European regulation 2016/427 (the first package of the so-called Real-Driving Emissions (RDE) regulation) introduced on-road testing with Portable Emissions Measurement Systems (PEMS) to complement the chassis dynamometer laboratory (Type I) test for the type approval of light-duty vehicles in the European Union since September 2017. The Not-To-Exceed (NTE) limit for a pollutant is the Type I test limit multiplied by a conformity factor that includes a margin for the additional measurement uncertainty of PEMS relative to standard laboratory equipment. The variability of measured results related to RDE trip design, vehicle operating conditions, and data evaluation remain outside of the uncertainty margin. The margins have to be reviewed annually (recital 10 of regulation 2016/646). This paper lays out the framework used for the first review of the NO margin, which is also applicable to future margin reviews. Based on experimental data received from the stakeholders of the RDE technical working group in 2017, two NO margin scenarios of 0.24-0.43 were calculated, accounting for different assumptions of possible zero drift behaviour of the PEMS during the tests. The reduced uncertainty margin compared to the one foreseen for 2020 (0.5) reflects the technical improvement of PEMS over the past few years.