3 to 84.7 cm), Poland (77.0 to 82.6 cm), Spain (77.5 to 83.8 cm), and the UK (76.9 to 83.7 cm). Click here for year-by-year data for EU countries, the UK and Norway.

Over the 14 year period to 2024 the trend line in each country generally tracks the European average. Italy, however, moved from having the lowest new bonnets in 2010 to the highest in 2024. Italy’s trend is explained by the swift rise in the sale of high-bonneted Jeep SUVs since 2010 coupled with a drop in Fiat sales from 2017. By 2024, Jeep models accounted for 5% of new sales in Italy, compared to approximately 1% on average across Europe.

Germany’s comparatively lower average bonnet height is explained by proportionately high-volume sales of lower-slung sedan cars, particularly those made by BMW, Mercedes, Porsche, and Tesla.

The UK mirrored the European average in 2024 but is a particular outlier for high-bonneted sales. The UK accounted for 39% of all sales of SUVs with bonnets more than 1 metre high, despite accounting for just 15% of total new car sales in Europe (EU, UK and Norway).

However, the UK’s cohort of high-fronted vehicles (approx 63,000 exceeding 1 m last year, including 53,000 Land Rover sales) is not apparent from its average bonnet height figure. This is because the UK also sees a comparatively large volume of low-bonneted sales (with Tesla, Mercedes-Benz and BMW featuring strongly in 2024). And statistically, the former and latter cohorts offset each other across a large-volume market which recorded 1.9 million new sales in 2024.

Vehicle-maker comparison: Jaguar Land Rover & Jeep have the highest bonnets

As well as having the highest bonnets, Jaguar Land Rover and Jeep are the only vehicle-makers with type-approved models that exceed 1 m. A number of other models with bonnets higher than 1 m are sold in Europe, but under Individual Vehicle Approval (IVA). The problems linked to the IVA loophole (which span shortcomings on safety, air pollution and climate) are accepted by the European Commission which has committed to table proposals to tighten the rules by the end of 2025. It is currently unclear if the UK government will also commit to addressing this loophole.

Scope, data coverage and terminology

The data assessed by T&E is confined to light duty passenger vehicle registrations formally known as M1. This includes cars, crossovers, SUVs and other light duty passenger vehicles, typically described collectively as cars (despite increasing size differences). Vans and pick-up trucks registered as light duty commercial vehicles (N1) are not included in this analysis of bonnet height (discussed further below).

The overwhelming majority of car sales across the EU, UK and Norway are included in the analysis, and data coverage rises over time. Between 2010 and 2018, the data covers an average of 81% of annual sales. From 2019 to 2024, data coverage rises to include an average of 88% of sales each year, and does not fall below 86% in any of these 6 years.

The data reflects what is known as bonnet leading edge height (BLEH). Here, for readability and simplicity we refer to “bonnet height” rather than using an acronym. The methodology to measure bonnet height in Europe is detailed under section 3 of Euro NCAP’s testing protocol for vulnerable road users.

Higher bonnets are more dangerous in crashes

High bonnets strike pedestrians higher up in the body, often hitting vital organs near the core, before knocking them forward and down, with a higher risk of driving over them, as illustrated below. On the other hand, low and sloping bonnets tend to hit pedestrians’ legs, giving them greater chances of landing on the bonnet and / or being deflected.

In Europe, 69% of pedestrian fatalities occur in urban areas, where speeds of 15 - 30 km/h are typical, and where lower speed limits (e.g. 30 km/h) are increasingly being adopted for given streets, roads or city areas. High bonnets are comparatively worse for pedestrians when they are struck by vehicles moving at speeds up to around 50 km/h, a point also made by Ptak. At higher speeds, the chances of survival drop for pedestrians struck by all vehicles, irrespective of bonnet height (as speed is of greater relative importance in high-velocity crashes). In short, the mitigating effects of lower bonnets would be most apparent in urban areas where more than two-thirds of pedestrians are killed.

European crash literature

The increased danger of higher bonnets was outlined in August 2023 as part of a major longitudinal study by VIAS, a Belgian institute specialising in road safety. VIAS analysed collisions in Belgium between 2017 and 2021, a sample cohort involving 300,000 road users in total. 

The crash data studied by VIAS shows that a 10 cm increase in bonnet height (from 80 cm to 90 cm) raises the risk of death by 27% for vulnerable road users. In the VIAS study, VRUs comprise pedestrians, cyclists, motorcyclists and scooter riders. VIAS also found that when high-fronted SUVs, such as pick-up trucks, crash into regular cars, they impose 20 - 50% more risk of serious injuries on the occupants of the regular cars. 

To better protect vulnerable users, VIAS stresses that the trend to higher bonnets must be arrested. Overall, the VIAS study presents a strong European research case to prevent and reverse ever-rising bonnet height. 

Euro NCAP notes that “the shape of the hood or bonnet leading edge can play a critical role in the outcome of a vehicle impact with a pedestrian and contribute to injuries”, and highlights that its test procedure “promotes energy absorbing structures and a more forgiving geometry that mitigates injuries”. 

High-fronted SUVs can offer relatively low protection to a pedestrian’s pelvis. For example, Euro NCAP testing on the leading edge of the Land Rover Defender’s bonnet, which is 115 cm high, “revealed poor protection to a pedestrian’s pelvis at nearly all points across [its] width”. NCAP also found that the same vehicle is also among those with elevated crash aggressivity towards regular cars, i.e. highly damaging in collisions with typical mid-sized family cars. 

Euro NCAP’s testing and rating focuses on avoiding and mitigating primary injuries, i.e. as the vehicle first strikes the pedestrian. Assessing the likelihood, and likely severity, of secondary injuries - i.e. as the pedestrian later hits the ground, or is struck again by the vehicle - can be more complex. 

However, the literature has assessed both primary and secondary injuries by using modelling and analysing real-world collisions. And overall, the literature echoes the VIAS findings (summarised above) regarding vulnerable road users, most particularly for pedestrians. Reading the literature, it is clear that: 

  • Good practice vehicle design points to bonnet heights between 60 cm and approximately 75 cm.

  • The risk of pedestrians sustaining serious head injuries in crashes increases as bonnet height exceeds 80 cm.

  • Bonnets higher than 100 cm are “more aggressive”, particularly linked to increased head injury risk.

  • Injury risk and severity are linked to bonnet height, with those struck below their centre of gravity at greater danger (see further the literature reviewed in detail in Annex 2 of downloadable report pdf).

The centre of gravity of lower-height females (5th percentile) is 86 cm. While it is lower for younger children, the centre of gravity in average height 11 to 12 year olds is comparable to the 5th percentile adult female. In other words, if bonnet height in vehicles produced after a certain date was limited to 85 cm, it would help protect almost all females and offer at least some protection for children from the age at which most will be walking independently. Or, put another way, the more bonnet height exceeds 85 cm, the more adults and children are at greater risk.

In short, danger to other road users rises with increased bonnet height. High-bonneted vehicles are linked to increased rates of death and serious injury in other road users. While we have focused most here on vehicle-to-pedestrian crash severity, similar issues - and increased risks - arise for cyclists and other vulnerable road users. Occupants of regular-sized cars are also at greater risk from high-fronted SUVs, as shown by the VIAS study.

Higher bonnets mean more children not seen

As well as increasing collision severity, higher bonnets reduce vision, particularly of children. Reduced driver vision risks increasing the frequency of collisions, and / or near miss situations.

Children are disproportionately killed as pedestrians in road traffic collisions. Of the approx 430 children killed a year on Europe’s roads, 31% die as pedestrians, compared to 18% when all age groups are taken together.

Linked to work by Clean Cities on child-friendly cities, T&E commissioned tests to better understand the extent to which drivers in high-bonneted SUVs can see children to the front. This analysis was undertaken by an expert in direct vision, Dr Steve Summerskill at the Loughborough School of Design and Creative Arts (SDCA).

Summerskill assessed the visibility of children of average European height standing in a central position at the front of two well-known high-bonneted vehicles, the RAM TRX and the Land Rover Defender, and one regular car, the VW Golf.

The RAM TRX was chosen as one of highest-fronted light duty vehicles sold in Europe. RAMs are not type approved for the European market, but are registered under Individual Vehicle Approvals (an approval route which is often problematic, and due to be tightened, at least in the EU). The leading edge of the RAM TRX’s bonnet is close to 130 cm high and an elevated area nearer the windscreen also contributes to obscuration by raising the line of vision above the bonnet edge, as shown below. At 115 cm, the Land Rover Defender is understood to have the highest bonnet of European-made models.

On the other hand, the VW Golf, with a bonnet height of 75 cm, is intended to act as a proxy for other vehicles with bonnet heights of 60 to 75 cm, which follow best practice in the design of vehicle fronts, according to the literature. Other vehicles with bonnet heights of 60 to 75 cm include the Audi A1, BMW 4 Series, Hyundai Ioniq, Kia Ceed, Mercedes Benz CLA, Opel / Vauxhall Astra, Porsche Taycan, Seat Leon, Skoda Fabia, Tesla Model 3 and Tesla Model Y.

Seated behind the steering wheel of a RAM TRX pick-up truck, a driver of average European adult height cannot see children of average height standing in front aged up to, and including, nine years old. Average height drivers in Land Rover Defenders cannot see children aged up to four-and-half standing in front.

Such compromised vision helps explain why drivers behind high bonnets often fail to see children in front of them, when leaving a driveway or parking space, for example. At junctions, compromised vision increases crashes, particularly when turning.

Reduced vision is also highly likely to lead to more near-miss incidents, burdening all other road users with higher risks and reduced safety. As yet, however, the risk of increased collision frequency does not appear to have been studied in European literature, while near miss situations generally go unrecorded in police reporting, which complicates the analysis of the effects of impaired vision.

For parents of young children cycling or scooting, however, the results of the tests conducted for this report are scarcely news. The testimony below indicates that experiencing such high risk levels turns families away from active travel choices, in turn feeding a negative loop of unwanted car use, physical inactivity, followed by negative health and environmental consequences.

Why improvements in both active and passive safety are necessary

Active safety improvements generally involve technological supports designed to avoid crashes, such as Automatic Emergency Braking (AEB). Passive safety improvements generally refer to enhanced vehicle design that lessens injury, such as bonnet heights of 60 to 75 cm.

Since July 2024 AEB has been required on almost all new cars and vans sold in the EU. (At the time of writing, Northern Ireland falls under the same requirement, but no similar legal provision applies in the rest of the UK.) AEB may activate - or not - depending on the technology, the weather and light conditions. Testing on numerous AEB systems shows they frequently don’t work in rain, fog, or poor light. Yes, AEB prevents a cohort of crashes. But rising bonnets make other crashes more severe.

There are also a small number of AEB systems - that used in the Jeep Avenger, for example - which have been found by Euro NCAP to perform poorly even in standard daylight situations. Unfortunately, however, a vehicle-maker may continue to fit poor-to-marginal AEB essentially because these systems satisfy EU type approval tests, and being rated poor-to-marginal by NCAP does not prevent their use.

Looking at the bigger picture, Europe is at risk of failing to meet its objective to halve road fatalities by 2030 (compared to 2019), and remains particularly challenged in reducing pedestrian road deaths. The literature underlines that improved road safety involves enhancing both active and passive safety - not an either/or approach. In short, there is a need both to lower bonnet height, and deploy and improve technologies such as AEB.

All other things being equal, a car with a good AEB system and a bonnet height between 60 and 75 cm will always be safer than a high-bonneted vehicle with the same AEB.

Part 2

Bonnet height distribution

46% of new cars have bonnets higher than 85 cm; 1.5% higher than 1 m

This section presents the distributional analysis of bonnet height. As we advocate for regulators to focus on car sales, we exclude van body types (VTBs).

After VBTs are excluded, approximately 46% of new sales exceed 85 cm. Some 10% of new sales surpass 93 cm, while 4.4% are above 97 cm, and 1.5% exceed 1 metre. The focus on vehicles with bonnets higher than 1 m is linked to greater crash severity, as outlined in the literature review (above).

Vehicle production with bonnets > 1 m is currently low in Europe

Vehicles with bonnets higher than 1 m comprise 1.5% of new sales. Looking at the location of their purchase and production, a number of points may be worth noting:

  • The UK accounts for a very disproportionate amount of sales where bonnet height exceeds 1m. More specifically, the UK makes up 15% of new car sales in Europe, but 39% of sales with bonnets higher than 1 m, namely 63,000 of 161,000 sales. In other words, of the 1.5% of sales over 1m in Europe, almost two fifths are sold in the UK.

  • The converse is that the EU, with 85% of new car sales, accounts for 61% of sales with bonnets higher than 1m (98,000 vehicles in 2024). Of the 1.5% of sales over 1m in Europe, three-fifths are sold in the EU.

  • Two vehicle-makers account for all sales with bonnets above 1 m, namely Jaguar Land Rover (JLR) and Jeep.

  • For the EU, the 98,000 new sales in 2024 of vehicles with bonnets above 1 m split 50/50 between sales by JLR and Jeep (i.e. 49,000 each).

  • In the UK, JLR accounts for almost all of its 63,000 high-bonnet sales, with just 1,500 Jeeps.

Relatively few models with bonnet height > 1 m

There are just 10 models with bonnet heights exceeding 1 metre, seven of which are made by JLR, and three by Jeep. The seven JLR models are the Land Rover Defender (with a bonnet height of 115 cm), Land Rover Discovery (112 cm), Range Rover Sport (110 cm), Land Rover Discovery Sport (107 cm), Jaguar F-PACE (105 cm), Range Rover Evoque (104 cm) and Range Rover Velar (104 cm). The three Jeep models are the Wrangler (123 cm), Compass (105 cm) and Renegade (103 cm).

In short, very few vehicles made in the EU exceed a bonnet height of 1m, and those exceeding this figure comprise less than 1% of sales within the 27 member states.

Bonnet height distribution of new battery electric vehicles (BEVs)

The average bonnet height of new BEVs in 2024 was 81.5 cm, or 2.3 cm less than the market average. After excluding van body types, 60% of new BEVs sold in 2024 do not exceed 85 cm, considerably higher than the comparative figure for all sales (46%). Currently, no BEV exceeds a bonnet height of 1 metre (the bonnet height of the Kia EV9 is at 1 m).

Measured by bonnet height, the single highest BEV segment is around 70 cm, and there are large concentrations from 78 to 94 cm. Recently-launched BEVs with bonnets not exceeding 85 cm include the Audi A6 e-tron (80 cm), BYD Sealion 7 (80 cm), Mini Cooper E (75 cm) and the VW ID.7 (80 cm).

Part 3

Recommendations

Cap the height of new car bonnets sold in the EU and the UK by 2035

T&E and the Clean Cities Campaign call on the EU and UK to cap the maximum height of car bonnets. We recommend a maximum height of 85 cm for new cars from 2035, subject to further study.

An 85 cm limit aims to protect 95% of adult female pedestrians involved in crashes (only 5% of adult females in Europe have a centre of gravity lower than 86 cm). Being struck below one’s centre of gravity increases survival rates.

The limit ultimately placed on bonnet height should also provide a reasonable level of protection for child pedestrians, particularly from approx 11 years of age, in line with increased independent mobility at this time.

Urging the European Commission to publish proposals to reverse and cap bonnet height rise by July 2027, the deadline to review EU vehicle safety legislation, and asking UK to meet the same timeframe, this report also recommends:

  • Including bonnet height on the Vehicle Registration Certificate of newly-sold cars by 2030,

  • Adding the width, length and total vehicle height of new cars to vehicle registration certificates sooner under separate legislation (e.g. type approval), and

  • Adopt a Child Visibility Test to reduce vehicle blindspots, which we propose first for inclusion in Euro NCAP’s protocols before being brought into EU vehicle safety law.

Reform by countries and cities

  • Countries and cities are urged to make taxes and parking charges fairer by linking them to the weight and size of vehicles.

  • Across most of Europe, weight is the best available proxy until law-makers make size data more widely accessible.

Discussion of the recommendations

Timing and legislative route

Here we discuss the recommendations further, with particular emphasis of enabling the car industry to prepare during the lead-in time to 2035.

We propose that the width, length and total vehicle height be added to the Vehicle Registration Certificates (VRCs) of new cars by 2028, and that this can be mandated under type approval legislation which is due to be evaluated by September 2026. This is a key first step, providing European consumers with vital information regarding their intended purchase. Germany already includes vehicle width and height on its VRCs, but does so voluntarily, i.e. EU law does not currently require their inclusion.

We advocate that proposals to cap and reverse bonnet height rise are published by July 2027, the deadline to review EU vehicle safety legislation. From the time of its publication, a proposal acts to change the design parameters governing new model development, and will likely discourage the emergence of new models with bonnets exceeding the limit proposed for 2035 (with 85 cm recommended here, subject to further study). Specific elements recommended for inclusion within the proposal achieve the following targeted outcomes:

  • Adding bonnet height to the Vehicle Registration Certificates (VRCs) of newly-sold cars by 2030 will empower consumers to make more informed choices. Recording bonnet height on VRCs is intended to complement the inclusion of other dimensions - width, length and total vehicle height - recommended above for inclusion on new VRCs by 2028.

  • Ending type approval for new models exceeding the bonnet height limit set for 2035 at a certain point in the early 2030s, e.g. 2032. Such a provision supports the phase-out of higher bonnets and ensures perverse effects are avoided (e.g. increased production of high-bonneted vehicles before the 2035 reform takes effect).

A new child visibility test is also recommended for vehicles, first for adoption by Euro NCAP, before being brought into EU vehicle safety law. Aimed at improving the visibility of two to eight year olds from the driver’s seat, it may be possible to include such a test in Euro NCAP’s safety assessment as soon as 2026/7. We also propose that child visibility testing is included in the July 2027 proposals to update the EU vehicle safety legislation. A concept level proposal for such a test is included in Annex 1 (found in the downloadable pdf report).

Van body types (in M1) and commercial vehicles (N1)

To facilitate the private use of vans as campers and other leisure purposes, we advocate that van body types (VBT) registered under M1 would be exempted from the 2035 limit. For clarity, the intended VBT exemption does not include pick-ups, a pick-up truck not being a van body type.

An anti-avoidance provision will be needed to prevent potential gaming linked to the VBT exemption. Such a rule could, for example, require that the model is predominately registered as an N1 light commercial vehicle, with a model losing its VBT exemption if its M1 registrations in the previous year outnumbered its N1 registrations. Vehicle-makers predominately targeting the M1 market will then design within the parameters of the 2035 limit.

Further work is needed to improve the bonnet profile of light commercial vehicles (N1). It is particularly important to progress the reform of Individual Vehicle Approval, the registration route for the largest pick-up trucks (which are imported, predominantly from North America). The Commission has committed to publishing proposals to tighten IVA by the end of 2025.

Bonnet height within newly-sold light commercial vehicles (N1) could also be further addressed by regulating specific examples of N1 vehicles, such as pick-up trucks, for example, by limiting their bonnet height from 2035.

Reforming taxes and parking charges

In parallel with addressing manufacturing, measures that discourage the purchase and use of ever-larger and heavier vehicles are also needed. At the national and local levels taxes and parking charges can be made fairer by linking them to vehicle weight and size.

France is the leading example of a country that varies Vehicle Registration Tax by weight. At the municipal level, four cities in France (Bordeaux, Grenoble, Lyon, and Paris), four in Germany (Aachen, Cologne, Koblenz, and Tübingen) and a London borough (Haringey) are among those that have made parking charges fairer by linking them to vehicle weight or size.

Part 4

Conclusion: reasons for law-makers to act

European road users face increased danger from large SUVs and pick-ups with bonnet heights above 85 cm, and further risk still from those exceeding 1 m. Children face the most acute risks.

Ever-higher bonnets feed an arms race that serves no useful function to society as a whole. Ever-higher bonnets are promoted by the makers of the largest vehicles, knowing they feed ‘mine is bigger’ competition that pits road users against each other. The intention behind using a firearms metaphor such as “Locked and loaded” (to market the Land Rover Defender), or the slogan “Built to impress, known to intimidate” (to sell RAM pick up trucks) is clear: such companies are trading on the intimidation that comes with high-fronted vehicles, ignoring their related dangers. To continue a do-nothing approach is to upend the common good in favour of a particularly aggressive approach to marketing vehicles.

High bonnets harm vehicle electrification. A bonnet height limit will help electrification because lower vehicle fronts reduce the use of energy and materials, delivering more range for less battery, together with more EVs overall (thanks to lower material consumption per vehicle).

Europe risks missing its 2030 road safety target to halve fatalities and serious injuries (compared to 2019), particularly on pedestrian deaths. Law-makers can send a clear signal to influence the design of future vehicles. Car-makers will respond with lower bonnets, reducing road deaths over the coming years. Safer, cleaner cars can come hand in hand.

Overall, limiting bonnet height is part of wider effort to discourage carspreading, which, intended or otherwise, amounts to a multi-pronged attack on public space, public safety and the common good that is steadily being advanced by the manufacturers of the biggest SUVs in particular. Putting a cap on bonnet height focuses on vehicle-making, tackling carspreading at source, as do width limits for new cars (proposed by T&E in 2024).

The societal harm imposed by high-fronted vehicles is increasingly understood. It is no longer safe or reasonable to leave bonnet height unregulated. The trend highlights the urgency of the situation. Law-makers interested in road safety need to progress a limit on bonnet height. Clear political commitments will stop the growth of the most dangerous high-fronted SUVs, and reduce risks for all road users. The case to act is compelling.

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