To rephrase my complaint: "conformity factor" should be more appropriately named "Excess Factor".
Consider a car just barely passing a CF 2.1 NOx test in 2017, then it obviously won't pass the stricter CF 1.5 NOx test in 2021. even though the NOx emissions limit will be identical!:
>European emission standards for passenger cars (Category M)*, g/km
Tier Date (Type Approval) Date (First Registration) CO THC NMHC NO
x HC+NO
x PM PN [#/km]
Diesel
Euro 6c - September 2018 0.50 - - 0.080 0.170 0.0045 6×1011
Euro 6d-Temp September 2017 September 2019 0.50 - - 0.080 0.170 0.0045 6×1011
Euro 6d January 2020 January 2021 0.50 - - 0.080 0.170 0.0045 6×1011
As the emissions standard becomes stricter, then that same car would only pass increasing Excess Factors
A 2017 NOx Excess Factor currently named "110% conformity factor CF" of 2.1 would result in a "50% conformity factor" car in 2021, even though the emission limits and the car are identical... does that make sense to the reader who wasn't pointed out the inversely defined terminology?
It reminds me of "symbolic euro" which does not mean a euro as a symbolic gesture at all, it means a sum of money representing however high the cost will turn out to be, say in damages,...