Brussels, 17.5.2018

SWD(2018) 189 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT

Accompanying the document

Proposal for a Regulation of the European Parliament and of the Council

on the labelling of tyres with respect to fuel efficiency and other essential parameters and repealing Regulation (EC) No 1222/2009

{COM(2018) 296 final}
{SEC(2018) 234 final}
{SWD(2018) 188 final}


Table of Contents

1.    Introduction    3

1.1.    Context    3

1.2.    Legal framework    4

2.    Problem definition    6

2.1.    Problem 1: Low visibility and awareness of the tyre label    7

2.2.    Problem 2: Compliance with the TLR    8

2.3.    Problem 3: Outdated, inaccurate and incomplete information on the tyre label    9

2.4.    Who is affected by the problems?    10

3.    Why should the EU act?    11

3.1.    Legal basis    11

3.2.    Necessity of EU action?    11

3.3.    Added value of EU action?    11

4.    Objectives: What is to be achieved?    12

4.1.    General objectives    12

4.2.    Specific objectives    13

5.    What are the available policy options?    14

5.1.    What is the baseline from which options are assessed?    15

5.2.    Description of the policy options    16

5.3.    Options/measures discarded at an early stage    27

6.    What are the impacts of the policy options?    30

6.1.    Environmental impacts    31

6.2.    Social impacts    33

6.3.    Economic impacts    35

6.4.    Other impacts    37

7.    How do the options compare?    39

7.1.    Summary of impacts and options comparison    39

8.    Preferred option    41

8.1.    Description of the preferred policy option    41

8.2.    REFIT (simplification and improved efficiency)    43

9.    How will actual impacts be monitored and evaluated?    47



1.Introduction

This impact assessment relates to the review of Regulation 1222/2009 1 on the labelling of tyres (hereafter the “Tyre Labelling Regulation” or TLR). It examines how the effectiveness of the European tyre labelling scheme could be improved to support cleaner, safer and quieter vehicles and to maximise its contribution to the decarbonisation of the transport sector.

1.1.Context

Lowering the demand for energy by 'putting energy efficiency first' is one of the five main objectives of the Energy Union strategy. In 2015, Member States in the Council confirmed the imperative need to reach the 20% energy efficiency target for 2020. In November 2016, the Commission proposed to further strengthen this beyond 2020 with a 30% EU energy efficiency target for 2030 2 .

In its Communication "A European Strategy for Low-Emission Mobility 3 the Commission announced that by 2050 greenhouse gas (GHG) emissions from transport need to be at least 60% lower than in 1990 and be firmly on the path towards zero. Therefore, the "Third Mobility Package" will include initiatives to reduce emissions by cars and lorries, to increase safety of road transport and to reduce pollution. The EU 2030 framework for energy and climate includes a target of at least a 40% cut in domestic EU greenhouse gas emissions compared to 1990 levels.

The transport sector accounts for one third of European energy consumption. Road transport was responsible for about 22% of the EU’s total greenhouse gas emissions in 2015 with a steady increase since 1990 when the share was 13%. Reducing these emissions is an acute challenge given that from 2010 to 2050 it is estimated that passenger transport will grow by 42% and freight transport by 60% 4 . Increasing the fuel efficiency of vehicles is thus a key element in decreasing transport emissions and also contributes to reducing the EU’s dependence on energy imports.

The rolling resistance of tyres accounts for 5-10% of a vehicle’s fuel consumption 5 . Decreasing rolling resistance is therefore important for increasing fuel efficiency and decreasing greenhouse gas emissions.

Furthermore, the Commission's Communication "A European Strategy for Plastics in a Circular Economy" 6 specifically mentions the need to study how to reduce unintentional release of microplastics from tyres, possibly through tyre design, minimum requirements for abrasion and information requirements.

Finally, the European Union is committed to reducing noise pollution to WHO recommended levels. Given that at speeds over 35 km/h for passenger cars and 60km/h for heavy vehicles, tyre road noise is the dominant noise source 7 , reducing noise from tyres is essential to tackle its health effects.

1.2.Legal framework

Recognising the importance of energy efficient tyres, the EU adopted in 2009 two sets of rules relating to tyres:

1.The TLR setting out Union requirements harmonising the information on tyre parameters to be provided to end-users allowing them to make informed purchasing choices.

2.The Regulation on type-approval requirements for the general safety of motor vehicles 8 (hereafter the “General Safety Regulation” or GSR) putting in place harmonised technical requirements that tyres must satisfy before they can be placed on the Union market.

The GSR puts in place minimum requirements for, amongst others, (i) the rolling resistance, (ii) external rolling noise and (iii) wet grip performance of tyres. These minimum requirements became applicable for all three parameters from 1 November 2012, with a second tier of more stringent requirements for the rolling resistance starting to apply on 1 November 2016 (with further requirements coming into application in 2018 and 2020).

In addition to the GSR, two other legal frameworks are particularly relevant to the TLR, relating to market surveillance and energy labelling.

As with any other product placed on the Union market, the compliance of tyres with the applicable requirements under the TLR must be checked by national market surveillance authorities. Regulation 765/2008 9 sets the framework for market surveillance by all the Member States and ensures efficient cross border market surveillance.

Although tyres are not covered under the energy labelling framework, it should be noted that this framework was updated in 2017 with the adoption of Regulation 2017/1369 10 . This introduced a number of new elements, such as a product registration database, and new rules on visual advertising and on distance and internet sales Where appropriate rules on tyre labelling should be aligned to this updated framework.

The TLR 11 relates to C1, C2 and C3 tyre types 12 , as defined in article 8 of the GSR. The definition of tyre types is based on the vehicles they are primarily designed for, including the weight and passenger capacity, and on the tyre load and speed indexes of the tyres, as shown in the table below. C1 tyres are used typically for passenger cars, C2 tyres for light commercial vehicles (LCVs) and C3 tyres for heavy commercial vehicles (HCVs).

Table 1: Definition of tyre types included in the TLR, based on the GSR

Tyre type

Designed primarily for vehicle categories

Seats in addition to driver’s seat (based on vehicle category)

Vehicle weight (based on vehicle category)

Load capacity index

Speed category symbol

C1 tyres

≤8

≤3.5 t

Not applicable

Not applicable

C2 tyres

≥8

≥3.5 t

≤121

≥N

C3 tyres

≥8

≥3.5 t

≤121

≤M

≥122

none

In the current TLR, three tyre performance parameters are specified and included on the label for C1 and C2 tyres: fuel efficiency, wet grip, and external rolling noise measured value (in dB). For C3 tyres there is no label, but information on the three performance parameters must be provided in technical promotional material.

Figure 1: Example of the tyre label for a tyre with fuel efficiency class B, wet grip class B, and external rolling noise of 72 dB (equivalent to two “soundwaves” on the scale)

The three performance parameters are interrelated. For example, improving rolling resistance can have an adverse impact on wet grip, thereby decreasing road safety. Similarly, the improvement of the wet grip might have an adverse impact on the external rolling noise, increasing noise pollution. This “contradiction” doesn’t mean that the parameters of fuel efficiency, wet grip and external rolling noise cannot all be improved at the same time.

The TLR and the GSR on tyres can be seen as a "parallel" to the EU's ecodesign and energy labelling framework (which is not applicable to means of transport). Ecodesign regulations set minimum energy efficiency requirements that products must satisfy before they can be sold on the Union market, while energy labels inform the end-user of their energy consumption so that they can make informed purchasing decisions, resulting in a combined "push and pull" effect.

This same "push and pull" effect can also be seen in the EU mobility framework, where Regulations on emission performance standards set mandatory emission reduction targets for new passenger cars 13 and new light commercial vehicles 14 , while the car labelling Directive helps consumers to buy or lease cars which use less fuel (and thereby emit less CO2) and encourages car manufacturers to reduce the fuel consumption of new cars 15 .

Article 14 of the TLR requires the Commission to assess its effectiveness, addressing inter alia the following issues:

The effectiveness of the label in terms of end-user awareness, in particular whether the provisions of Article 4(1)(b) are as effective as those of Article 4(1)(a) in contributing to the objectives of this Regulation;

Whether the labelling scheme should be extended to include retreaded tyres;

Whether new tyre parameters, such as mileage, should be introduced;

The information on tyre parameters provided by vehicle manufacturers and retailers to end-users.

To support this assessment, an independent review study was conducted in 2016 16 . The study was based on surveys and interviews targeting different actors in the tyre supply chain and market surveillance authorities with the aim to assess the effectiveness of the labelling scheme, the level of enforcement and the possibilities to improve the regulation. It included a consumer survey with 6051 car owners in six Member States 17 .

Furthermore, in accordance with Article 11(b) of the TLR, the review study analysed the possibility of covering tyres designed to perform better in ice and snow conditions compared to normal tyres. An open public consultation (see Annex 2 for the results) and an evaluation (Annex 5) complemented the review study.

Based on the review study, the Commission published a Report to the European Parliament and the Council assessing the need to review Regulation (EC) 1222/2009 18 . This report concluded that certain aspects of the TLR could be strengthened or made more effective. Despite the increased tyre performance already achieved with the current Regulation, potential exists for further fuel savings as well as for increased road safety and reduced noise emissions.

2.Problem definition 

Article 1 of the TLR provides that:

"The aim of this Regulation is to increase the safety, and the economic and environmental efficiency of road transport by promoting fuel-efficient and safe tyres with low noise levels.

This Regulation establishes a framework for the provision of harmonised information on tyre parameters through labelling, allowing end-users to make an informed choice when purchasing tyres."

The review study showed that, in addition to the GSR, the TLR has delivered fuel savings of about 1% annual fuel consumption resulting in 170 PJ/year (and in turn CO2 emission reductions of 12 MtCO2/year), and increased tyre safety performance (around 260 fatalities avoided per year) and a slight decrease of the external rolling noise 19 . However, it has become evident that it has not fully reached the above-stated aims. The causes for the reduced effectiveness and efficiency of the label are both external and linked to the label itself. On the one hand, the ‘external’ factors are the relatively low awareness among end-users of the existence of the label and the inadequate enforcement of the rules by Member States’ market surveillance authorities (MSAs). On the other hand, the factors intrinsic to the label are outdated performance classes, and inaccurate and incomplete information.

In the absence of any action, the TLR might still be able to drive the market towards more efficient, safe and quiet tyres. Nevertheless, further improvements would allow the TLR to reach its aims in a more effective and efficient manner.

2.1.Problem 1: Low visibility and awareness of the tyre label

The problem: A consumer survey 20 showed that less than half of car owners were aware that the tyre label existed. Moreover, the review study found that in some Member States 21 , up to 90% of shops inspected by MSAs did not have tyres on display, as they were all in stock elsewhere. This was confirmed by the open public consultation where only 20% of respondents indicated they saw the label before purchasing tyres.

The result is that in many cases the customer is unable to see the label before buying the tyres and that therefore the label cannot perform its key function, i.e. influencing purchasing decisions.

The drivers of the problem: The low awareness of the label is caused by several factors:

(1)In brick and mortar shops 22 only about 20-30% of customers see the tyres before purchasing them; therefore most customers also do not see the label in this setting.

(2)It is not a requirement for a retailer to show the label in online shops or in other distance selling environments. This is relevant since online sales of tyres are increasing 23 .

(3)Some end-users of tyres do not purchase their tyres directly, but instead through leasing contracts or as part of a fleet solution, thus not seeing the tyres or the label when purchasing.

(4)End-users of C3 tyres are only provided with the information on the three performance parameters but are not required to be provided with the label itself. As a result they are provided with less easily understandable and comparable information.

(5)For tyres sold with a new vehicle (OEM tyres 24 , which constitute 25% of tyre sales in the EU 25 ), the TLR includes a requirement to provide information on the fuel efficiency, the wet grip and the external rolling noise classes only where end-users are offered a choice at the point of sale between different tyres to be fitted on the new vehicle they want to buy. However, in many situations end-users are not offered such a choice. In these cases, there is no obligation for the vehicle manufacturers and retailers to provide information on the key parameters of the label. This constitutes a missed opportunity for end-users to be made aware of the tyre label and to benefit from the information contained in it when purchasing tyres.

2.2.Problem 2: Compliance with the TLR 

The problem: Preliminary results of the MSTyr15 project on market surveillance for tyres, involving surveillance authorities from 14 Member States and Turkey 26 , show that 4.2% of labels inspected were non-compliant, not visible or not available and that 15% of tyres tested for wet grip and rolling resistance were non-compliant. The 2016 Review study surveyed 14 market surveillance authorities (11 Member States and 3 from the German regions). Compliance levels varied from 25% to 100% but the numbers of inspections and tests undertaken varied greatly. Of those interviewed, only two Member States’ authorities (Germany and Belgium) performed laboratory tests to check the values declared on the labels.

75% of those questioned in the consumer survey for the review study said that if their confidence in the label were higher, it would have a greater influence on their purchasing decisions.

This level of non-compliance is comparable to that found in the Commission’s Evaluation of the Energy Labelling Directive 27 , which estimated that 10-25% of products on the market are non-compliant with applicable requirements and that around 10% of envisaged energy savings are lost due to non-compliance 28 .

The drivers of the problem: Compliance with the TLR has four main drivers:

(1)The degree of, and approach to, market surveillance varies greatly between Member States, with very few MSAs conducting laboratory tests to verify the label values 29 ;

(2)Limited resources and low priority for market surveillance for tyres;

(3)High cost and too few accredited test facilities are the main barriers for increased laboratory testing of tyres, according to MSAs;

(4)Some MSAs 30 had difficulty obtaining technical documentation in situations where the manufacturer was located in another Member State or outside the European Union.

2.3.Problem 3: Outdated, inaccurate and incomplete information on the tyre label

The problem: The set-up of the label itself suffers from three distinct flaws:

a)Outdated performance classes: The current minimum requirements of the GSR mean that it is no longer possible to sell the lowest performing tyres on the Union market. As a result, classes G and F (and E for C3 tyres) for rolling resistance, class F for wet grip and the third soundwave class for noise are now empty because tyres with corresponding performances are no longer allowed on the EU market. Additionally, the current label scheme for C1 and C2 tyres has no D class for rolling resistance and wet grip. At the other end of the scale, the top classes were already populated in 2017. This was only at the level of 1% of the tyres made available on the market for the rolling resistance, but up to 26% for the wet grip and up to 18% for noise (of C1 tyres). Based on experience of energy labelling for other product groups it may be expected that the top classes of the tyre label will become increasingly populated over the next years. This would reduce the effectiveness of the label.

b)Inaccurate information: tyre tests conducted by some MSAs and consumer organisations showed deviating results compared to the declared label values for all three performance parameters, but in particular for wet grip 31 .

c)Incomplete information: The tyre label only covers fuel efficiency, wet grip and external rolling noise in ‘normal’ conditions. There is no information on the performance of tyres in snow and ice conditions, which is particularly relevant in the Nordic countries and in mountainous areas. This is potentially misleading for end-users, as tyres with very good level of performance under ice conditions tend to have in general low wet grip rates 32 . Retreaded tyres 33 and studded tyres 34 are not covered by the label. The label also does not cover abrasion and mileage, although this information could raise end-users' awareness in the context of the circular economy and plastics strategies.

The drivers of the problem:

(1)Outdated performance classes: the outdated performance classes are mainly caused by the banning of tyres with lower performance through the GSR, and to a lesser extent by the expected increased population of the top classes on the label. Therefore, the available scale is not fully used, reducing the impact of the label to incentivise purchasing of better performing tyres thereby making it less effective.

(2)Inaccurate information: the deviating test results are attributed by MSAs 35 to different test conditions, incorrect application of the test methods referred to in the TLR and a lack of transparency of testing conditions. The problem is most pronounced for the wet grip parameter. In addition, it is solely the responsibility of the manufacturers 36 to declare the classes on the label.

(3)Incomplete information: the incompleteness of the label stems from the TLR itself which is silent on snow and ice indications, on retreaded or studded tyres and on mileage and abrasion. For these two last parameters, the problem relates to the lack of reliable, reproducible and accurate testing procedures.

2.4.Who is affected by the problems?

Society as a whole is affected through the increased environmental impact associated with energy consumption, increased fuel costs to end-users and businesses, and negative health and safety impacts. An estimate 37 of using only tyres in the top fuel efficiency class in the EU shows potential reductions in CO2 emissions of 47 Mt per year (corresponding to fuel savings of EUR 11 billion), which is equal to nearly 5% of the total CO2 emissions from road transport in the EU. It could reduce fuel consumption by up to 5%, corresponding to EUR 250 over the lifetime of a set of passenger cars tyres 38 .

In addition, tyre wear particles generated from the friction between the tyre and the road are released to the environment as particles of different sizes and in different amounts. Smaller particles contribute to particulate air pollution and larger particles deposit on the road and run-off into streams and accumulate in the oceans, often referred to as microplastics. According to the Commission's Communication "A European Strategy for Plastics in a Circular Economy" 39 , it is estimated that between 75 000 and 300 000 tonnes of microplastics in total are released into the environment each year in the EU, of which around three quarters come from tyres 40 .

End-users, manufacturers and retailers are also negatively impacted by a reduced efficiency of the TLR. For instance, the review study pointed out that the disparate enforcement of the label negatively affects end-users’ confidence in the information on the label, and has given retailers the impression that tyre labelling has a low priority with surveillance authorities. This undermines the effectiveness of the label and constitutes a barrier to innovation and market transformation. It also prevents a level playing field by putting at disadvantage manufacturers and retailers who comply with the TLR requirements compared to those who do not.

Furthermore, considering the whole lifecycle of the tyre, choosing tyres with low fuel efficiency can potentially be costlier to end-users and businesses, due to higher fuel consumption in the use phase. An estimate of using only fuel efficiency class A tyres in the EU shows an annual fuel savings potential of close to 8,5 billion litres 41 .

3.Why should the EU act? 

3.1.Legal basis

The legal basis for the legislative proposal is Articles 114 and 194(2) of the Treaty on the Functioning of the European Union (TFEU) on the internal market and energy efficiency respectively.

3.2.Necessity of EU action?

Action at EU level provides end-users with the same, harmonised information, no matter in which Member State they choose to purchase their tyres. This is becoming all the more relevant as the online trade increases. With a tyre labelling scheme at EU level, energy efficient and safe tyres that reduce noise pollution are promoted in all Member States, creating a larger market for such tyres and hence greater incentives for the tyre industry to develop them.

It is essential to ensure a level playing field for manufacturers and retailers as regards the information supplied to customers for tyres for sale across the EU internal market. For this reason EU-wide legally binding rules are necessary.

Market surveillance is an activity carried out by Member States' authorities. To be effective, the market surveillance effort must be uniform across the European Union, thereby supporting the internal market and incentivising businesses to invest resources in designing, making and selling energy and fuel-efficient tyres.

3.3.Added value of EU action?

A harmonised regulatory framework at EU level provides added value compared to having regulations at Member State level, because it reduces costs for manufacturers by allowing them to enter the entire EU market with only one label. This strengthens competitiveness EU-wide and facilitates easier inter-European trade of tyres, which also benefits end-users in terms of lower prices and a wider range of products.

Fully achieving a level playing field and avoiding fragmentation of the internal market, requires maintaining and improving the harmonised labelling scheme at EU level.

Increased market take-up of fuel-efficient tyres, through optimisation of the TLR, will contribute to achieving the targets agreed under the EU 2030 framework for energy and climate including the energy efficiency target 42 and the reduction of at least 40% in domestic reduction in GHG emissions compared to 1990 43 .

The energy cost savings will accrue to end-users and offset the increased purchase price of higher performing tyres, leading to an overall decrease in Total Cost of Ownership (TCO) for the end-user 44 . For society as a whole the TLR provides added value in terms of safer tyres (better wet grip), through the related decrease in the number of fatalities and severe injuries in traffic accidents.

Promotion of market transformation towards fuel efficient and safe tyres is in line with the EU’s aim of land transport policy, which is to promote efficient, safe and environmentally friendly mobility. Extending the labelling provisions to C3 tyres is in line with the Commission’s proposal for a Regulation on the monitoring and reporting of CO2 emissions from and fuel consumption of new heavy-duty vehicles 45 .

The TLR also supports the implementation of the Energy Efficiency Directive, which requires Member State to ensure that central governments only purchase tyres (and other energy-related products) with a high energy performance (i.e. in the highest fuel efficiency class) insofar as it is consistent with cost effectiveness, economic feasibility, wider sustainability technical suitability as well as sufficient competition.

The proposed changes to tyre labelling will also play an important part in the objective of “empowering consumers” formulated in the EU Consumer Policy Strategy 2007-2013 46 , “Consumer empowerment in the EU” 47 and a “New Deal for Consumers” 48 , since it will enable consumers to make an informed and better choice when buying tyres. Finally, the General Product Safety Directive 2001/95/EC 49 , and in particular the Rapid Alert System on dangerous products (RAPEX), may be relevant since inadequate or erroneous tyre labelling could lead to a safety risk for consumers and could be notified in RAPEX.

4.Objectives: What is to be achieved?

4.1.General objectives

A revised TLR should pursue the following general objectives:

1)Promote fuel efficiency to contribute to the EU's objective to reduce energy consumption by at least 30% and domestic GHG emissions by 40% by 2030;

2)Increase road safety to contribute to the target of halving the number of road deaths between 2010 and 2020, endorsed by the Council of the European Union in 2010 50 and reconfirmed by European Transport ministers in a meeting in Valletta on 29 March 2017 51 ;

3)Decrease external rolling noise to reach the target in the 7th Environmental Action Programme 52 of the European Union to significantly decrease noise pollution and move closer to the World Health Organisation (WHO) recommended levels 53 ;

4)Promote competitiveness of the EU tyre industry by ensuring free circulation of compliant tyres and encourage innovation within the internal market.

There are synergies between these objectives. Reducing fuel consumption (e.g. by reducing rolling resistance of tyres) leads to lower CO2 and other pollutants emissions. Tackling the problem at EU single market level safeguards and enhances the efficiency and effectiveness of the current EU measure while ensuring the free circulation of products within the internal market.

4.2.Specific objectives

The specific (sub) objectives that flow from the above-mentioned general objectives are:

1)Raising the profile of the tyre label by inter alia (i) making sure that tyre label is shown at all times when tyres are sold; (ii) completing the tyre label to include snow and ice tyres; and (iii) aligning, where appropriate, with the energy labelling framework.

2)Improving end-user’s trust in the tyre label by inter alia (i) ensuring that the tyre label is adequately enforced; and (ii) improving test standards.

The TLR can contribute to achieving the general and specific objectives mentioned above to a larger extent than it currently does (see Annex 5 on evaluation), by addressing the problems defined in Section 2.

The table below provides an overview of the relation between problems, drivers and possible measures. Section 5.2 explains the different measures in more detail.

Table 2: Overview of the relation between problems, drivers and measures

5.What are the available policy options?

The procedure for identifying policy options (POs) follows from the Better Regulation Toolbox methodology 54 . Specific measures in the POs are the result of a combination of initiatives mentioned in the Review study, the evaluation in Annex 5, the open public consultation in Annex 2, the Inception Impact Assessment 55 , and inspiration taken from the Ecodesign Directive 56  and the Energy Labelling Framework Regulation 57 .

The measures have been linked to the policy options in the next table.

Table 3: Modelled options

Policy options and sub-options

Description

PO1 (BaU)

Baseline – Business as Usual. How the market would develop without changing the current regulation

PO2

Non-regulatory measures

1.Information campaigns

2.Joint enforcement actions

3.Mandate to revise/develop relevant testing methods (e.g. abrasion)

PO3

Targeted legislative actions

4.Online labelling

5.Mandatory labelling of tyres delivered with vehicles at all times

6.Require label to be provided for C3 tyres

7.Require label to be provided to end-users in case of purchase through leasing contracts or as part of a fleet solution

8.Mandatory inclusion of snow performance on the label

9.Mandatory inclusion of ice performance on label

10.Re-adjustment of the label classes

11.Tyre registration database

12.Technical documentation and product fiche content

13.Amendment of current Annex V on test method for wet grip of C1 tyres

14.Amendment of current Annex IVa on laboratory alignment procedure for the measurement of Rolling Resistance Coefficient (RRC)

15.Extension of the type approval process to include label declaration

PO3B

As policy option 3, but without re-adjustment the label classes

PO3C

As policy option 3, but without the extension of the type approval procedure to the declaration of the label values

PO3|D

As policy option 3, but without online labelling

PO3E

As policy option 3, but without the tyre registration database

PO3F

As policy option 3, but without the effect of further OEM requirement

PO4

Policy option 2 + option 3. Non-legislative measures and targeted legislative actions are all applied

PO4B

As policy option 4, but without re-adjustment the label classes

PO4C

As policy option 4, but without the extension of the type approval procedure to the declaration of the label values

PO4D

As policy option 4, but without online labelling

PO4E

As policy option 4, but without the tyre registration database

PO4F

As policy option 4, but without the effect of further OEM requirement

Section 5.2 describes the specific measures in each option in more detail.

5.1.What is the baseline from which options are assessed?

In the baseline, the current TLR and all other relevant EU-level and national policies and measures are assumed to continue, including the GSR. This baseline will be referred to as BAU 58 (Business As usual) or ‘no-action’ scenario.

The base cases include the Original Equipment Manufacturer (OEM) tyres sold with new vehicles for each tyre type.

So far, tyre labelling has been able to transform the market in a positive direction for all the performance parameters included in the label, even though the effect on the noise level is less clear (see the Evaluation report in Annex 5). There is still room for the label to drive the market because the market share of tyres with the best fuel efficiency class A is still low (less than 1% of the tyres sold), but due to the problems described in Section 2, the full potential is not reached in the baseline scenario.

5.2.Description of the policy options

5.2.1.Option 1 – No action

PO1 (as described above) forms the baseline for the impact assessment of the other options.

5.2.2.Option 2 – Non-regulatory measures

PO2 is based on the outcome of the review study, which shows a need to improve end-users' knowledge of the label. Indeed, the consumer survey showed that only around half of the respondents were aware of the label before taking the survey.

5.2.3.Option 3 – Targeted legislative measures

Article 11 of the TLR empowers the Commission to adopt implementing acts to amend and adapt the TLR to technical progress. The scope of the article could be expanded to changes to the label itself. Therefore, inclusion of the snow, ice, mileage and abrasion performance, and re-adjustment of the label classes would be achieved via delegated acts.

Delegated acts are the appropriate instrument as Article 11 refers to amending non-essential elements and supplementing the Regulation, which is what delegated acts under Article 290 of the Treaty on the Functioning of the European Union are designed for.

The majority of the targeted legislative actions would take the form of amendments to the current TLR and/or its annexes, as a part of the current revision. A further amendment that should be considered is reinforcing the requirements of the TLR on penalties and enforcement.

5.2.4.Option 4 – Non-regulatory measures and targeted legislative measures

Details of the measure under Options 2 and 3 are set out below.

Option 2 - Non-regulatory measures (see above 5.2.2.)

1.Information campaigns

Target groups. In their replies to the consultation carried out for the review study, tyre manufacturers, retailers and consumer organisations recommended organising promotion campaigns to increase end-users’ knowledge of the label and explain its meaning. The target groups should be end-users in the C1, C2 and C3 tyre segments. However, awareness campaigns targeting end-users of C1 tyres are considered the most important because they constitute the largest share of tyre sales. Moreover, information campaigns should target tyre retailers, with efforts focused on (but not limited to) the development of educational tools such as brochures, short videos, webinars, etc. Guidance could be developed in cooperation between Member States and retail organisations and be supported by the European Commission. Tools for retailers could partly build on information material developed for end-users, providing them with a basis to inform end-users about the label parameters.

Geographic scope and initiators. The awareness campaigns should be run at national level by Member State authorities, at EU level by the Commission, or both. It would be an advantage to include tyre manufacturers and retailers in the campaigns to reach end-users more effectively. Some Member States have already facilitated awareness campaigns about the tyre label or plan to do so. Experiences and recommendations from these campaigns should be taken into account.

Media scope. The activities could be carried out through several different media such as television, posters in the public space, internet banners, social media campaigns, etc. They could be undertaken either at national and/or EU level and include stakeholders such as Member States, consumer organisations, manufacturers and retailers.

Awareness campaigns could include a reference to the fuel savings calculator on the Commission’s website 59 that allows end-users to calculate their potential fuel savings from tyres. In addition, the Commission could support activities with regard to cooperation and exchange of best practices, including recommending common key messages.

53% of respondents to the OPC thought that awareness raising campaigns by Member States or business would be useful to increase consumer knowledge of the tyre labelling scheme.

2.Joint enforcement actions

The aim of joint enforcement action is to foster cooperation as well as exchange of information and experiences between MSAs to extend and improve market surveillance and enforcement of the tyre labelling in the EU. This measure is intended to alleviate the problems mentioned by MSAs that the test costs are high that there are too few test facilities.

The activities envisaged under this measure would be the following: 60

Enhance EU level cooperation – share plans and results between MSAs, and adapt results among individual countries;

ADCO group 61 – encourage MSAs to participate in the ADCO for labelling of tyres. The group discuss market surveillance issues for tyres with the aim to ensure efficient, comprehensive and consistent market surveillance;

ICSMS 62 – encourage MSAs to publish results of market surveillance activities in the ICSMS database on a regularly basis (the database includes very few data on tyres);

Pan-European project to increase the level of market surveillance and investigate enforcement challenges for tyres (for instance uncertainties of test results);

An increased role of the European Commission in market surveillance including supporting the options mentioned above.

An example of a joint surveillance action is the Market Surveillance Action for Tyres 2015 (MSTyr15) 63 project. The main objective of the project is to help deliver the intended economic and environment benefits of labelling C1 tyres. This will be achieved by improving the effectiveness of market surveillance authorities through capacity-building, training and the development and use of good practice guidelines. Future projects could include more MSAs, and the extension of inspections and testing to C2 and C3 tyres.

3.Mandate to revise/develop testing methods (e.g. for abrasion)

Based on statements from MSAs and industry representatives, the review study found that the test methods for the current label parameters contain a number of uncertainties, especially for the wet grip test. Furthermore, the test method for rolling resistance is based on laboratory measurement rather than real-life driving. Moreover, test methods for parameters not currently on the label are missing, for example for mileage and abrasion. To improve the effectiveness of the TLR it is suggested to upgrade the test methods to be more reliable, accurate and reproducible. In addition, the test methods should preferably be closer to “real world” use of tyres. The latter would be a prerequisite for developing test methods related to e.g. mileage and abrasion.

The benefits of such new test methods are to obtain more reliable test results, and the possibility of including new performance parameters on the label. The drawbacks are that real-life testing might increase test costs compared to laboratory tests.

Against this background, the Commission will prepare a standardisation request to initiate development and revision of the relevant standards.

Option 3 - Targeted legislative measures (see above 5.2.3.)

4.Online labelling

This measure includes an obligation on manufacturers and retailers to show the label when tyres are offered for sale online. A similar obligation has been implemented for energy-related products covered by an implementing measure under the Energy Labelling Framework Regulation.

This measure is becoming more and more important because tyre purchases on the internet are increasing. It is expected that online tyre retail will grow to around 24% of total sales in Europe by 2023 64 . In addition, an increasingly large share of consumers uses the internet in advance to inform their choice before buying a product in a retail outlet. This development is only expected to increase or even accelerate along with mobile internet device market penetration.

Online labelling for tyres could follow the key principles set out in Regulation (EU) 518/2014 regarding labelling of energy-related products on the internet. This regulation requires that:

-The label corresponding to the advertised product must be clearly displayed in proximity to the price of the product, or;

-If the energy label is not shown, the energy class must be displayed 65 , and should itself be a link to the corresponding energy label.

The design of the arrow and whether the arrow should indicate the fuel efficiency class alone or both the fuel efficiency class and the wet grip class should be investigated further.

34% of OPC respondents thought the tyre label should be shown when tyres are sold online. 56% of those replying to the consumer survey for the review study said that they expected to buy tyres on the internet in the future.

5.Mandatory labelling of tyres delivered with vehicles at all times

This measure is an extension of the current requirement to provide the label information when tyres are sold with new vehicles (OEM tyres).

Results of the review study show that only 31% of the buyers of new vehicles were offered a choice between different tyre, and only 18% were given the required information. This means a contrario that about 82% is not informed about the performance of the tyres on their new car.

76% of OPC respondents though the label should be provided with all tyre sales.

6.Require the label to be provided for C3 tyres

This measure is an extension of the current requirement to provide the label as such to end-users of C3 tyres. The 2008 Impact Assessment for the TLR 66 discussed whether the fuel efficiency, rolling resistance and noise parameters should apply to C3 tyres. It was argued by some stakeholders that there was no need for rolling resistance labelling of C3 tyres because they are sold to professionals who already have all the information necessary for their purchasing decision and therefore a labelling scheme would not bring any added value. This was objected to by road transport companies themselves, including their European federation, the International Road Transport Union. Furthermore, experience with other product groups (such as professional refrigeration and lighting) has shown that the comparative value and green-to-red scale of the label also have a positive impact in a B-to-B setting.

Although C3 tyres account for only 5% of tyre sales in the EU, they consume more fuel and cover more kilometres annually than C1 tyres so the potential for fuel savings in absolute term will be higher in this market (estimated already in the 2008 IA as EUR 800 savings per year; equivalent to EUR 870 in 2017).

In 2008, the conclusion regarding the labelling scheme for C3 tyres was to make the grading available only in catalogues, websites and advertising tools as this market is addressed to professionals and it was considered sufficient to make the information available for end-users without further communication tools. In the context of this impact assessment it is appropriate to revisit that conclusion.

7.Require the label to be provided to end-users in case of purchase through leasing contracts or as part of a fleet solution

In leasing and fleet solutions, end-users driving the vehicle and/or paying for the fuel are usually not responsible for purchasing the tyres, but rather lease the vehicles including a pre-defined set of tyres. In order for end-users to know the impacts of using tyres with different performance levels, the lessor should be responsible for providing the lessee with the relevant tyre label information and the label itself in the same way that a tyre retailer is responsible for providing the information.

8.Mandatory inclusion of snow performance on the label

In the tyre labelling scheme, the wet grip index is used as a measure for safety. However, this risks misleading end-users purchasing tyres for winter conditions in two ways. First, they may believe that a tyre with very good wet grip will have a good grip on snow, which is not necessarily the case due to the varying conditions such as temperature and surface roughness, which make the tyres perform differently on each type of road surface. Second, and conversely, tyres designed to perform better on snow and ice often have a poorer wet grip than standard summer tyres 67 .

The inclusion of snow and ice performance in the labelling scheme would address a safety concern and would provide more complete information to end-users, which could ultimately lead to increased label confidence, especially in Nordic regions.

This measure concerns inclusion of an icon on the label showing that the tyre has suitable performance in severe snow conditions. The proposed icon is the 3-PMSF (3 Peak Mountain Snow Flake) logo or 'Alpine symbol', which is applicable for all tyre types (C1, C2 and C3). The threshold performance that is required of the tyre in order to use the 3-PMSF logo is defined in UNECE Regulation 117 68 , implemented in the EU through the GSR 69 .

Figure 2: The 3-PMSF logo 

Source: UNECE Regulation 117

There is a general agreement among stakeholders that were consulted for the review study, including C1 end-users, industry and consumer organisations, that good snow and ice grip performance should be indicated by pictograms on the tyre label to increase road safety and help end-users choose the best tyre. 59% of those questioned in the consumer survey for the review study said that it was very important to include information on snow and ice performance.

Using pictograms ensures language neutrality of the label similar to labels implemented under the Energy Labelling Framework Regulation.

9.Mandatory inclusion of ice performance on the label

This measure is very much in line with the measure on snow performance, but concerns the inclusion of a logo showing that the tyre has suitable performance on ice. Tyres with a good performance on ice are also referred to as “Nordic winter tyres”. These tyres often have the lowest wet grip values on the label as ice grip and wet grip are negatively correlated, and end-users consulting the wet grip scale for assessing the tyre safety will therefore be misled by this information.

Ice performance should be implemented in the same way as the snow performance, by adding a logo on the label if the tyre lives up to a certain performance (brake or handling) on ice. An ISO standard is under development and it is expected that the standard will be ready between end of 2018 and beginning of 2019.

The expected ISO standard, in combination with a threshold value and a corresponding pictogram, seems to be a useful solution. If a redesign of the label is decided, a consumer survey should be considered to assess the effect of having both the snow and the ice logo on the label, as opposed to allowing tyre manufactures to only show one of them.

43% of respondents to the OPC thought that it should be mandatory to show information ice and/or snow performance on the tyre label, while 27% thought this should be included, but that it should be voluntary.

10.Re-adjustment of the label classes

This measure concerns re-adjusting the label to deal with the outdated performance classes while maintaining the label’s potential to drive the market towards better performing tyres. The current label is no longer accurate because of the GSR banning bottom classes and the fact that for wet grip, the label has an empty class in the middle of the A-G range.

This measure does not involve a full “rescaling” of the label as envisaged under the Energy Labelling Framework Regulation for products where the top class was overpopulated and A+, A++ and A+++ classes were added. It would be similar to the situation where a more stringent tier of requirements is introduced after a certain date in current product specific energy labelling regulations. When this happens, manufacturers have to accompany the product with the new label. There is no requirement to change the labels on products that were placed on the market prior to the change, and they are eventually all sold in the normal way.

The re-adjustment is an aspect of “future proofing” the label and would take into account the speed of the technological progress. The re-adjusted label could leave the top class empty to encourage innovation and technological progress, provide for regulatory stability and limit the need for future of re-adjustment.

In the review study, it was concluded that the level of technological development compared to the label classes, and the rate at which tyres with both an A-class for rolling resistance and wet grip are developed, does not justify a full rescaling of the label. However, the label is no longer accurate because of the GSR banning bottom classes and the fact that for wet grip, the current label has an empty class in the middle of the A-G range, and this would justify a re-adjustment of the classes.

For the current assessment, newest data was obtained from the German tyre database TOL 70 and supplemented by extrapolated sales weighted data from GfK for 5 Member States 71 . The updated data show the same results as the 2016 Review Study: the market share of tyres rated “A” in both RRC (rolling resistance coefficient) and wet grip is still less than 1% and the main constraint is the RRC. This result fits with the statement from the tyre industry that the focus is on developing tyres with better wet grip while maintaining or improving RRC when possible, as the two parameters are to some extent negatively correlated. It is also in line with the consumer survey where C1 end-users showed a higher focus on safety.

However, the new data shows that for the wet grip of C1 tyres, the top class is already populated at the level of 26% of the tyres made available on the market. For the three classes on external noise, the bottom class has been banned and the top class is already populated at the level of 18%. Also, for the noise there are only 2 classes, which may be too little to drive the market towards better performing tyres.

The three possible options for re-adjustment are the following:

1.Bespoke 4 classes scale so that empty classes are no longer shown;

2.Keep the current scale(s) but have some classes empty (greyed-out) to reflect regulatory requirements which mean that there are no tyres in those classes;

3.Redefine the boundaries between the current A-G classes to make them more accurate.

11.Tyre registration database

This measure concerns the establishment of a digital registration database for tyres on the EU market and a requirement for manufacturers to enter information in the database that is intended to provide relevant information to end-users, retailers, manufacturers and MSAs, and will also be a useful tool for retailers when providing the tyre label information to end-users.

This measure assumes the tyre label database could become part of the product database that will be set up according to the Energy Labelling Framework Regulation. That database will consist of a public (open) part and a compliance part (for MSAs), which will be accessible via an online portal. Including tyres in the database would possibly require a legislative amendment to the Energy Labelling Framework Regulation.

The responsibility of the tyre manufacturer would be to register all new types and enter pre-defined information in the database before placing the tyre on the market. The information would include details about the manufacturer and the product, for instance manufacturers name and trademark, model identifier, performance classes and other parameters on the label, the label in electronic format and the technical documentation.

As tyre manufacturers are already obliged to assemble all the required documents and information (including providing the label) and make the technical documentation available to MSAs on request, the additional costs for uploading this information in a database would be limited. The additional costs could be offset by the fact that manufacturers do not need to handle requests from the authorities because they would have easy access to the information in the database.

The burden for MSAs to obtain the documentation would be reduced. As the Commission is already obliged to set up the database for energy-related products, the extra costs for inclusion of tyres would be marginal. In the Impact Assessment accompanying the Energy Labelling Framework Regulation it is estimated that this option could increase compliance by 6% and thus reduce losses from non-compliance by 3%.

70% of OPC respondents supported a registration database and 30% of those questioned in the consumer study specifically mentioned this as an element that would improve their confidence in the tyre labelling scheme.

12.Technical documentation and product information sheet

This measure concerns inclusion of (i) a new annex in the TLR detailing the content of the new technical documentation that tyre manufacturers must make available to MSAs and (ii) an annex detailing the content of the product information sheet with relevant information for end-users.

Under the current TLR, technical documentation must be sufficiently detailed to allow authorities to verify the accuracy of information provided on the label with regard to fuel efficiency, wet grip and external rolling noise 72 . This measure would extend this requirement by including specific parameters and the order in which they should appear in the technical documentation. Furthermore, the product information sheet would mirror the current Annex III “Information provided in technical promotional material”.

This will make it easier for manufacturers to ensure that they provide sufficient documentation and for market surveillance authorities to evaluate the received documentation.

13.Amendment of the current Annex V on test method for wet grip of C1 tyres

In the current TLR, the wet grip index for C1 tyres must be measured according to several ASTM standards. It is proposed to change the wet grip measurement method in the TLR to ISO 23671:2015 Passenger car tyres – Method for measuring relative wet grip performance 73 (or the newest version of this standard 74 ).

This standard specifies the method for measuring relative wet grip braking performance, indexed to a reference under loaded conditions for new passenger cars tyres on a wet-paved surface. The use of a reference tyre is necessary to limit the variability of the testing procedures. The ISO standard to some extent builds upon the ATSM standards mentioned in the current TLR. The ISO standard is considered the recognised state of art measurement method for tyre wet grip performance.

14.Amendment of current Annex IVa on laboratory alignment procedure for the measurement of RRC

In 2010, an 'Expert Group on laboratory alignment for the measurement of tyre rolling resistance' was set up 75 . The main activities of the group are dedicated to the creation of an alignment method for laboratories having to measure tyre rolling resistance in accordance with the TLR. In 2013/2014 and 2016/2017, the Expert Group assessed, in cooperation with a Network of Reference Laboratories 76 , the stability and validity of the assigned values 77 of the reference laboratories.

The experience gained during the inter-laboratory comparison tests led the Expert Group to suggest some amendments to the Laboratory alignment procedure for the measurement of rolling resistance in Annex IVa of the TLR 78 . The amendments focus on clarifying several definitions and the general provisions of Annex IVa, and correcting the formula to calculate allowed standard deviation of the measured rolling resistance.

15.Extension of the type approval process to include the label declaration

Under the GSR the manufacturer must test tyre types either in-house or in a third party laboratory. A national type approval authority then endorses the resulting test values. Currently, the values for rolling resistance, wet grip and noise that manufacturers declare on the tyre label are based on the results of those tests. However, the declaration of those values on the label (i.e. the translation of those values into the classes of the label) is not subject to any verification and is done by manufacturers themselves (self-declaration).

This measure would require the tyre manufacturer to subject the label declaration to the type approval process. Consequently, this would add an additional guarantee of the correctness of the label.

16.Mandatory and independent third-party testing

This measure would require product testing to be done by independent third-party laboratories, over and above the testing that takes place under the GSR. The current GSR requires manufacturers to test their tyres, but they are allowed to carry out the testing in in-house facilities.

Third party testing will result in extra costs for manufacturers and manufacturers who are placing products on the European market, estimated to be as follows per tyre type placed on the market:

Table 4: Overview of testing costs per tyre type

Tyre type

Test cost

C1

3,500-4,000 Euro

C2

4,000-4,500 Euro

C3

5,000-6,000 Euro

Source: ETRMA

Industry does not support introducing additional independent third party testing of tyre performance. They argue that third party testing would be disproportionate to the available infrastructure of testing institutes/type approval authorities’ laboratories and create unacceptable delays and costs for the tyre industry. Instead, they propose that market surveillance and enforcement should be increased and more coordinated.

Third party testing is however supported by other stakeholders such as environmental organisations and testing labs.

17.Inclusion of studded tyres in the scope of the TLR

This measure concerns inclusion of studded tyres 79 in the scope of the TLR to make information about the tyre performance parameters available to end-users for this specific type of tyre. Studded tyres are a subgroup of Nordic winter tyres developed for sub-zero temperatures and ice and wet ice conditions. Only 'studdable' tyres supplied without studs are currently covered by the TLR. Studded tyres are also exempted from the GSR.

18.Inclusion of retreaded tyres in the scope of the TLR

This measure concerns the extension of the scope of the TLR to include retreaded tyres.

Tyre re-treading is a process used to extend the life of used tyres. When a tyre is re-treaded, the worn-out tread is replaced with a new one, which can be repeated as long as the casing integrity is guaranteed. Re-treading is particularly relevant for C3 tyres, which make up about 30% of the market share of re-treaded C3 tyres in Europe, corresponding to around 5 million tyres 80 , 81 . However, a decreasing trend has been seen in the C3 retreaded market from 2013-2015 due to increasing imports in the EU of low cost C3 tyres. The market share of re-treaded C1 and C2 tyres is below 2% in Europe.

19.Mandatory inclusion of mileage as a performance parameter

This measure concerns adding mileage as a new tyre performance parameter on the label. Mileage is an important parameter for end-users and various stakeholders such as environmental and consumer organisations requested adding it to the label, as shown in the annexed OPC report.

Mileage is an indication of the usable life of a tyre, based in particular on the number of kilometres that the tyre can be expected to be driven for, before it reaches the legally defined minimum tread depth.

27% of OPC respondents were in favour of including mileage as a parameter on the label, but only if the accuracy of the measurement could be ensured.

20.Mandatory inclusion of abrasion as a performance parameter

This measure concerns the inclusion of abrasion as a new performance parameter on the tyre label.

Abrasion is the removal of materials from the tyre when it interacts with the road surface. Tyre wear particles are generated from the friction between the tyre and the road. According to the tyre industry, these particles might therefore be an agglomeration of approximately equal mass fractions of material from the tyre and the road 82 . The abrasion rate is intrinsically linked to the durability and life expectancy of tyres. 

Particles are released to the environment as particles of different sizes and in different amounts. Smaller particles contribute to particulate air pollution and larger particles deposit on the road and run-off into streams and accumulate in the oceans. These particles are often referred to as microplastics. The Commission’s recently published EU Strategy for Plastics in the Circular Economy 83 presents key commitments for action at EU level and recognises the significant contribution of tyre wear to the accumulation of microplastics in aquatic environments. Furthermore, the Commission acknowledges the need for more research to improve understanding of the sources and impacts of microplastics 84 .

21% of OPC respondents were in favour of including mileage as a parameter on the label in all circumstances, with 20% in favour only if the accuracy of the measurement could be ensured. 41% thought concerns about abrasion should be covered in other forms of regulation.

5.3.Options/measures discarded at an early stage

Inclusion of studded tyres

The market share of studded tyres is very small in all but the two Nordic Member States (Sweden and Finland) as well as Norway, and the potential fuel saving is therefore very limited. One reason for the low market share is that use of studded tyres is actually prohibited in many Member States. In addition, testing of rolling resistance and wet grip for studded tyres is not possible with the current test standards. In both the RRC and the wet grip tests there is a limited allowed ‘roughness’ of the surface (machine drums or road ), and the use of studs on these surfaces during the test will damage them to such an extent that the surfaces no longer comply with the test standards. Hence, with the current test standards, including studded tyres is not possible.

Based on all of the above reasons, including studded tyres in the TLR is discarded.

Inclusion of re-treaded tyres

The performance of re-treaded tyres is determined by the combination of casing, tread, and applied re-treading process 85 . The major challenge of including retreaded tyres in the labelling scheme is the necessity to establish the three label performance parameters (fuel efficiency, wet grip and external rolling noise) for each combination of casing, tread and retreading process. Since re-treaded tyres are produced in small series, the cost of testing each combination would make the re-treading business economically unfeasible, especially for SMEs 86 .

As already mentioned, the TLR does not require C3 tyres to have a label. According to the industry organisation for tyre retreaders 87 , the major barrier for including re-treaded tyres in the TLR is the vast diversity of possible product combinations and small number of similar re-treaded tyres.

Based on all of the above reasons, including retreaded tyres in the TLR is discarded.

Inclusion of mileage as a performance parameter

Inclusion of mileage in the label seems to be useful for end-users and could be an important factor for tyre purchases. It is also a durability parameter that fits adequately with the objectives of the circular economy strategy. However, its inclusion on the label coupled with the inclusion of further parameters such as abrasion and snow/ice performance should be assessed cautiously to avoid overburdening the label with too much information for the end-user, thereby reducing its effectiveness. In this context, the relation with the dry grip of tyres also has be taken into account.

More importantly, inclusion of mileage is currently not feasible as there is no reliable, accurate and reproducible standardised test method for identifying the number of kilometres achievable by tyres. Such a method would have to be developed by the standardisation bodies to provide end-users with comparable information. It should also be considered that measuring mileage using a standardised test method can deviate significantly from the mileage experienced by end-users in real life (as mileage is influenced by other parameters such as weather and road conditions, driving behaviour, etc.). If this happens, it may undermine end-users’ confidence in the label.

Environmental stakeholders are in favour of including mileage on the label as shown in the annexed OPC report. Some even indicated that if the measure is not included based on lack of an appropriate measurement methods, it would be necessary to initiate the standardisation work as soon as possible in order to avoid that this argument will be used also in the future for not taking action.

The industry and MSAs agree that it is not possible to measure mileage with the accuracy required for labelling, and MSAs do not consider it possible to perform market surveillance on such a requirement. Furthermore, the tyre industry, MSAs and tyre testing organisations all agree that introducing mileage as a parameter in the tyre labelling scheme would be very costly and would not help end-users choose better tyres.

However, this issue could be further investigated in a future amendment of the TLR (possibly through delegated acts), also taking into account consumer understanding testing of the future label.

This measure is therefore discarded based on the inability of meeting the criteria for technical feasibility (lack of testing method).

Inclusion of abrasion as a performance parameter

As with mileage, inclusion of abrasion in the label could be useful for end-users and thus an important factor for tyre purchases, contributing to the EU Strategy for Plastics. The inclusion of abrasion is however not feasible for the time being as there is no reliable, accurate and reproducible standardised test method for measuring the abrasion effect of tyres. Such a method would have to be developed by the standardisation bodies to provide end-users with this information.

The opinion of stakeholders regarding this measure is very much in line with their views on mileage, because the two parameters are related. As confirmed in the OPC, industry believes that tyre labelling is not appropriate for this complex question, while NGO’s 88 consider it important that this information is included in the label. Given the likely high price of tyres that are well performing in terms of abrasion, the utility of including information on the release of microplastics on the tyre label needs to be carefully examined. Using the GSR to ban tyres that did not reach an acceptable abrasion level, in addition to labelling, in other words the traditional “push and pull” affect, is a future option that needs to be considered.

Due to the lack of a reliable and reproducible testing method, this measure is not technically feasible at this stage. However, given the importance of abrasion for the environment and for the durability of tyres, once such a test become available in the future, it should be made possible to adapt the label parameters under the TLR using a delegated act. To facilitate this process, the Commission could give a mandate to CEN/CENELEC to develop such a methodology.

Mandatory and independent third-party testing

For the purpose of this impact assessment, this measure is discarded for several reasons. Firstly, European product legislation (e.g. on safety or energy efficiency) is overwhelmingly based on some form of self-declaration by manufacturers and importers of the compliance of their products with the applicable requirements. This is supported by the CE marking and is based on the so-called New Legislative Framework that was introduced in 2008 89 (as an update of the New Approach to technical harmonisation that started in 1973). Resort to independent third party testing or type examination is limited to specific cases where the co-legislators have considered that the risk and consequences of non-compliance are particularly high, for example in the case of certain personal protective equipment or gas appliances. Non-compliance with the tyre labelling requirements, which could of course result in loss of energy and monetary savings, does not fall into this category.

Secondly, in the context of the revision of the Energy Labelling legislation, which was finalised in August 2017 with the adoption of a new Regulation, the co-legislators considered that self-declaration was still the appropriate conformity assessment procedure for demonstrating compliance with product-specific energy labelling requirements (e.g. for washing machines, vacuum cleaners and refrigerators). Although there has been a strong call for more, and more effective, market surveillance to check compliance, this is addressed by the extension of the type approval process to the label declaration and the product registration database.

Thirdly, the tyre labelling regulation is closely linked to the GSR, which imposes a type approval process on tyre manufacturers for key tyre parameters, but does not require mandatory third party testing. Imposing this only for the purpose of tyre labelling would mean diverging from this process and adding additional costs for manufacturers.

Fourthly, there is a risk that the lack of independent test laboratories 90 will constitute a barrier for placing new tyre models, including better performing tyres, on the market. Finally, third party testing is not guaranteed to address the inaccuracy of the information on the label, as this is at least partly driven by difficulties with the test procedures as such and not only by whether the tests are undertaken by a third party. This is also an issue best dealt with under the GSR, as the instrument that sets the general testing requirements.



Table 5: Options that were discarded at an early stage and options that were modelled

Discarded options

Inclusion of studded tyres

Inclusion of re-treaded tyres

Inclusion of mileage as a performance parameter

Inclusion of abrasion as a performance parameter

Mandatory and independent third-party testing

Modelled options

PO2: Non-regulatory measures

PO3:Targeted legislative actions

PO3B: As policy option 3, but without the effect of re-adjustment the label classes

PO3C: As policy option 3, but without the effect of the extension of the type approval procedure to the declaration of the label values

PO3D: As policy option 3, but without the effect of online labelling

PO3E: As policy option 3, but without the effect of the tyre registration database

PO3F: As policy option 3, but without the effect of further OEM requirement

PO4: Policy option 2 + option 3. Non-legislative measures and targeted legislative actions are all applied

PO4B: as policy option 4, but without the effect of re-adjustment the label classes

PO4C: As policy option 4, but without the extension of the type approval procedure to the declaration of the label values

PO4D: As policy option 4, but without the effect of online labelling

PO4E: As policy option 4, but without the effect of the tyre registration database

PO4F: As policy option 3, but without the effect of further OEM requirement

6.What are the impacts of the policy options? 

The impacts were modelled following the methods set out in detail in Annex 4. The key assumptions underlying the modelling were:

·General assumptions: market data and prices for C1 (replacement tyres and OEM), C2 and C3 tyres; average number of kilometres that are driven each year; average lifespan of tyres; etc.

·Scenario assumptions: sales data; distribution of tyre models in the different label classes over time; effects of non-compliance; etc. (For instance, non-compliance is assumed to decrease in option 2 and even more in option 3 to 7%, compared to 15% in BAU scenario).

·Behavioural assumptions: impact of information campaigns and readjustment of the classes on end-users’ buying behaviour; impact of improved market surveillance on compliance rate; impact of including snow and ice indicators on the label on number and severity of accidents; etc. (For instance, awareness of the label is assumed to increase from 41% to 60% due to information campaigns).

Given that there is significant uncertainty in particular as regards the behavioural assumptions, the impact assessment includes an extensive sensitivity analysis in section 8.2.

6.1.Environmental impacts

6.1.1.Fuel consumption

The rolling resistance of the tyres affects the energy consumption of a vehicle, and the differences in fuel consumption shown in the figure below are due to different rolling resistance in each policy scenario (the BAU values are provided for comparison). As seen in the figure below, policy option 4 (PO4) has the lowest annual energy consumption followed by policy option 3 (PO3).

Both scenarios give slightly higher consumption without re-adjustment of the label (PO3B and PO4B), but significantly higher consumption without the extension of the type approval procedure to the declaration of the label values (PO3C and PO4C). This can also be seen from the cumulative energy savings from 2017 to 2030, which are shown for each policy option in the table below, and the part of the saving resulting from each specific measure, where 36-39% of total savings results from the extension of the type approval procedure to the declaration of the label values. These two specific sub-options are shown in the graph below, while all sub-options are shown in the table under the graph.

Figure 3: Total fuel consumption for main scenarios expressed in PJ per annum 91 .

Source: Modelling by Viegand Maagøe – see methodology Annex 4

Table 6: Cumulative fuel savings in PJ achieved by 2030 in each policy scenario (compared to BAU) 

Specific measure

PO2

PO3

PO4

Annual savings in 2030

14 PJ/year

123 PJ/year

129PJ/year

Cumulative savings (2017-2030)

179 PJ

1348 PJ

1440 PJ

Savings distributions on each specific measure in the options

Information campaigns

48 PJ (27%)

not applicable

40 (3%)

Concerted market surveillance

130 PJ (73%)

*109 (8%)

Extension of type approval procedure

not applicable

526 (39%)

514 (36%)

Re-adjustment of label (with new A)

86 (6%)

87 (6%)

Online labelling

91 (7%)

85 (6%)

Digital registration database

*197 (15%)

*184 (13%)

Inclusion of OEM tyres

427 (32%)

400 (28%)

Technical doc. and data sheet

*21 (2%)

*20 (1%)

*The effect of these measures on compliance rate diminishes when extension of type approval procedure testing is applied

Source: Modelling by Viegand Maagøe (see methodology Annex 4)

As seen in the previous table, the fuel savings are to a large extent driven by the decrease in non-compliance induced by the extension of type approval procedure testing (36-39% of savings) and by the mandatory labelling of OEM tyres at all times (28-32% of savings). It should be noted that including the extension of type approval procedure testing leads to a reduction in non-compliance, which is also driven by the digital registration database, the technical documentation content definition and concerted market surveillance decreases. Hence, the effects of these other measures will be greater than shown in the figure above if the extension of type approval procedure testing is not implemented.

It is important to note that the effect of label re-adjustment relies on the assumption that it is technically possible to improve both the rolling resistance and the wet grip parameters to the new class A (see annex 6). Re-adjusting the label with four classes (A-D) is assumed to cause a saving somewhere between the re-adjusted label (adding a new class) and not changing the label classes, i.e. somewhere between 0-6%. This is because in this case the class A threshold is not moved, but end-users might perceive the difference between A and D on the label as more significant, because classes below D are not shown.

The impact of information requirements on end-users’ purchase behaviour has been investigated, and it is found that the awareness of the label and the importance of each label parameter to the end-user determines how large a share of end-users would buy higher rated tyres. For the rolling resistance parameter, 34% of end-users find it “very important” according to the 2016 consumer survey, but only a fraction of them is expected to actually purchase a more fuel-efficient tyre based on more/better information (See methodology Annex 4).

6.1.2.CO2 emission mitigation

CO2 emissions are directly linked to vehicle fuel consumption, and the savings follow the same pattern as the fuel savings, hence the scenarios have the same relative savings. The absolute values are given in the table below.

Table 7: CO2 emission savings from each policy option in Mt CO2-eq.

The distributions between specific measures in % are the same as fuel savings shown in the previous table.

Policy option:

PO2

PO3

PO4

Annual CO2-eq savings in 2030

1.1 Mt/year

9.1 Mt/year

9.5 Mt/year

Cumulative CO2-eq savings (2017-2030)

13 Mt

99 Mt

106 Mt

Source: Calculation modelled by Viegand Maagøe (See methodology Annex 4)

In addition to CO2, other emissions result from the exhaust of vehicles. These include NOx gasses, exhaust particles, CO, SO2, etc. 92 . These pollutants will decrease with the fuel savings and CO2 emissions in all scenarios.

Policy option 4 is estimated to deliver 129PJ of final energy by 2030, which is around 0.8% of the savings needed to reach the EU’s target of 30% energy efficiency by 2030. It is also estimated to save around 10 Mt CO2 equivalent, which would contribute 1% towards the EU’s target of 40% GHG emissions reduction by 2030.

6.1.3.Noise pollution

It is not possible to quantify exactly the direct health effect of tyre external rolling noise levels. However, it is well-established that noise influences human health and causes both premature deaths and hospitalisations due to cerebrovascular diseases and coronary heart disease 93 , especially related to noise above 55 dB.

The average noise levels for each scenario are given in the table below, noting that the lower the values, the less serious the negative health effect. Since external rolling noise is generally considered less important than other factors by end-users, the effect of the label information is limited.

Table 8: Noise levels in 2030 for each tyre type (C1, C2 and C3) in each policy option

2030 noise levels

C1 tyres

C2 tyres

C3 tyres

Policy Option

Replacement

OEM

Replacement

OEM

Replacement

OEM

BAU

70.5

71.2

72.1

72.5

71.5

72.0

PO2

70.3

71.2

71.9

72.5

71.3

72.0

PO3

70.2

70.2

71.7

71.7

71.7

71.1

PO4

70.1

70.1

71.7

71.7

71.0

71.0

Source: Calculations by Viegand Maagøe (See Methodology Annex 4)

6.2.Social impacts

6.2.1.Road safety

One of the largest social impacts related to tyres is safety, which is determined by the wet grip of the tyre. The wet grip is related to braking length and thus to impact and speed in accidents, which affects the severity of injuries. Reduced impact speeds also lead to less severe accidents, or even to avoided accidents, when the grip allows coming to a full stop before impact.

The following Table   gives an overview of how safety, in terms of severity in accidents, is affected in each policy scenario. Note that only accidents on wet road (9% of total accidents) and accidents on snowy (1%) and icy (1%) road are considered here, since the policy options include safety parameters only for wet grip, snow grip and ice grip. It should be noted that there is a generally positive correlation between grip on wet road and grip on dry road, even though it is not directly quantifiable. This means that the effect of increasing wet grip will also have a positive effect on safety on dry road, leading to an even higher number of avoided fatalities and injuries than shown in the table below.

Table 9: Severity of accidents in each policy option, measured by number of fatalities, severe injuries and minor injuries caused by traffic accidents on wet, snowy and icy roads.

BAU

PO2

PO3

PO4

Annual occurrence 2030 (in numbers)

Fatalities

1 390

1 387

1 332

1 331

Severe injuries

14 138

14 016

11 556

11 540

Minor injuries

134 583

134 720

136 400

136 465

Cumulative number,

2017-2030

Fatalities

Not applicable

53

790

818

Severe injuries

1 534

27 593

28 489

Minor injuries

-1 729

-20 612

-21 472

Source: Calculations by Viegand Maagøe (see methodology Annex 4)

As seen from the above Table , the number of fatalities and severe injuries decrease with the increase in safety parameters (wet grip, snow grip and ice grip) in the three policy scenarios compared to BAU. PO4 shows the largest improvement, but with very similar results in PO3, of 4% fewer fatalities and 19% fewer severe injuries per year in 2030.

If the same improvement is assumed for dry road safety, it would correspond to 543 less fatalities per year in 2030 (where total fatalities are assumed to have fallen to 12,640 in the BAU scenario) and 24,160 less severe injuries (out of the total 128,500 in the BAU scenario in 2030).

At the same time, however, the number of minor injuries increases in the policy scenarios, and most in PO4 and PO3. This is because the wet grip affects the severity of accidents, and thus the accidents that would have inflicted e.g. a severe injury in BAU, cause only minor injuries in the policy options. However, the number of avoided fatalities and severe injuries are higher than the increase in minor injuries, because some accidents no longer cause personal injuries at all, due to increased grip of the tyres.

6.2.2.Noise health effects

Noise is an important social impact factor of tyres due to related health issues. Road traffic noise at levels over 55 dB Lden 94 affects an estimated 100-125 million European citizens based on noise mapping, with the actual number most likely being higher due to incomplete reporting 95 , 96 . For sleep disturbance, an indicator of 50 dB Lnight is recommended 97 .

Table 10: Health effects of environmental noise from road traffic

Implication

Annoyance

Sleep disturbance

Hospitalisations

Deaths

Reading impairment

Affected people

20 million

8 million

43 000

10 000

8 000

Source: https://www.eea.europa.eu/signals/signals-2016/articles/transport-and-public-health

Due to the large variations in reported numbers, it is not possible to quantify exactly the correlation between tyre external rolling noise and noise exposure in the different policy options. The World Health organisation (WHO) and the European Environmental Agency (EEA) assessed the health effects of the environmental noise form road traffic in the unit Disability Adjusted Life Years (DALY) per year. The latest data from this assessment (from 2011) is used here.

Table 11: WHO health effects of environmental noise form road traffic in DALY/year

Implication

Cardio vascular

Annoyance

Sleep disturbance

Tinnitus

Cognitive impairment in children

Total

DALY/year

140 890

378 590

354 134

4 577

14 316

873 981

Source: Excel sheet provided by DG Environment, based on data form World Health Organisation (WHO) from 2011

Using the model, the decrease in health impacts in the table below can be calculated for an average decrease in noise exposure by 1 dB. This saving can be monetarised by using the Value of One Life Year (VOLY) Noise Directive, namely €110 987. This calculation is shown here as an example of impacts that can be obtained by decreasing road noise levels. The impacts cannot be calculated for each policy scenario because the improvement in average noise levels is overall too small (less than 1 dB).

Table 12: Health and monetary impacts of decreased noise exposure

Implication

Cardio vascular

Annoyance

Sleep disturbance

Tinnitus

Cognitive impairment in children

Total

Decrease, DALY/year

19 154

37 655

37 621

364

1 320

94 471

Decrease, %

14%

10%

11%

8%

9%

11%

Savings/year, billion euro

2.13

4.18

4.18

0.04

0.15

10.49

6.3.Economic impacts

6.3.1.Societal costs

Traffic accidents and noise pollution result in high societal costs. However, it has only been possible to quantify the accident-related costs impacts of the policy scenarios 98 . The total monetary savings are related to the number of accidents leading to fatalities, severe injuries and minor injuries respectively (see section 6.1).

The accident related cost savings in EUR million are shown in the table below as annual costs in 2030 and cumulative costs savings from 2017 to 2030. Policy scenarios 3 and 4 give rise to the highest savings (i.e. largest decrease in severe accidents). Not including re-adjustment or extension of type approval procedure testing would each result in approximately EUR 160 million less savings in 2030.

Table 13: Health costs of fatalities, severe and minor injuries in traffic.

BAU

PO2

PO3

PO4

Annual costs EUR 2030 million

Fatalities

2 354

2 348

2 255

2 254

Severe injuries

3 565

3 534

2 914

2 910

Minor injuries

2 622

2 625

2 657

2 659

Total

8 541

8 507

7 826

7 822

Cumulative cost savings 2017-2030, EUR million

Fatalities

Not applicable

89

1 330

1 378

Severe injuries

386

6 948

7 173

Minor injuries

-34

-401

-418

Total

442

7 876

8 133

Source: Calculations by Viegand Maagøe (see Methodology Annex 4)

6.3.2.Financial savings for end-users

The economic impact for end-users primarily consists of the tyre purchase price and the fuel cost savings in the use-phase. The rolling resistance directly affects the fuel cost, whereas the combined performance of the three label parameters affects the tyre purchase price. Hence, the fuel savings caused by decreasing rolling resistance have to counterbalance the increase in purchase price caused by the total performance improvement. As seen in the table below, the economic benefit for vehicle owners is low, with PO3 and PO4 giving the highest end-user savings of below 1%. Calculations are based on average market values for rolling resistance and prices. The Total Cost of Ownership (TCO) is calculated as the purchase price for a full set of tyres and the fuel cost over the average tyre lifetime. The fuel cost savings have not been discounted.

Table 14: End-user Total Cost of Ownership (TCO), for C1, C2 and C3 users, at individual end-user level and on EU level. Based on tyre mileage and number of tyre fitted on each vehicle

Tyre type

BAU

PO2

PO3

PO4

End-user level, EUR

TCO

TCO

Saving

TCO

Saving

TCO

Saving

C1

5 164

5 155

9 (0.2%)

5 136

28 (0.5%)

5 129

35 (0.7%)

C2

12 473

12 467

6 (0.0%)

12 409

64 (0.5%)

12 400

73 (0.6%)

C3

88 454

88 342

112 (0.1%)

87 933

521 (0.6%)

87 780

673 (0.8%)

EU level, billion EUR

C1

1 742

1 739

3 (0.2%)

1 733

9 (0.5%)

1 730

12 (0.7%)

C2

512

512

0 (0.0%)

509

3 (0.5%)

509

3 (0.6%)

C3

666

665

1 (0.1%)

662

4 (0.6%)

661

5 (0.8%)

Total

2 920

2 916

4 (0.1%)

2 904

16 (0.5%)

2 900

20 (0.7%)

Source: Calculations by Viegand Maagøe (See methodology Annex 4)

6.3.3.Turnover and Employment

The business turnover is calculated for a simplified supply chain consisting of three actors: manufacturers, wholesalers and retailers. The turnover and employment are based directly on tyre sales and prices, and are without inflation or discounting. The estimated "mark-up factors" shown in the table below are used to scale between the three supply chain links, and the "revenues per employee" are used to estimate employment. More details on calculations are provided in Annex 4.

Table 15: Estimated mark-up factors and turnover per employee used in calculations

Market

Turnover/employee EUR

Mark-up factors

Retail

25 511

2

Wholesale

59 241

1.25

Manufacturer

63 929

1

Source: http://www.eurocommerce.eu/retail-and-wholesale-in-europe/facts-and-figures.aspx

As seen in the two tables below, both turnover and employment are expected to increase towards 2030 due to an increase in sales (2.1% per year for entire market) and in performance (see tyre unit prices in Annex 4). The difference between the scenarios is thus based entirely on tyre price increases due to increased performance, and PO3 and PO4 provide the largest performance increase and thus the largest turnover and employment benefit compared to BAU. See Annex 4 for the graphs of the turnover and employment development from 2017 to 2030.

Table 16: Estimated turnover and cumulative increase by 2030 for manufacturers, wholesalers and retailers in the tyre sector

Sector

BAU

PO2

PO3

PO4

2030 levels, million Euro

Retail

52 656

52 619

57 107

56 900

Wholesale

32 910

32 887

35 692

35 562

Manufacture

26 328

26 310

28 553

28 450

Total

111 893

111 816

121 352

120 912

Cumulative

increase, 2017-2030, million euro

Retail

Not applicable

2 786

44 606

46 803

Wholesale

1 742

27 879

29 252

Manufacture

1 393

22 303

23 401

Total

5 921

94 787

99 456

Source: Calculations by Viegand Maagøe (see methodology Annex 4)

Table 17: Estimated employment and cumulative increase by 2030 for manufacturers, wholesalers and retailers in the tyre business (in full-time equivalents)

Sector

BAU

PO2

PO3

PO4

2030 levels, employees

Retail

2 064 037

2 062 603

2 238 519

2 230 405

Wholesale

555 524

555 138

602 484

600 301

Manufacture

411 830

411 544

446 644

438 395

Total

3 031 391

3 029 285

3 287 647

3 269 101

Increase in employees between 2017-2030,

Retail

Not applicable

109 227

1 748 487

1 834 608

Wholesale

29 398

470 595

493 774

Manufacture

21 794

348 870

366 053

Total

160 419

2 567 953

2 694 435

Source: Calculations by Viegand Maagøe (see methodology Annex 4)

6.4.Other impacts

6.4.1.Impact on competitiveness

Overall, any measure improving end-users' understanding of the tyre label and manufacturers’ compliance with the labelling requirements, will improve competitiveness in the tyre market, since the tyre label would increasingly be a decision parameter for end-users in a purchase situation. The higher the understanding of, and confidence in, the label, the more end-users are likely to use the information given on the label to decide which tyre to buy. This means that tyre manufacturers can use the tyre label parameters to a higher degree to benchmark and differentiate their products.

This increase in competitiveness is likely to be the highest with the re-adjustment option that sets a new threshold for class A, since no or only very few tyres have yet achieved rolling resistance and wet grip within class A. The combination of new class A in both wet grip and rolling resistance would be difficult to reach and would likely cause competition among manufacturers, as was the case in 2012 when the label was first implemented 99 . This would also support EU tyre manufacturers, which tend to produce higher quality tyres, to compete in the market.

6.4.2.Impact on innovation

Although very few tyres are currently rated in fuel efficiency class A, there is a lot of research and development (R&D) effort in tyre manufacturing 100 to achieve high performance in both wet grip and rolling resistance at the same time, as these two parameters counteract each other. This innovation effort is expected to increase as more end-users become aware of the tyre label and increased market surveillance results in a more level playing field, in which manufacturers are awarded for producing better performing tyres. Readjusting the label classes will most likely increase the innovation effort as well.

As noted in the 2016 Review Study, innovation is most likely to focus on rubber mixtures and additives that allow the development of tyre treads with properties promoting both good wet grip and fuel efficiency.

6.4.3.Impact on SMEs

On the manufacturer side, the EU market is primarily comprised of large global tyre companies, represented by ETRMA with 12 companies in total. ETRMA members account for 72% of the European C1 and C2 tyre markets and 70% of the C3 tyre market (2016) 101 . No SME tyre manufacturer was identified in the EU. Tyre imports from non-EU countries cover the remaining market share of roughly 30 % 102 .

By contrast, SMEs dominate the tyre retreading industry with a market share of 35-40% of truck and bus tyres (C3). As described in section 5.3.1.2, the inclusion of retreaded tyres in the labelling scheme has been discarded mainly because the current testing methods would make the retreading business economically unfeasible, especially for SMEs. The proposed policy options are therefore not considered to have significant impacts on these businesses.

SMEs active in retailing/importing of tyres could face additional costs by the proposed changes, specifically related to the obligation on manufacturers and retailers to show the label when tyres are offered for sale online. These costs relate mainly to the obligation to ensure that the information is provided in a legible, comprehensible and comparable fashion, independently of the end-user’s Internet access device; this may create web design costs. Providing the information to end-users once the design stage is completed bears no additional cost. Furthermore, this proposal does not change the coverage of the TLR in terms of products or create obligations to produce new information. Therefore, it is not expected to give rise to significant implementation costs.

Finally, SMEs using tyres in their activities will benefit from reduced costs over the lifetime of the tyres and increased safety for their employees.

7.How do the options compare?

7.1.Summary of impacts and options comparison

As seen from the results presented in the two tables below, PO4 results in the greatest overall benefits, closely followed by PO3. PO2 gives only minor benefits in comparison, and in terms of turnover (and employment), it actually causes a decrease. This is because the development in BAU outpaces the overall improvement in tyre performance by 2030 in PO2, thus causing a lower tyre price and a lower turnover in the industry (see consumer prices in Annex 4). In cumulative savings, PO2 does provide only minor improvements.

However, when combined with the legislative amendments in PO3, the information campaigns and increased market surveillance efforts pay off, as seen from the difference in benefits between policy options 3 and 4 (option 4 being the combination of options 2 and 3). In other words, the information campaigns and concerted enforcement actions in addition to legislative improvements will have a greater effect than information requirements without further legislative changes. This conclusion is supported by experience with energy labelling of household appliances, where the combination of legislative requirements with improved market surveillance and information efforts towards consumers has been effective. 103

By their very nature, the non-regulatory measures of option 2 contribute to a lesser extent to the general and specific objectives than the targeted legislative actions of option 3. Nevertheless, as argued above, legislative and non-legislative measures mutually reinforce another and work best in combination (option 4).

Table 18: Summary of policy option impacts, changes in annual values by 2030 compared to BAU

2030

Energy savings

GHG

End-user expenditure

Extra turnover

Compliance costs

Road safety

Societal health costs

Fuel savings

CO2-eq reduction

Purchase cost saving

Energy cost savings

Net cost savings

Manu-facture

Whole-sale

Retail

Manufacturers

Retail

Member states

Commission

Fatalities

Severe injuries

Minor injuries

Fatalities

Severe injuries

Minor injuries

Policy Option

PJ

Mt

mln. €

mln. €

mln. €

mln. €

mln. €

mln. €

mln. €

mln. €

mln. €

mln. €

Nr.

Nr.

Nr.

mln. €

mln. €

mln. €

PO2

14

1.1

37

812

849

-18

-23

-37

0

0

0.02

0.5-1

3

122

-137

6

31

-3

PO3

123

9.1

-4 451

6 632

2 181

2 226

2 782

4 451

127

50

0.02

0.5-1

58

2 582

-1 818

99

651

-35

PO3B

109

8.0

-3 615

5 899

2 284

1 808

2 260

3 615

127

50

0.02

0.5-1

47

2 035

-1 505

79

513

-29

PO3C

84

6.2

-3 397

4 522

1 125

1 698

2 123

3 397

126

50

0.02

0.5-1

47

2 081

-1 492

80

525

-29

PO3D

114

8.4

-4 415

6 143

1 728

2 208

2 759

4 415

127

50

0.02

0.5-1

57

2 548

-1 790

97

643

-35

PO3E

101

7.4

-4 018

5 445

1 427

2 009

2 511

4 018

127

50

0.02

0.5-1

56

2 499

-1 750

95

630

-34

PO3F

93

6.8

-1 808

5 030

3 222

904

1 130

1 808

127

0

0.02

0.5-1

37

1 487

-1 480

63

375

-29

PO4

129

9.5

-4 244

7 012

2 768

2 122

2 653

4 244

127

50

0.02

0.5-1

59

2 598

-1 882

100

655

-37

PO4B

120

8.9

-3 237

6 560

3 323

1 619

2 023

3 237

127

50

0.02

0.5-1

44

1 932

-1 429

75

487

-28

PO4C

90

6.6

-3 531

4 902

1 371

1 766

2 207

3 531

126

50

0.02

0.5-1

48

2 097

-1 551

81

529

-30

PO4D

123

9.0

-4 252

6 687

2 435

2 126

2 657

4 252

127

50

0.02

0.5-1

59

2 577

-1 868

99

650

-36

PO4E

114

8.4

-4 193

6 221

2 028

2 096

2 620

4 193

127

50

0.02

0.5-1

58

2 545

-1 848

98

642

-36

PO4F

94

6.9

-1 720

5 174

3 454

860

1 075

1 720

127

0

0.02

0.5-1

39

1 517

-1 528

65

382

-30

Source: calculations by Viegand Maagøe (see methodology Annex 4). Further details about administrative costs appear in Annex 3.

Table19: qualitative evaluation of the policy options. PO3B and PO4B exclude re-adjustment and PO3C and PO4C excluding the extension of type approval procedure

Option

Energy savings

GHG

End-user expenditure

Extra turnover

Compliance costs

Road safety

Societal health costs

Total

Nr of "+"

PO2

(+)

(+)

+

-

+++

+

+

6

PO3

++(+)

++(+)

++

+++

++

+++

+++

18

PO3B

++(+)

++(+)

++

++

++

++

++

15

PO3C

++

++

+

++

++

++

++

13

PO3D

++(+)

++(+)

+(+)

+++

++

+++

+++

17.5

PO3E

++(+)

++(+)

+

++(+)

++

+++

+++

16.5

PO3F

++

++

+++

+

++

+(+)

+(+)

13

PO4

+++

+++

++(+)

+++

++

+++

+++

19.5

PO4B

++(+)

++(+)

+++

++

++

++

++

16

PO4C

++

++

+

++

++

++

++

13

PO4D

++(+)

++(+)

++

+++

++

+++

+++

18

PO4E

++(+)

++(+)

++

++

++

+++

+++

17

PO4F

++

++

+++

+

++

+(+)

+(+)

13

Source: Based on calculations by Viegand Maagøe (see methodology Annex 4)

Option 4 adds the non-regulatory measures of option 2 to the legislative actions identified in option 3. Given that the legislative actions result in significantly more savings than the non-regulatory ones, option 4 does not deliver much more savings compared to option 3. Nevertheless, as outlined in section 7.1, second paragraph, the non-regulatory and legislative actions mutually reinforce each other. For example, joint surveillance action by Member States will be more effective once the registration database is in place, which would give them central access to all compliance information. In addition, in option 4 the Member States play an important role and this can have an additional beneficial effect in terms of increasing their commitment to the tyre labelling scheme.

From the overall ranking, PO4 (combination of policy options 2 and 3) comes out best overall. PO3 alone gives almost the same improvements as PO4.

8.Preferred option

8.1.Description of the preferred policy option

Based on the analyses presented in the previous chapters, the preferred option is PO4, which combines the specific measures from PO2 and PO3. This option includes the following measures:

Table 20: Specific measure included in the preferred option

POLICY OPTION

SPECIFIC MEASURES

PO 4 – Combination of PO 2 and PO 3: Non-regulatory actions and Targeted amendments to the TLR

1.Information campaigns

2.Joint enforcement actions

3.Mandate to revise/develop relevant testing methods (e.g. abrasion)

4.Online labelling

5.Mandatory labelling of tyres delivered with vehicles at all times

6.Require label to be provided for C3 tyres

7.Require label to be provided to end-users in case of purchase through leasing contracts or as part of a fleet solution

8.Mandatory inclusion of snow performance on the label

9.Mandatory inclusion of ice performance on label

10.Re-adjustment of the label classes

11.Tyre registration database

12.Technical documentation and product fiche content

13.Amendment of current Annex V on test method for wet grip of C1 tyres

14.Amendment of current Annex IVa on laboratory alignment procedure for the measurement of Rolling Resistance Coefficient (RRC)

15.Extension of the type approval process to include label declaration

The preferred option is estimated to result in the following administrative costs.



Table 21: Overview of administrative costs (all costs are direct costs) compared to baseline.

II. Overview of costs (million EUR) – Preferred option

Options

Manufacturers

Retailers

Member States

EU/Commission

Information campaigns

10

(only once)

2

(only once)

Joint enforcement actions

0.02 per year

0,5-1 per year

Online labelling

3

(only once)

Labelling of tyres delivered with vehicles

50 per year 104

Provision of label for C3 tyres

6 per year 105

Mandatory inclusion of snow and ice performance

Re-adjustment of the label classes

40

(only once) 106

30

(only once)

Tyre registration database

0.25 per year

0.1(only once) and 0.01 per year

Content of technical documentation and product fiche

120 per year 107

Amendment of measurement methods in Annex IVa and V

Extension of type approval procedure

0.65 per year

Total

127 per year

40 only once

50 per year

30 only once

0.02 per year

13 (only once)

0,5-1 (per year)

2,1 (only once)

Source: Based on calculations by Viegand Maagøe

8.2.Sensitivity assessment of the preferred option

Although 75% of those questioned in the consumer survey said that their confidence in the label would influence their purchasing decisions, there is no quantitative evidence of the effect of the label on consumer behaviour. Quantitative data on compliance rates was also difficult to obtain. Therefore, a sensitivity analysis is presented below to assess the impact of the lack of data.

8.2.1.Compliance rate

In the modelling of the preferred option, the compliance rate is expected to increase, which in turn is expected to cause decreases in fuel consumption, traffic accident severity and noise levels. In particular, the specific options of extension of the type approval accredited testing, joint enforcement actions, the tyre registration database and definition of the technical documentation and product information sheet content are expected to increase compliance rates.

In the BAU scenario a non-compliance rate of 15% is assumed, with non-compliant tyres expected to be on average two classes below their label value. In the preferred option, the non-compliance rate is assumed to decrease to 7% with non-compliant tyres on average being one class lower than the label value. This change is due to the collective effect of all of the above-mentioned specific options. In all scenarios it is assumed that the rate of non-compliance is the same for all three label parameters.

Since the non-compliance rate is based largely on assumptions for both the BAU 108 scenario and the preferred option, and the compliance rate has a large effect on the impact, a sensitivity assessment was conducted to address this uncertainty.

In the preferred option the non-compliance rate was varied between 0% (ideal scenario) and 15% (BAU) for all three label parameters with average non-compliance magnitudes of one and two classes.

For the total energy consumption, the correlation with the compliance rate is:

·2.6 PJ/year in 2030 per %-point change for 1 class non-compliance;

·5.2 PJ/year in 2030 per %-point change for 2 classes of non-compliance.

For the safety cost, the correlation with the compliance rate is:

·9.1 million euro/year in 2030 per %-point change for 1 class non-compliance. The maximum difference (from 0% to 15% non-compliance) was 11 fatalities and 500 severe accidents;

·18.6 million euro/year in 2030 per %-point change for 2 classes non-compliance. The maximum difference (from 0% to 15% non-compliance) was 22 fatalities and 1000 severe accidents.

For noise, the correlation cannot be made by noise class (number of “soundwaves” on the label), since the class depends on tyre size and type. Instead, the sensitivity analysis was based on dB values and the correlation to compliance rate is:

·0.01 dB in average value per %-point change for in non-compliance.

If only half of the expected improvement in the non-compliance rate would be achieved, compared to the preferred option, the result would be:

·24.5 PJ less fuel savings in 2030, corresponding to 19% less than the total savings in the preferred option (129 PJ/year in 2030);

·88 million euro less in health cost savings in 2030, corresponding to 12% of the total savings in the preferred option (718 million euro in 2030);

·0.05 dB higher noise levels on average, corresponding to around 10% of average values for all tyre types. The resulting values, however, depend highly on tyre size and type.

8.2.2.Consumer behaviour

In the modelling of the preferred option, consumers are assumed to react to the label information by purchasing better performing tyres. Specifically, the options related to online labelling, information campaigns and the product registration database are expected to increase label awareness 109 . The impact of the policy option is based on the number of end users purchasing better tyres, which is determined from a combination of the following parameters:

·Potential increase in awareness from awareness raising campaigns (59%) 110

·Number of end users purchasing tyres online (21%) 111

·Number of end users consulting the product database for information (51%) 112

Furthermore, the share of respondents in the 2016 consumer survey who rated each parameter as “very important” is assumed to be affected by the label on that specific parameter:

·Rolling resistance (efficiency): 34%

·Wet grip (safety): 62%

·Noise: 21%

The combination of the above parameters was used to determine the share of end users affected by increased information provision for each parameter. The affected share in the preferred option (Policy option 4) for each parameter is:

·9% of end users would buy a tyre with better rolling resistance performance

·17% of end users would buy a tyre with better wet grip performance

·6% of end users would buy a tyre with better noise performance

Since the underlying assumptions for the effect of increased information is based on a single questionnaire and end users might react differently in real life or refrain from purchasing better performing tyres due to increased prices, a sensitivity assessment was made for the information effect for each parameter. In this sensitivity analysis, the affected share of end users was varied for each parameter and plotted against the impact.

The resulting correlation shows that the total impact of the preferred option is not very sensitive to consumer behaviour compared to the compliance rate.

·For fuel efficiency, the correlation was 2.5 PJ/year per %-point of users choosing differently. This means that if, for example, only half as many end users as assumed in the preferred option were to buy more fuel efficient tyres, the annual savings in 2030 would be 17 PJ less, corresponding to 12% of the total fuel savings from the preferred option in 2030.

·For safety (measured as societal health costs), the correlation is 1.42 million euro/year per %-point of end users choosing differently. If only as many end users as assumed in the preferred option were to buy tyres with better wet grip, annual societal health cost savings in 2030 would be 19 million EUR less, corresponding to 3% of the health cost savings from the preferred option in 2030.

·For noise levels (dB measured values) the correlation for C1 tyres is 0.047 dB per %-point of end users affected by the noise information. If only half of the users assumed in the preferred option buy less noisy tyres, the difference in 2030 would be 0.24 dB on average, corresponding to a dB decrease of 0.34% less than the average noise in the preferred option. The percentage effect will be the same for C2 and C3 tyres.

8.3.REFIT (simplification and improved efficiency)

Identified possibilities for simplification of legislation and reduction of regulatory costs are:

Product registration database

Establishment and use of a product registration data, where manufacturers are obliged to upload product information including energy labels and technical documentation (including test reports), would make it easier and less costly for MSAs to access the required documentation. In addition, retailers will have easy access to download labels and product information sheets including electronic versions for labelling of tyres in web shops. Furthermore, a product registration database could also save time for manufacturers because they do not have to spend time to handle inquiries from market surveillance authorities about delivery of technical documentation, etc. On the other hand, manufacturers will face some extra costs for uploading the necessary information into the database.

The Commission is establishing a product registration database for energy-related products as required by the new Energy Labelling Framework Regulation. It is anticipated that tyres could be included in this database and the additional cost for extension of the database is considered marginal.

Alignment with General Safety Regulation

Both the TLR and the GSR require that tyres are tested according to UN-ECE 113 test standards. However, while the GSR requires an approval by a third party public authority before the product can be placed on the market, there is no such requirement in the TLR, according to which manufacturers makes a self-declaration. In both cases, manufacturers are allowed to do the testing in their own test facilities. In addition, under GSR a Technical Service can also do the test. To simplify the legislation and at the same time increase the compliance rates for tyres it is proposed to further align the TLR with the GSR with regard to certification procedures. Use of third party approval is more burdensome for manufacturers than self-certification but the manufacturers are already required to have their tyres approved under the GSR, even if a more thorough (and more expensive) testing is required to establish the label performance parameters. Therefore, the alignment could somewhat increase the manufacturers’ costs for testing at an approved testing laboratory, but in return the tyres will only have to be tested once.

The use of pre-market approval for establishment of the tyre performance parameters on the label could reduce the need for testing by market surveillance authorities and thereby reduce Member States’ enforcement costs, because the test results on which the label information is based would be more reliable.

Tyre Labelling Regulation/delegated acts

Currently, Article 11 of the TLR provides that implementing acts are to be used to introduce information requirements on wet grip for C2 and C3 tyres if suitable testing methods are available, adapt parameters for snow/ice tyres and to adapt the annexes to technical progress. It is proposed that TLR should be adapted to the TFEU and that the use of delegated acts in accordance with Article 290 should be specified. The use of such delegated acts could also allow amendments to the label itself, in certain circumstances, where appropriate based on insights/evidence from consumer behavioural testing (for example, if and when suitable testing methods for abrasion become available). This creates a certain parallel with the regulatory framework set up for energy-related products under the framework Energy Labelling Regulation. This would simplify the regulatory process when changes are required to achieve additional environmental improvements or to add parameters to the label.

The change of the regulatory process will save resources in the European regulatory process (in the Commission, the European Parliament and the Council) and at Member State level.

Table 22: Qualitative description of cost savings in the preferred option

REFIT Cost Savings – Preferred Option(s)

Description

Amount

Comments

Product registration database

80 000 EUR/year 114

Recurrent cost savings for Member State market surveillance authorities.. Eventually also cost savings for manufacturers.

Initial marginal costs for the Commission to extend the database for energy-related products to cover also tyres.

Alignment with General Safety Regulation

420 000 EUR/year 115

Could require more expensive tests for manufacturers in approved testing laboratories but in return, they will not have to carry out further testing. Reduced market surveillance costs (recurrent savings).

Tyre Labelling Regulation / delegated acts.

110 000 EUR per delegated act 116

Will reduce the administrative costs in the EU law-making Institutions and in Member States.

9.How will actual impacts be monitored and evaluated?

The impact of the new TLR will be evaluated and monitored in a review study to be carried out 5-10 years after the entry into force of the new Regulation. In the review process, the impact of the TLR will be compared with the objectives of the Regulation as set out in the present Impact Assessment.

That review would include market analysis, which will allow the monitoring of the specific objective of having a well-known and well shown tyre label i.e. shown at all times when tyres are sold.

A consumer awareness study would also be part of the review, to assess how awareness of the label, and its impact on purchasing decisions, has improved. To align with general consumer awareness of energy labelling, the specific objective of having a well-known tyre label should be measured against the goal of 85% of consumers being aware of the label (which is the percentage of the Union’s population who recognise the energy label on appliances).

The main monitoring element to verify compliance with the GSR and TLR requirements will be the tests carried out by national market surveillance authorities. This will check whether the new requirements have been complied with by suppliers. This monitoring is particularly relevant to the specific objective of having an adequately enforced tyre label. Reporting by Member States to the Expert Group on Tyres Labelling – Market Surveillance Administrative Cooperation 117 will provide data regarding market surveillance activities and compliance rates. Further data will also come from the ongoing MSTyre15 joint surveillance action and any follow-up projects.

The proposed mandatory product registration database will also be a source of more solid data to monitor and evaluate progress towards meeting the objectives of the TLR and will provide data on the distribution of tyre models across the different performance classes. It will also support market surveillance, which is essential for enforcement of the TLR. Enforcement would also be aided by requiring Member States to inform the Commission of the penalties and enforcement mechanisms applicable to infringements of the TLR.

(1)

     Regulation (EC) No 1222/2009 of the European Parliament and of the Council of 25 November 2009 on the labelling of tyres with respect to fuel efficiency and other essential parameters, OJ L 342 of 22.12.2009, p.46

(2)

     This target is currently under examination in the ordinary legislative procedure: there is no sign that final agreement will be on a level of ambition lower than that proposed by the Commission.

(3)

     COM(2016) 501 final

(4)

   Impact Assessment accompanying the Proposal for a Directive amending Directive 1999/62/EC on the charging of heavy goods vehicles for the use of certain infrastructures, COM(2017) 276 final, https://ec.europa.eu/transparency/regdoc/rep/1/2017/EN/COM-2017-276-F1-EN-MAIN-PART-1.PDF

(5)

     Numbers are for highway driving, https://www.fueleconomy.gov/feg/atv.shtml . City driving results in 3-5% rolling resistance loss.

(6)

     COM(2018) 28 final

(7)

     Conference of European Directors of Roads - pavements noise-reducing pavements Technical Report 2017-01

(8)

     Regulation (EC) No 661/2009 of the European Parliament and of the Council of 13 July 2009 concerning type-approval requirements for the general safety of motor vehicles, their trailers and systems, components and separate technical units intended therefor, OJ L 200 of 31.7.2009, p.1

(9)

     OJ L 218, 13.8.2008, p. 30–47. See Commission proposal COM(2017)795 for a Regulation laying down rules and procedures for compliance with and enforcement of Union harmonisation legislation on products which will replace Regulation 765/2008.

(10)

   OJ L 198, 28.7.2017, p. 1–23

(11)

     The Tyre Labelling Regulation was amended twice before it entered into application, first because industry had developed a more a new testing method for the wet grip of C1 tyres, and then to reflect the fact that a suitable international harmonised testing method of grip on wet roads had been developed also for C2 and C3 tyres: Commission Regulation (EU) No 228/2011 of 7 March 2011 amending Regulation (EC) No 1222/2009 of the European Parliament and of the Council with regard to the wet grip testing method for C1 tyres and Commission Regulation (EU) No 1235/2011 of 29 November 2011 amending Regulation (EC) No 1222/2009 of the European Parliament and of the Council with regard to the wet grip grading of tyres, the measurement of rolling resistance and the verification procedure

(12)

     C1, C2, C3 tyres are legal terms defined in the Regulation (EC) No 661/2009 of the European Parliament and of the Council of 13 July 2009 concerning type-approval requirements for the general safety of motor vehicles, their trailers and systems, components and separate technical units intended therefor (OJ L 200, 31.7.2009, p. 1). They refer to tyres designed primarily for passenger cars, light commercial vehicles and heavy-duty vehicles

(13)

     Regulation (EC) No 443/2009

(14)

     Regulation (EU) No 510/2011

(15)

     https://ec.europa.eu/clima/policies/transport/vehicles/labelling_en

(16)

See https://ec.europa.eu/energy/sites/ener/files/documents/Study%20in%20support%20of%20the%
20Review%20of%20the%20Tyre%20Labelling%20Regulation_final.pdf

(17)

     Sweden, Finland, UK, Germany, France and Italy

(18)

     COM (2017) 658 final

(19)

     See the evaluation section in Annex 5

(20)

     Review study, including the results of the consumer survey covering six Member States and 6051 respondents.

(21)

     Review study (interviews with MSAs)

(22)

     Review study (consumer survey), OPC results in Annex 2

(23)

     According to GfK, 10-15% of tyres are sold online. The consumer survey undertaken in 2016 found that 12% of C1 tyre end users had bought them on the Internet, with 56% planning to do so in the future

(24)

     OEM tyres: Original Equipment Manufacturer tyres or tyres sold with new vehicles

(25)

     Braungardt et al. (2014), “Impact of Ecodesign and Energy/Tyre Labelling on R&D and Technology Innovation”, Link: http://www.ecofys.com/files/files/fraunhofer-ecofys-2014-impact-of-ecodesign-energy-labelling-on-innovation.pdf

(26)

     BE, BG, DE, EE, ES, FI, HR, IE, LT, LU, LV, PL, RO, SE, TU. For more information, see http://www.mstyr15.eu/index.php/en/

(27)

   SWD(2015) 143 final

(28)

   Ecofys, Evaluation of the Energy Labelling Directive and specific aspects of the Ecodesign Directive, June 2014

(29)

     The review study identified that among the MSAs of Belgium, Finland, Germany (3 Regions), Estonia, Malta, Netherlands, Sweden, United Kingdom, Hungary, Poland and Slovakia, only Germany and Belgium performed laboratory tests to verify the label values

(30)

     Sweden and German Regional MSAs

(31)

   See Review study

(32)

     The market share of these tyres at EU level is at the level of 30% of the annual C1 tyres sales for snow tyres and around 1% for ice tyres according to the review study.

(33)

     See Review study. Tyre retreading is a process used to extend the life of used tyres, in particular for C3 tyres. The market share of retreaded C3 tyres is around 30-40 % in Europe, which corresponds to around 5 million tyres.

(34)

     See Review study. Studded tyres are used primarily in the Finland, Sweden and Norway, where their average market share is 25 % of the C1 tyre market, and more than 50 % of car owners in Sweden and Finland have studded tyres for their car. At EU level, the estimated market share is around 0.25% of the annual sales according to the review study.

(35)

     Based on interviews undertaken during the review study

(36)

     “Manufacturers” also includes importers and authorised representatives.

(37)

     Review study, page 13

(38)

     See tyres labelling calculator: https://ec.europa.eu/energy/en/topics/energy-efficiency/energy-efficient-products/tyres  

(39)

     COM(2018) 28 final, http://ec.europa.eu/environment/circular-economy/pdf/plastics-strategy.pdf

(40)

     Source: Eunomia, http://www.eumicroplastics.com/

(41)

     Based on calculation models developed by consultants from Viegand Maagøe

(42)

      https://ec.europa.eu/energy/en/topics/energy-strategy-and-energy-union/2030-energy-strategy  

(43)

     COM/2015/080 final. Communication From The Commission To The European Parliament, The Council, The European Economic And Social Committee, The Committee Of The Regions And The European Investment Bank - A Framework Strategy for a Resilient Energy Union with a Forward-Looking Climate Change Policy

(44)

     See the evaluation of the existing Tyre Label Regulation in Annex 5.

(45)

     COM(2017) 279 final

(46)

     COM(2007) 99)

(47)

     SEC (2011) 469 final)

(48)

     COM(2018) 183/3

(49)

     OJ L011, 15/01/2002, p.4

(50)

     Council conclusions on road safety, 2 December 2010, paragraph 21, ST 16951/10

(51)

      https://www.eu2017.mt/en/Documents/Valletta_Declaration_on_Improving_Road_Safety.pdf  

(52)

      http://ec.europa.eu/environment/action-programme/  

(53)

      http://www.euro.who.int/en/health-topics/environment-and-health/noise/activities/development-of-who-environmental-noise-guidelines-for-the-european-region  

(54)

    https://ec.europa.eu/info/sites/info/files/file_import/better-regulation-toolbox-17_en_0.pdf  

(55)

      https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2017-3509962_en  

(56)

      http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009L0125&locale=en  

(57)

      http://eur-lex.europa.eu/eli/reg/2017/1369/oj  

(58)

     As opposed to BAU0, which refers to the baseline without any regulation in place, i..e before the current regulation.

(59)

     Tyres Labelling Calculator : Savings are based on the energy efficiency performance of the tyre and on the number of kilometres that the set of tyres can run.

(60)

     Recommendations partly taken from the “Evaluation of the Energy Labelling Directive and specific aspects of the Ecodesign Directive (http://www.energylabelevaluation.eu/eu/home/welcome)

(61)

     Administrative Cooperation Groups. Informal groups of market surveillance authorities with the aim to facilitate European cooperation

(62)

     ICSMS: the internet-supported Information and Communication System for the pan-European Market Surveillance. For more information, see https://webgate.ec.europa.eu/icsms/

(63)

     http://www.mstyr15.eu/index.php/en/

(64)

      https://ww2.frost.com/frost-perspectives/e-retailing-tires-projected-gain-strength-na-and-eu-tire-aftermarket/  

(65)

     See for example: https://europa.eu/youreurope/business/_static/images/uploads/nestedarrow.jpg  

(66)

     http://eur-lex.europa.eu/legal-content/EN/HIS/?uri=CELEX:32009R1222&qid=1520493804540

(67)

     'Summer tyre' does not correspond to a legal definition of a specific product. It refers to a normal tyre to be used preferably under non-severe wintry weather conditions. For information, there are 'all-season tyres', which also does not correspond to any legal definition and which are tyres that can be used both under summer and winter conditions according to manufacturer declaration. They are generally marked 'M+S' but do not necessarily respond to an approved 3-PMSF (3 Peak Mountain Snow Flake) certification as the legally defined 'severe snow tyre'. All these different terms of tyres ('summer' and 'all-season') correspond to manufacturer declaration, not based on further requirements or tyre performance tests.

(68)

.    Addendum 116: Regulation No. 117, ” Uniform provisions concerning the approval of tyres with regard to rolling sound emissions and/or to adhesion on wet surfaces and/or to rolling resistance”, United Nations, February 2014.

(69)

     See the pictogram in OJ L 307, 23.11.2011, p. 3.

(70)

Tyres online and Energy GmbH, database extractions from year 2012-2015, Hämmerling Group, Germany. Dataset covering 2012-2015 with 30,000 tyres total.

(71)

     Germany, United Kingdom, France, Italy and Spain

(72)

     Article 4 point 4 of the TLR.

(73)

      https://www.iso.org/standard/65530.html , https://www.iso.org/obp/ui/#iso:std:iso:23671:ed-2:v1:en

(74)

     The standard is reviewed every 5 years. A new process started in 2017.

(75)

     Members are tyre manufacturers, independent test laboratories and observes. See: https://ec.europa.eu/energy/sites/ener/files/documents/report_from_egla_expert_group_2017.pdf

(76)

     Publication of reference laboratories for the purpose of the alignment procedure concerning the measurement of rolling resistance of tyres for the implementation of regulation No http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2012.086.01.0003.01.ENG&toc=OJ:C:2012:086:TOC

(77)

     Assigned value’ means a theoretical value of one alignment tyre as measured by a theoretical laboratory, which is representative of the network of reference laboratories that is used for the alignment procedure.

(78)

     Report from the Expert Group on Laboratory alignment for the measurement of tyre rolling resistance under Regulation (EC) No 1222/2009

(79)

     Studded tyres have metal studs embedded within the tread in order to increase the traction of the tyre, in particular on ice.

(80)

     European Tyre and Rubber Manufacturers’ Association, ETRMA (2011), “Re-treading” Website last updated 2011. Link: http://www.etrma.org/tyres/retreading  

(81)

     Ruud Spuijbroek, Secretary at Bipaver (2015), personal communication on email September 16th 2015.

(82)

     http://www.etrma.org/uploads/Modules/Documentsmanager/20171003_etrma_trwp-position-paper.pdf

(83)

     http://ec.europa.eu/environment/circular-economy/pdf/plastics-strategy.pdf

(84)

     http://ec.europa.eu/environment/circular-economy/pdf/plastics-strategy.pdf

(85)

   Boustani, A. (2007), “Remanufacturing and Energy Savings” B.S. University of California Berkely, Massachusetts Institute of Technology. Link: http://web.mit.edu/ebm/www/Publications/reman-est.pdf  

(86)

     Retyre (2014), Main website. Link: http://www.retyre-project.eu/  

(87)

     BIPAVER

(88)

     See the OPC report in Annex 2

(89)

     https://ec.europa.eu/growth/single-market/goods/new-legislative-framework_en

(90)

     See Review study, https://ec.europa.eu/energy/sites/ener/files/documents/Study%20in%20support%20of%20the%20Review%20of%20the%20Tyre%20Labelling%20Regulation_final.pdf

(91)

1 Peta Joule per year is equal to 1 000 000 000 000 000 Joule per year (The Joule is a derived unit of energy in the International System of Units. It is equal to the energy transferred to (or work done on) an object when a force of one Newton acts on that object in the direction of its motion through a distance of one metre).

(92)

      https://www.theaa.com/driving-advice/fuels-environment/emissions  

(93)

      http://www.rivm.nl/dsresource?objectid=a4029a59-c241-46c8-b8d1-8f2f537e9ac1&type=org&disposition=inline  

(94)

Lden is the average annual Day, Evening and Night noise level, and 55 dB is the value set in the Environmental Noise Directive for noise mapping and assessments.

(95)

      https://www.eea.europa.eu/highlights/road-traffic-remains-biggest-source  

(96)

      https://www.eea.europa.eu/signals/signals-2016/articles/transport-and-public-health  

(97)

      http://ec.europa.eu/environment/noise/directive_en.htm  

(98)

     Total noise-related fatalities and hospitalisations including related costs are available only for the year 2014, and no correlation was made between tyre rolling noise and these incidents.

(99)

      http://www.transportengineer.org.uk/transport-engineer-news/goodyear-unveils-first-aa-grade-steer-concept-tyre/45469  

(100)

     See Review Study

(101)

     http://www.etrma.org/uploads/20170912%20-%20Statistics%20booklet%202017%20-%20alternative%20rubber%20section%20FINAL%20web1.pdf

(102)

     The majority of these companies are represented through the International Tyre Manufacturers’ Association (ITMA). See https://itma-europe.com/history/

(103)

See Impact Assessment for the Energy Labelling Regulation, section 8

(104)

     Retailers of vehicles

(105)

     Manufacturers of C3 tyres

(106)

     Cost per readjustment; if the label is re-adjusted again after for instance 10 years, cost for readjustment will appear again

(107)

     For provision of product information sheet

(108)

     Non-compliance rates of around 15% were reported but it was not specified for which parameter and how many classes the non-compliance was on average.

(109)

     These specific options are backed up/made possible by simultaneously adapting the measures related to requiring provision of a label for C3 tyres and in case of purchase through leasing contracts or as part of a fleet solution.

(110)

     In the 2016 consumer survey 41% of the respondents stated that they knew about the tyre label before taking the survey. The potential increase in awareness is thus 59%.

(111)

     In the 2016 consumer survey 21% of respondents stated that they would buy tyre online in the future.

(112)

     In the 2016 consumer survey 51% of respondents stated that they would use the online product registration database to search for information before purchasing new tyres.

(113)

     UN-ECE: United Nations – Economic Commission for Europe

(114)

     An estimated 1 working day (7.5 hours) is saved per product because the technical documentation will be easier to obtain. The example further assume that each member state conducts 15 technical documentation checks per year, and the average labour cost is 25.4 Euro. http://ec.europa.eu/eurostat/statistics-explained/index.php/Hourly_labour_costs  

(115)

   For Member States the need to test will decrease, since the testing will now be done by accredited, independent laboratories rather than through self-declaration by manufacturers. The number is based on assumed testing cost of 5000 EUR/test and 3 avoided tests per Member State per year.

(116)

Assumptions: 1 week saved per MS, 28 weeks saved in European Parliament and Council, 12 weeks saved in the Commission, labour costs: 40 EUR/hour.

(117)

http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=2808&Lang=EN


Brussels, 17.5.2018

SWD(2018) 189 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT

Accompanying the document

Proposal for a Regulation of the European Parliament and of the Council

on the labelling of tyres with respect to fuel efficiency and other essential parameters, and repealing Regulation (EC) No 1222/2009

{COM(2018) 296 final}
{SEC(2018) 234 final}
{SWD(2018) 188 final}


ANNEXES OF THE IMPACT ASSESSMENT
ON THE REVIEW OF THE TYRE LABELLING

REGULATION (EC) No 1222/2009/EC

Table of Content

Annex 1: Procedural information3

Annex 2: Stakeholder consultation6

1.Overview of the respondents to the OPC6

2.Overall results8

3.Detailed results9

3.1.Evaluation of existing tyre label9

3.2.Possible Improvements and additions14

4.In extenso comments from all respondents34

Annex 3: Who is affected and how?56

1.Practical implications of the initiative56

2.Summary of costs and benefits57

3.Estimation of administrative costs58

Annex 4: Analytical methods64

1.General assumptions64

2.Information effect65

3.Stock model assumption65

4.BAU Scenario assumptions66

5.Policy Option 2 scenario assumptions70

6.Policy Option 3 Scenario assumptions70

7.Policy Option 4 scenario assumptions72

8.Effect of Rolling resistance on fuel consumption72

9.Effect of Wet grip on safety74

10.Societal costs78

11.Economy and employment78

12.Label re-adjustment81

12.1Wet Grip81

12.2Rolling Resistance / Fuel Efficiency82

12.3Rolling resistance / Wet grip cross distributions84

12.4Noise (dB)85

12.5Noise (Classes)86

13.Proposal to new label intervals87

13.1Scenario 187

13.2Scenario 292



Annex 5: Evaluation96

1.Introduction - Purpose and scope of the evaluation98

2.Background to the intervention99

2.1.Description of the intervention and its objectives99

2.2.Baseline and points of comparison (BAU)102

3.Implementation / state of Play104

4.Method105

4.1.Short description of methodology105

4.2.Interviews and end-user survey107

4.3.Limitations and robustness of findings108

5.Analysis and answers to the evaluation questions108

5.1.Effectiveness108

5.2.Efficiency116

5.3.Relevance123

5.4.Coherence128

5.5.EU added value132

6.Conclusions134

6.1.What is/is not working and why?134

6.2.The Lessons learnt135

6.3.Actual performance compared to expectations135

6.4.Actions to be taken136

Appendix 1: Stakeholder consultation137

Appendix 2: Methods and analytical models179

Annex 6: Results193

1.List of policy options, including modified policy option193

2.End user expenditure193

3.Economy: Business turnover197

4.Safety and safety costs200

5.Energy and GHG emissions204

Annex 7: Glossary206



Annex 1: Procedural information

1. Lead DG, Decide Planning/CWP references:

Lead DG: Directorate-General for Energy (DG ENER).

The initiative is included in the Commission Work Programme 2018 as agenda planning item: 2016/ENER/040

2. Organisation and timing:

The Inter Service Steering Group met three times: 29 January, 21 February and 6 March 2018. The Inter Service Steering Group included representatives of DGs Internal Market, Industry, Entrepreneurship and SMEs (GROW), Mobility and Transport (MOVE), Justice and Consumers (JUST), Environment (ENV), Climate Action (CLIMA), the Joint Research Centre (JRC) and the Secretariat General (SG).

3. Consultation of the RSB: The Regulatory Scrutiny Board (RSB) delivered a positive opinion with reservations on a draft of the Impact Assessment on 23 March 2018 after the meeting on 21 March. The following table gives an overview of its main comments and how they have been addressed in the report.

RSB Opinion 23.03.2018 : Main comments

Where and how the comments have been taken into account

The report does not adequately present the context of the Tyre Labelling Regulation (TLR), e.g. how it works together with the General Safety Regulation (GSR), Energy Labelling Directive and market surveillance frameworks. It does not present the actual and potential contribution of the labelling scheme to the efficiency and safety of tyres, beyond the requirements put in place by the GSR.

An explanation of the Energy Labelling Regulation and the Market Surveillance Regulation, and their relevance, has been added to Section 1.2 on page 4.

The actual contribution of the TLR has been added to the problem definition on page 7.

The presentation of policy options is not sufficiently clear, nor does it appear to cover the full range of policy issues addressed in the proposal.

The table at the beginning of section 5 (page 15) now presents the all the options, and the presentation of the options in section 5.2 (pages 15-26) has been improved. A new Table 4 has been added (page 28) to summarise the options that were discarded at an early stage and options that were modelled.

A more detailed explanation of why Option 4 is the preferred option has been added at page 41 and Table 18 has been made more exact (the mathematical calculations from Table 17 have been translated into half “+” s).

The report calculates impacts using behavioural assumptions that are neither transparently presented nor accompanied by a sensitivity analysis.

A summary of the underlying assumptions of the modelling has been added at the beginning of section 6 (page 29).

A sensitivity analysis on the key behavioural assumptions of consumers has been added to section 8 on the preferred option.

Specific objectives are missing, as are a good representation of stakeholder views on the different policy options.

The specific policy options have been added at the beginning of section 4.2 on page 12. Their monitoring and evaluation has been added to section 9.

A summary of the views of stakeholders by category (industry, Member States and consumers) has been added to Annex 2. Views of stakeholders, from the consumer survey during the review study and the OPC have been added throughout the text where appropriate.

4. Evidence, sources and quality:

The impact assessment draws on an extensive amount of desk research, external studies, targeted consultations, interviews, focus groups, workshops and other

This impact assessment is based on the findings from the Review Study carried out in 2016 1 and the subsequent Open Public Consultation (OPC) 2 , but with market data updated to 2017. The calculations are based on a stock model, determining the number of tyres of each type (C1, C2, C3) in the EU, which is built on annual sales provided by the European Tyre and Rubber Manufacturers Association, ETRMA, combined with ACEA’s (European Automobile Manufacturers Association) annual numbers on vehicles in use in the EU 3 . As part of the 2016 Review Study an extensive stakeholder consultation was performed to assess the efficiency and effectiveness of the label scheme. Stakeholders from across the supply chain were approached to assess their role and whether the TLR was serving its intended purpose. The stakeholder consultation thus included:

·Tyre suppliers;

·Tyre distributors;

·Vehicle suppliers and distributors;

·End users in each tyre segment: C1, C2 and C3.

Interviews and questionnaires were conducted with organisations in each segment, and a more thorough consumer survey was carried out in the largest end-user segment: private car owners of C1 vehicles. The C1 consumer survey included 6,000 respondents, a thousand from each of the following six Member States:

   Germany (~42 million cars)

   England (~29 million cars)

   France (~32 million cars)

   Italy (~37 million cars)

   Sweden (~4.5 million cars)

   Finland (~3 million cars)

External expertise was used where necessary, for example the Expert Group on Laboratory alignment for the measurement of tyre rolling resistance under Regulation (EC) No 1222/2009, the International Organization for Standardization, tyre specialists, the European Tyre & Rubber Manufacturers’ Association, the Platform for cooperation between National Road Authorities as well as other studies.

https://www.iso.org/standard/65530.html ,

https://www.iso.org/obp/ui/#iso:std:iso:23671:ed-2:v1 :

http://www.etrma.org

http://www.retyre-project.eu

http://www.transportengineer.org.uk/transport-engineer-news/goodyear-unveils-first-aa-grade-steer-concept-tyre/45469

http://www.cedr.eu

https://www.ecofys.com/files/files/fraunhofer-ecofys-2014-impact-of-ecodesign-energy-labelling-on-innovation.pdf



Annex 2: Stakeholder consultation

The stakeholder consultation took the form of the publication of the combined Evaluation Roadmap and the Inception Impact Assessment for the review of the tyres labelling Regulation in July 2017 and the Open Public Consultation (OPC) that ran from 10 October 2017 to 8 January 2018. The Review study also included an extensive stakeholder consultation, details are given in Appendix 1 to Annex 5.

A.Combined Evaluation Roadmap and Inception Impact Assessment

The roadmap was published on 12 July 2017 with a feedback period till 9 August 2017. Eight feedbacks were received from the following stakeholders:

·Consumer organisations: ANEC and BEUC (Belgium), Deutsche Umwelthilfe e.V. (Germany),

·Company/business organisations: ExxonMobil Petroleum & Chemical B.V.B.A. (Belgium), ENPA & EMMA (Belgium)

·Business associations: Imported Tyre Manufacturers' Association (United Kingdom), BIPAVER (Netherlands), European Tyre & Rubber Manufacturers Association (Belgium), EurEau European Federation of NAtional Associations of Water Services (Belgium)

Stakeholder comments in extenso are available at http://ec.europa.eu/info/law/better-regulation/initiatives/ares-2017-3509962_en .

B.Open Public Consultation (OPC)

The Open Public Consultation (OPC) was launched on 10 October 2017 and ended on 8 January 2018 ( https://ec.europa.eu/info/consultations/public-consultation-evaluation-and-review-eu-tyres-labelling-scheme_en ).

1.Overview of the respondents to the OPC

70 responses were received. 20 respondents identified themselves as citizens/consumers (one anonymous), 7 identified themselves as representing commercial tyre business, and 44 identified themselves as working for either an interest organisation or local/national authority (one anonymous). In addition, one stakeholder provided only a written statement (The Association of European Radios). See the list of stakeholder respondents in Table 1.

Table 1 Overview of stakeholder respondents

Category

Stakeholder ID

Member State

Tyre suppliers 

1.Apollo Tyres

 International

2.Continental Reifen Deutschland GmbH

 Germany

3.ExxonMobil Petroleum & Chemical BVBA

 International

4.Goodyear Dunlop Tires B.V.

 Netherlands

5.Michelin Nordic AB

 Sweden

6.Nokian Tyres Plc

 International

Retailer

7.BOVAG

Netherlands

Market surveillance authority

8.Swedish Energy Agency in cooperation with other agencies

Sweden

9.Swedish Transport Agency

Sweden

Member State government

10.Federal Ministry of Environment

Belgium

11.Ministry of Infrastructure and Water Management

Netherlands

Member State regional or local government authority

12.City of Helsinki

Finland

13.DCMR EPA/EUROCITIES

Netherlands

14.Federal Office for the Environement (FOEN)

Switzerland

15.Gemeente Den Haag

Netherlands

16.The City of Oslo, Department for Urban Environment

Norway

Non-governmental organisations representing societal interests

17.ACP Automóvel Clube

Portugal

18.Allgemeiner Deutscher Automobil Club e.V. (ADAC e.V.)

Germany

19.ANEC and BEUC

EU

20.Association of Austrian Newspapers

Austria

21.Association of Dutch Water Companies and the Association of Dutch Water Authorities

Netherlands

22.Austrian Journal and Trade Association (ÖZV)

Austria

23.Deutscher Verkehrssicherheitsrat e.V.

Germany

24.European Association for Accident Research and Analysis (EVU)

Austria

25.European Environmental Citizen's Organisation for Standardisation

EU

26.Fédération Internationale de l’Automobile (FIA Region I)

Luxembourg

27.Quercus ANCN

Portugal

28.The European Environmental Bureau

EU

29.Transport & Environment (T & E)

EU

30.ZERO - Associação Sistema Terrestre Sustentável

Portugal

Industry organisations

31.Advertising Association

United Kingdom

32.Advertising Information Group

Germany

33.BDEW Bundesverband der Energie- und Wasserwirtschaft

Germany

34.Däckbranschen Sverige AB

Sweden

35.European association of television and radio sales houses (EGTA)

EU

36.European Caravan Federation

Germany

37.European Magazine Media Association
and European Newspaper Publishers' Association (EMMA& ENPA)

EU

38.European Tyre & Rubber Manufacturers Association (ETRMA)

EU

39.German Insurance Association (GDV)

Germany

40.Nordic Logistics Association

Norway, Denmark, Sweden

41.Swedish Water and Wastewater Association

Sweden

42.The Danish Chamber of Commerce

Denmark

43.The European Federation of National Association of Water Services (EurEau)

EU

44.Verband der TÜV e.V.

Germany

45.Wirtschaftsverband der deutschen Kautschukindustrie e.V.

Germany

46.Zentralverband der deutschen Werbewirtschaft ZAW e.V.

Germany

Other

47.Commodity producer for tires

Germany

48.Solvay Silica (Manufacture of silica for the tire industry)

Belgium

49.Type Approval Authority

Netherlands

50.Water supply plant

Finland

Citizens / consumers

20 respondents identified themselves as citizens and/or private consumers

Respondents mainly originate from northern/western European countries which are not fully representative of the whole European Union. However it provides some basis for full extrapolation to the rest of EU-28 countries.

2.Overall results

The first part of the questionnaire (question 7 to 10) covered the respondent’s opinion on and experience with the current tyre label. A clear majority of respondents found the label useful and helpful when making a purchasing decision and 83% of respondents found an EU-wide label covering all EU countries a good thing. Understanding the label and its parameters is essential in order for the label to have its intended effect. For people having problems understanding the label parameters, the external noise parameter was the most difficult. 77% did not have any problem understanding any label parameters. 29% considered the wet grip parameter the most important, compared to 16% for rolling resistance and 4% for external noise.

The awareness of the label is high, and a majority of respondents had seen the label in use when purchasing tyres. However, this may be expected given the high share of stakeholder respondents and the results should therefore not be used as a general consumer opinion. 43% did not even see the label beforehand in relation to their last tyre purchase. Either they have purchased through an online shop, which is not covered by the regulation, or the physical shop simply did not have the tyre on display and had to order from stock, in which case the consumer will only see the label when receiving the tyre. A final possibility is that the dealer simply did not comply with the regulation, hence not showing the label.

The second part of the questionnaire (question 11 to 21) covered the respondents' opinion on measures and parameters which could improve the current label. Other safety parameters such as snow and ice grip were considered important to include by the respondents, but opinion was divided whether this information should be mandatory or voluntary. The emphasis on safety parameters is consistent with respondents finding the wet grip parameter the most important in the current label, oppose to environmental and economic parameters such as rolling resistance and external noise. 67% of respondents agreed that re-treaded tyres should be included in the labelling scheme, but only if a reliable methodology can be developed. Opinion was divided on whether studded tyres should be included. The possible reason is that this tyre type is not widespread throughout the EU and therefore only relevant in some countries.

Only 21% believed abrasion was an important parameter to include, the remaining respondents considered it more appropriate to regulate abrasion through other forms of regulation or only include it if accuracy of measurements can be ensured. A slight majority were against mileage being included in the label and respondents in favour emphasized the need for an accurate and economically viable testing method.

The consensus was a need to improve awareness of the label through awareness campaigns, mandatory online labelling, and labelling of OEM 4 tyres. To improve consumer confidence, respondents agreed on increasing market surveillance and creating a better platform for the authorities to enforce and coordinate activities. Almost all respondents were in favour of establishing a digital registration database. Another measure to improve confidence would be by introducing third-party verification of tyre test results. It was widely agreed by the respondents that this would improve confidence and should be made mandatory.

3.Detailed results 

As described in the previous section, the first part of the questionnaire covers the opinion on and experience with the current tyre label used in the evaluation. The second part covers opinion on improvements and additions for a revised regulation subject to this impact assessment. Relevant comments have been selected for each theme. Full comments from all respondents are listed in the end of the annex. Comments from respondents wishing anonymity have been excluded. Questions and selected comments have been themed as follows.

3.0.Evaluation of existing tyre label

Question 7a: Are you aware of the EU labelling scheme for tyres?

Question 7b: In your opinion, is the label a helpful piece of information when deciding which tyres to buy?

Question 7c: Do you think it is a good thing that a single EU-wide label covers tyres sold in all EU countries?

Question 8: Clarity of label. The study found that some consumers did not understand the pictures on the label representing different characteristics of the label (see images below). Which, if any, of the images below do you think is difficult to understand?

Please tick the box(es) above the image(s), if difficult to understand:

Figure_1_-

_Fuel_efficiency_pictogram.png

Figure_2_-

_Wet_grip_pictogram.png

Figure_3_-

_External_rolling_noise_pictogram. png

Question 9a: When purchasing your last tyre, did you see the tyre itself beforehand?

Question 9b: Did you see the EU label?

Question 10: Relative importance of label characteristics. Which of the tyre's characteristics currently shown on the label do you consider to be the most important when purchasing a tyre?

Comments on question 10

Respondent ID

Respondent category

Fazilet Cinaralp

An organisation representing industry views

All three performances are key for informed decision by the consumer.

Stephan Rau

An organisation representing industry views

All three performances are key for informed decision making by the consumer.

Jos de Gier

An organisation representing industry views

Most important Wet Grip, secondly RR and less Noise. Overall, these key performances are a good basis for a well-founded buy-decision.

Christoffer Greenfort

An organisation representing industry views

Road safety performance.

Soren Larsen

An organisation representing industry views

We believe fuel efficiency, wet and winter grip and noise are important characteristics.

Martina Petkova

A business manufacturing or involved in the trading of tyres

All three performances contribute to increase the safety as well as the economic and environmental efficiency of road transport and are thus equally important. Consumers should decide based on needs.

Susanne Buchholz

A business manufacturing or involved in the trading of tyres

As in tyre development various performances need to be balanced, it is important to show at least two conflicting characteristics - e.g. fuel efficiency (environment) and wet grip (safety).

Andrew Bassett

A business manufacturing or involved in the trading of tyres

A critical parameter is absent that affects all aspects of tire performance: air retention. This parameter could be accounted for without necessarily being shown as an additional label criterion.

Hans Norén

Swedish Transport Agency, regulatory authority for tires (MSA)

Ice grip.

Schneuwly Dominique

A Member State regional or local government authority

One characteristic is only valuable if the others are visible too.

Johan Sliggers

A Member State government

It is customer choice what characteristic he finds most important. In the tyre awareness campaign in the NLs the choice is often safety (wet grip).

Marina Lukovnikova

A Member State government

We provide the answer as the authority, not as a consumer. All parameters are important, in different aspects.

Guido Gielen

A non-governmental organisation representing societal interests (for example, environmental or consumer interests)

1) Its wet grip performance; 2) wear/life and 3) price seem to be the most important considerations for many

Citizen/consumer (NL)

All three characteristics, as well as the wear factor.

Citizen/consumer (IT)

Its grip on dry surfaces, its grip on wet surfaces and its performance in terms of fuel economy.

General comments related to evaluation of existing tyre label

ANEC/BEUC (Consumer association): “External rolling noise performance does not deliver useful consumer information.”

FOEN (Member State regional or local government authority):“Reconsider noise pictogram (smileys? :-) / :-I / :-( , add colour?)”

3.1.Possible Improvements and additions 

3.1.0.Awareness and online labelling

The following table gives an overview of the answers provided by each main stakeholder group regarding awareness raising and online labelling. Detailed answers can be seen after the summary table.

Respondent category

Summary of answers

Industry

Most of the respondents representing industry agree that label information should always be provided before purchase, also by businesses selling vehicles. To improve the awareness of the label they believe the most beneficial option would be to encourage Member States to run awareness campaigns and that online labelling would improve the visibility of the label.

Governmental organisations

Most of the respondents representing governmental organisations agree that label information should always be provided before purchase, also by businesses selling vehicles and that online labelling would improve the visibility of the label. Regarding how to improve the awareness of the label the governmental organisations have no preferred option as their answers are divided on different suggestions.

Non-governmental organisations

Most of the respondents representing non-governmental organisations agree that label information should always be provided before purchase, also by businesses selling vehicles. To improve the awareness of the label they believe the most beneficial option would be to encourage Member States to run awareness campaigns and that online labelling would improve the visibility of the label.

Consumers

Most of the consumers agree that label information should always be provided before purchase, also by businesses selling vehicles. To improve the awareness of the label they believe the most beneficial option would be to encourage Member States to run awareness campaigns and that online labelling would improve the visibility of the label.

Survey results:

Question 11: Information on all tyres. The study found that most people are not offered a choice of tyres when purchasing a vehicle. Do you agree that businesses selling a vehicle should always provide tyre labelling information for the tyres fitted on that vehicle, including in situations when the customer is not given a choice of tyres?

Question 12: Raising awareness. The study found that some consumers and organisations were not aware of tyre labelling or the benefits of investing in fuel-efficient tyres. Which of the following options (if any) would you like to see included in the Regulation in order to raise awareness?

Comments on question 12

Respondent ID

Respondent category

Bertrand Vallet

An organisation representing industry views

Microplastics release during the use phase

Soren Larsen

An organisation representing industry views

Marking 3PMSF for winter tyres, tested in accordance with UNECE R117 Annex 7. And categorise tyres in general: A, B, C...

Ines Nitsche

An organisation representing industry views

There should be no extension of the system to other types of advertising media as this would threaten the refinancing of the media and thus the editorial reporting.

Katja Heintschel von Heinegg

An organisation representing industry views

Under no circumstances should the requirement to disclose relevant environmental properties in media advertising be extended in the course of any revision of the Regulation.

Marie De Cordier

An organisation representing industry views

Raise awareness through more effective provision of information at the point of sales when the consumer is in the process of making a purchasing decision.

Martina Petkova

A business manufacturing or involved in the trading of tyres

Further encourage Member States to offer purchasing incentives for tyres of label grades A-C (rolling resistance, wet grip) and aim for such tyres in public procurement.

Andrew Bassett

A business manufacturing or involved in the trading of tyres

Label criteria should be tested under 'in-use' conditions. Most tyres in the EU don't run at optimum pressure. Consumer confidence will increase if reported performance is closer to actual performance

Johan Sliggers

A Member State government

The NLs is facilitating a campaign to raise awareness of the importance of tyres: www.kiesdebesteband.nl

Schneuwly Dominique

A Member State regional or local government authority

Reconsider information on the tyres (is everything still needed?), add and highlight label data ON tyre.

Guido Gielen

A non-governmental organisation representing societal interests (for example, environmental or consumer interests)

Tyre choice has some influence on fuel economy but tyre pressures and driver behaviour are bigger, more significant factors. Label would need to offer better consumer relevant information

Aline Maigret

An NGO representing societal interests (for example, environmental or consumer interests)

There is a need for campaigns promoting the label but also explaining the meaning of the parameters/logos (including the safety and environmental benefits) especially if new parameters are added.

Verband Österreichischer Zeitungen

Other

Awareness-raising measures are useful, but should be carried out on a private-sector basis, not by additional. Labelling rules relating to advertising media.

Question 13: Pre-sale provision of information. The study found that the label is often not visible to customers when they buy tyres. Which of the following options (if any) would in your opinion improve the visibility of the label to customers?

General comment related to awareness and online labelling

ANEC/BEUC (Consumer association):“There is a need for better visibility of the label, hence awareness raising campaigns are necessary.”

3.1.1.Market surveillance and third-party verification

The following table gives an overview of the answers provided by each main stakeholder group regarding market surveillance and third-party verification. Detailed can be seen after the summary table.

Respondent category

Summary of answers

Industry

The industry respondents are divided in terms of whether third-party verification would improve the accuracy of the information on the label and whether to introduce third-party verification as a requirement. Furthermore, they are divided on how to improve market surveillance and no preferred option for industry can be identified.

Governmental organisations

Most of the respondents representing a governmental organisation believe that third-party verification would improve the accuracy of the information on the label and it should be introduced as a requirement. Regarding market surveillance they believe that better sharing of results between surveillance authorities could improve market surveillance.

Non-governmental organisations

Most of the non-governmental organisation respondents believe that third-party verification would improve the accuracy of the information on the label and it should be introduced as a requirement. Regarding market surveillance they believe it would be beneficial if the wet grip testing is updated and the results between surveillance authorities are shared with the industry.

Consumers

Most of the consumers believe that third-party verification would improve the accuracy of the information on the label and it should be introduced as a requirement. Regarding market surveillance they believe that better sharing of result between surveillance authorities could improve market surveillance.

Survey results

Question 14a: Would you be more confident of the accuracy of the label's information if third-party verification of tyre test results were mandatory?

Question 14b: In your opinion, should third-party verification of tyre test results be introduced as a requirement?

Question 15: Market surveillance. The study found that some areas and some Member State authorities were not as good as others at checking if labels were accurate or were being shown to customers. Which of the following options (if any) would in your opinion improve market surveillance?

Comments on question 15

Respondent ID

Respondent category

Fazilet

Cinaralp

An organisation representing industry views

MSAs should build skills and testing capabilities to make regular, more coordinated and more visible enforcement actions through market surveillance. This market surveillance activity should involve all 28 MSAs. Meaningful penalties must be established by Member States in case of non-compliance

Stephan Rau

An organisation representing industry views

MSAs should build up skills and testing capabilities. This to make regular, more coordinated and more visible enforcement actions through market surveillance. This market surveillance activity should involve all 28 MSAs in Europe. Meaningful penalties must be established by Member States in case of non-compliance.

Jos de Gier

An organisation representing industry views

Test spread reduction of the current Wet Grip test, by modifying the test method and/or calculation method for the final result. Meaningful penalties in case of non-compliance.

Martina Petkova

A business manufacturing or involved in the trading of tyres

The further development of market surveillance capability and capacity at member state level would best support to improve market surveillance. The launch of the joint market surveillance initiative MSTyr15 is an excellent tool to enhance a high level surveillance system in Europe.

Susanne Buchholz

A business manufacturing or involved in the trading of tyres

Continental is convinced that market surveillance of label performance through regular spot check testing (not simply verification of documents) with meaningful penalties provide the most effective and efficient tool to ensure reliable labelling and a level playing field. The self-certification requirements reflect the available testing infrastructure. If only third party testing was allowed, this would create unacceptable delays/costs for the tyre industry and disadvantages also to consumers.

Johan Sliggers

A Member State government

On testing: Fuel efficiency and noise get better when tyres wear. This is not the case with wet grip. There, the braking distance increases with wear. The standard for wet grip should include a maximum detoriation for worn tyres.
On labels on each batch: every new batch need new testing and possibly a different label

On better sharing of test results: make all test data available in an uniform format on the internet.

See document Tyres in Europe for more detail.

Henk Wolfert

A Member State regional or local government authority

Maybe tests under real driving conditions could change the order of A-G labels?

Aline Maigret

A non-governmental organisation representing societal interests (for example, environmental or consumer interests)

-A centralised registration database that provides solid information to consumers in order to make an informed choice. As the Commission is setting up a database for the Energy label, the possibility of using it to tyre labelling information should be investigated.
-Non-compliant manufacturers should be fined with penalties that are dissuasive and in proportion to the damage caused to consumers and the environment. Several consumer tests have shown discrepancies with manufacturer's test results

Nerea Ruiz

A non-governmental organisation representing societal interests (for example, environmental or consumer interests)

Inclusion on the automotive database

Stephane Arditi

A non-governmental organisation representing societal interests (for example, environmental or consumer interests)

For better sharing of results, go beyond industry and make them available to all, notably by publishing on the automotive database

Laura Carvalho

A non-governmental organisation representing societal interests (for example, environmental or consumer interests)

Inclusion in the automotive database

Citizen/consumer (NL)

Does enforcement also monitor the values on the label? Perhaps EU-wide joint check and publish results (perhaps à la EURO-NCAP by a consumer organization)

Citizen/consumer (FI)

Randomly check if the claimed performance on the label matches the performance of the tyres when sold.

General comments related to market surveillance and third-party verification

Consumer: “[…] it was a suspicion that lower quality brands were not as diligent when obtaining data; this needs to be thoroughly audited in all companies supplying the EU.”

ETRMA (industry organisation):“Industry does not support introducing independent third party testing of the tyre performance. [Instead market surveillance should be] “Increased, more coordinated, more visible enforcement actions through market surveillance is needed.”

ANEC/BEUC (consumer association): "Market surveillance is not adequately carried out and therefore enforcement of the legislation must be improved. Sanctions must be applied in case of non-compliances.”

Goodyear (manufacturer): "[…] efforts should be dedicated to further increase awareness and market surveillance efforts. […] A highly developed market surveillance system with regular surveillance activities at Member States’ level as well as a meaningful set of penalties is important to ensure compliance with the regulation. […] third party testing might be disproportionate to the available infrastructure of testing institutes/type approval authorities’ laboratories, [and] create unacceptable delays and costs for the tyre industry […]”

FOEN (other):“Independent testing is needed in order to guarantee some degree of credibility of the label information.”

Verband der TÜV e.V. (industry association): A label based on the neutrality and competence of a third party organization would make a positive contribution to the confidence of market participants and provide the consumer with a valuable means of orientation, enabling them to compare products realistically. Therefore a system of mandatory confirmation tests such as Conformity of Production (CoP), performed by third-party laboratories, should be implemented.

3.1.2.Ice and snow grip

The following table gives an overview of the answers provided by each main stakeholder group regarding ice and snow. The detailed answers can be found after the summary table.

Respondent category

Summary of answers

Industry

The respondents representing industry think that information on snow and ice performance of a tyre should be included in the label, but are divided on whether it should be mandatory or voluntary.

Governmental organisations

The respondents representing governmental organisations think that information on snow and ice performance of a tyre should be included in the label but are divided on whether it should be mandatory or voluntary.

Non-governmental organisations

The respondents representing non-governmental organisations think that information on snow and ice performance of a tyre should be included in the label but are divided on whether it should be mandatory or voluntary.

Consumers

Consumers think that information on snow and ice performance of a tyre should be included in the label as a mandatory requirement.

Survey results:

Question 16: Snow and ice performance. The tyre label does not currently include information on tyres primarily designed to perform better in ice and/or snow conditions. Do you think that information on snow and ice performance of a tyre should be included in the label?

General comments related to ice and snow grip

ANEC/BEUC (consumer association):“Although good grip on icy road is one of the most important characteristic, there is no information on this in the current label. According to a study from Nokia tyres, the wet grip pictogram is misleading in Nordic countries.”

Goodyear (manufacturer):“[…] either category of winter tyres, i.e. snowflake-marked tyres, and ice tyres (with their future official marking) should be entitled to only one extra logo on the EU label. [and] should be added to the EU tyre label on a voluntary basis […]”

Solvay (“To ensure people safety (wet grip) in winter conditions, we recommend to create a Snow and Ice label”

Swedish Energy/Chemical/Transport Agencies: “Without complementary information about tyre performance under snowy and icy conditions, consumers could choose the wrong type of winter tyre. This is particularly true when consumers buy tyres on the internet without the possibility of speaking with a representative who can answer questions about the product.”

3.1.3.Studded and retreaded tyres

The following table gives an overview of the answers provided by each main stakeholder group regarding studded and retreaded tyres. Detailed answers and question phrasings can be seen after the summary table.

Respondent category

Summary of answers

Industry

Most respondents representing the industry suggest including retreated tyres if accuracy of the measurement methods can be ensured. Regarding studded tyres most industry respondents had no opinion.

Governmental organisations

Most respondents representing a governmental organisation suggest including retreated tyres if the accuracy of the measurement can be ensured, but they do not believe that studded tyres should be included.

Non-governmental organisations

Most respondents representing a non-governmental organisation suggest including retreated tyres if the accuracy of the measurement can be ensured but they have no opinion whether studded tyres should be included.

Consumers

Most consumers suggest including retreated tyres if the accuracy of the measurement can be ensured but they have no clear opinion whether studded tyres should be included.

Survey results:

Question 17: Re-treaded bus and truck/lorry tyres ("C3"). Currently, a label is not required for re-treaded tyres. Re-treading tyres can extend the life of used tyres by replacing worn-out tyre tread, contributing to the circular economy. The study found that there was currently no widely accepted method for measuring the fuel efficiency of re-treaded tyres. Should re-treaded tyres be included in the labelling scheme?

Question 20: Studded tyres. The study found that in countries where studded tyres are used frequently, national measures to ensure their safety and reduce their environmental impact already exist. In some EU Member States, studded tyres are banned. In addition, no method exists for comparing studded tyres to regular tyres for fuel efficiency and wet grip. Should studded tyres be included in the labelling scheme?

General comments related to studded and retreaded tyres:

City of Helsinki: “In Helsinki, 75-80% of C1 and C2 vehicles use studded tyres during winter. This has significant local environmental impacts mainly in the form of elevated noise levels and PM10 dust particles from road and tyre wear. City of Helsinki aims to mitigate the harmful effects of studded tyre use by raising awareness on the matter and providing citizens with fact-based information to help them make more environmentally friendly decisions when choosing winter tyres (non-studded winter tyres over studded tyres). Providing information on snow and ice performance, and possibly abrasion in the tyre label, as well as including studded tyres in the labelling scheme would contribute to that cause.”

3.1.4.Mileage and abrasion

The following table gives an overview of the answers provided by each main stakeholder group regarding mileage and abrasion. Detailed answers and question phrasings can be seen after the summary table.

Respondent category

Summary of answers

Industry

Most respondents representing the industry do not suggest including mileage information or abrasion information on the label, and there is general agreement that concerns about abrasion are more appropriately addressed through other forms of regulation.

Governmental organisations

Respondents representing a governmental organisation suggest including abrasion information if the accuracy of the measurement can be ensured. The governmental organisation respondents are divided regarding whether mileage information should be included on the label.

Non-governmental organisations

Most respondents representing a non-governmental organisation suggest including both mileage information and abrasion information on the label.

Consumers

The consumers answers are very divided and there is no clear opinion on information on mileage and abrasion on the label.

Survey results

Question 18: Mileage. Currently, tyre mileage information (the total distance that tyres can be expected to last for) is not included in the label. The study found that mileage in tyres is very difficult to test or monitor accurately. The tests that do exist are expensive and tend to be bad at measuring "real-life" mileage (that is, outside laboratory conditions). Should mileage information be included in the label?

Question 19: Abrasion and microplastics. Currently, information about abrasion (the removal of material from the tyre when it interacts with the road surface) is not included in the label. Abrasion contributes to a significant percentage of microplastics (small plastic particulates) in the ocean and to air pollution through so-called tyre road wear particles. The study found that there was currently no accurate way of measuring abrasion, and that other legislation already exists to regulate the chemical content of tyre materials. Should abrasion information be included in the label?

General comments related to mileage and abrasion

T&E (NGO): “As regards test methodology on mileage, much progress has been made at UNECE level since the Commission study on the EU Tyre Label was commissioned. […] the Real-world Driving Emissions (RDE) tests recently introduced for cars, it is possible to test tyres' durability in real world conditions and the costs will come down as the tests are more widely used.”

ETRMA (industry organisation):"ETRMA believes that the labelling scheme is by no means appropriate to address this [abrasion] complex question.”

ZERO - Associação Sistema Terrestre Sustentável (NGO):“If these [mileage and abrasion] parameters are not included in the current regulation, the Commission should now, at the very least, request that robust and representative methods are developed for these parameters.”

The European Environmental Bureau (NGO):“As regards measurement methodologies not being developed or agreed yet, a mandate should be issued asap to standardisation bodies by EC to make sure this situation will not be perpetuated and used as an argument to not take action in the future. In the meantime, transitional methods could be suggested and/or simple information provided (e.g on abrasion and microplastics).”

BDEW Bundesverband der Energie- und Wasserwirtschaft (industry organisation):“Incentives should be created to develop tires with less microplastic abrasion. With regard to microplastic abrasion, grading / differentiation in labelling would be important in order to provide the consumer with information for a purchase decision.” [Machine translated]

EurEau (industry organisation):“We would highlight that abrasion contibutes to microplastics in WATER RESOURCES, and not directly water supply. Since the tyres are an important source of microplastics emitted to the aquatic environment, the labelling scheme should include microplastics emissions during normal wear and tear as an indicator.”

3.1.5.Digital registration database

The following table gives an overview of the answers provided by each main stakeholder group regarding a digital registration database. Detailed answers can be seen after the summary table.

Respondent category

Summary of answers

Industry

The majority of respondents representing industry are in favour of setting up a digital registration database and providing public information about tyres to inform consumers and also provide information about tyres to make it easier for authorities to check that labels are correct.

Governmental organisations

All respondents representing governmental organisations suggest that a digital registration database should be set up and provide public information about tyres to inform consumers and also provide information about tyres to make it easier for authorities to check that labels are correct.

Non-governmental organisations

Most respondents representing a non-governmental organisation suggest that a digital registration database should be set up and provide public information about tyres to inform consumers and also provide information about tyres to make it easier for authorities to check that labels are correct.

Consumers

The vast majority of consumers suggest that a digital registration database should be set up and provide public information about tyres to inform consumers and also provide information about tyres to make it easier for authorities to check that labels are correct.

Survey results

Question 21a: Should a digital registration database providing information about tyres be set up?

Question 21b: If a digital registration database should be set up, what sort of information should it provide?

General comments related to digital registration database

ANEC/BEUC (consumer association):“The possibility of using the database currently being set up for the EU energy label should be investigated for the tyre labelling scheme.”

Goodyear (manufacturer):“[…] in light of additional management and administrative cost involved we do not deem it necessary to introduce another database at European level.“

FOEN (Swiss federal office for environment):“A public database containing data of all sold tyres is needed (for information AND controlling purpose) […]”.

3.1.6.Small and Medium Sized Enterprises (SMEs)s

General comments related to SMEs:

European Caravan Federation (industry organisation):“Motor caravans are generally built by SMEs using multi-stage builds. The tyres for the completed vehicle are provided as part of the base vehicle and not by the final stage manufacturer. Any requirements for provision of information to the consumer must therefore be carefully considered in respect of these vehicles to ensure that undue burden is not placed onto these SMEs.”

3.1.7.Advertisement

General comments related to advertisement

The Association of European Radios“AER believes that, especially when it comes to radio, advertising is not the right place to insert detailed information. It does not and cannot provide all information necessary for the final purchase decision. The consumers’ decision is based on many other sources, such as brochures and websites, and information collected at the point of sale. […] Consequently, AER calls for the status quo regarding advertising rules contained in the Tyre Labelling Regulation: i.e. no labels or terms and conditions inserted in tyre advertisements in billboards, newspapers, magazines, radio broadcasting, television and similar online formats.”

EMMA/ENPA (industry organisation):“We would in particular like to comment on the suggestion to extend technical information on tyre efficiency to advertising, specifically in magazines and newspapers. It is our view that a mandatory inclusion of such information would be inefficient and would in the process have negative effects on the value of advertising in both print media and digital media.”

ÖZV (NGO): “A widening of the requirements for compulsory information in advertisements leads to a situation that makes the advertising as a whole unattractive.” [Machine translated]

European association of television and radio sales houses (industry organisation):“[…] TV and radio advertisements [..] are not optimal platforms for conveying technical information in a meaningful way to consumers. […] the potential negative impact that mandatory information messages would have on TV and radio revenues could be significant”

Zentralverband der deutschen Werbewirtschaft (industry organisation):“[The label should be] made available to the consumer only where he / she takes note of the information in a manner relevant to the purchase decision. This does not usually take place via the media advertising […]”

3.1.8.Rescaling

General comments related to readjustment:

ETRMA (industry organisation):“It is considered premature to revise the labelling scale requirements for both wet grip and fuel efficiency, and even noise, while efforts should be dedicated to increase awareness and market surveillance efforts”

Goodyear (manufacturer):“Goodyear supports the conclusion of the Viegand Maagoe study stating that it is premature to revise the labelling scale for any of the three tyre label performances […]”

3.1.9.Testing standards

General comments related to testing standards

“The boundary conditions are too broadly defined (road test surface, temperatures, test vehicle.”, “The label says nothing about the absolute, achievable braking distances” [FIA]

ExxonMobil Petroleum & Chemical BVBA (tyre supplier):“A revised rolling resistance coefficient (RRC) standard test and rating that requires RRC average over time vs. a single data point under optimal conditions” 

ETRMA (industry organisation): ETRMA is recommending introducing the new revised test method [for wet grip] at the current planned revision of the tyre label scheme.” 

3.1.10.Additional suggestions

Däckbranschen Sverige AB (industry organisation):“It would be desirable to investigate the possibility of also obtaining information in the tire label regarding performance throughout the lifetime.” 

Solvay Silicia“It is important to monitor how the overall tire performances (Rolling Resistance, Wet Grip, Noise) age during the tire lifecycle (e.g.: performance variation after 10 000 Km, 20 000 Km, above 30 000 Km)”. 

ExxonMobil Petroleum & Chemical BVBA (tyre supplier):“A key aspect is inflation pressure loss rate (IPLR) performance. Specifying tyres with a maximum IPLR of e.g. 2% or 2.5% (which could also be progressively reduced in response to market demands and technology developments) should promote improved IPLR performance of tyres in the EU.

“The regulation should integrate a clear obligation to manufacturer (supplier) to fulfil compliance evaluation procedure, including periodical control of production.”

“The text of regulation may be improved for more clarity. Market surveillance authorities and even laboratories have sometimes difficulties to interpret the text in the same way.” [Federal Ministry of Environment]

4.In extenso comments from all respondents 

“As an ex-employee of a large tyre company, I know the vast sums of money invested in getting data for these types of test & it was a suspicion that lower quality brands were not as diligent when obtaining data; this needs to be thoroughly audited in all companies supplying the EU.” [Consumer]

The European Caravan Federation (ECF) is the umbrella organisation representing the national organisations of the European Caravanning Industry. Membership of the ECF consists of 12 caravanning federations and numerous national members of the caravanning industry within the EU member states. These members are involved in the production, the sales and the use of touring caravans, motor caravans and the supply of specialist parts and services to the industry.Motor caravans are manufactured by small and medium sized manufacturers in quantities from 10 to 10.000 annually. Motor caravans are generally built by SMEs using multi-stage builds. The tyres for the completed vehicle are provided as part of the base vehicle and not by the final stage manufacturer. Any requirements for provision of information to the consumer must therefore be carefully considered in respect of these vehicles to ensure that undue burden is not placed onto these SMEs. [European Caravan Federation]

In Helsinki, 75-80% of C1 and C2 vehicles use studded tyres during winter. This has significant local environmental impacts mainly in the form of elevated noise levels and PM10 dust particles from road and tyre wear. City of Helsinki aims to mitigate the harmful effects of studded tyre use by raising awareness on the matter and providing citizens with fact-based information to help them make more environmentally friendly decisions when choosing winter tyres (non-studded winter tyres over studded tyres). Providing information on snow and ice performance, and possibly abrasion in the tyre label, as well as including studded tyres in the labelling scheme would contribute to that cause. [City of Helsinki]

As regards test methodology on mileage, much progress has been made at UNECE level since the Commission study on the EU Tyre Label was commissioned. Thus Question 18 above somewhat prejudges the answers and influences the audience by claiming that the tests are "expensive and inaccurate"; this is a subjective view. Similarly to the Real-world Driving Emissions (RDE) tests recently introduced for cars, it is possible to test tyres' durability in real world conditions and the costs will come down as the tests are more widely used. Most drivers fall within the 70-80% of all driving conditions, and so called boundary conditions to mirror the on-road use can be introduced, as was successfully done in RDE. As regards question 21 on database, synergies should be sought with the provisions on online exchange platforms agreed as part of the new Type Approval and Market Surveillance regulation - the information on tyres should be added into one common EU database on type approval of vehicles, their parts and components. [Transport & Environment]

An ice-labelling mark is very important for the Nordic market [Michelin Nordic AB]

“Although the tyre label is an important tool for consumers across Europe to take an informed decision, there is a need to review the current regulation, and to launch the impact assessment. We reiterate our position:

- the methodology used to define the energy classes of tyres must reflect real life performance, hence providing accurate and transparent information to consumers. Currently, we fear that manufacturers are often using loopholes in the methodology as well as tolerances in order to reach higher energy classes. It is misleading information for consumers. The methodology needs to be updated.

-There is a need for better visibility of the label, hence awareness raising campaigns are necessary.

-Market surveillance is not adequately carried out and therefore enforcement of the legislation must be improved. Sanctions must be applied in case of non-compliances.

-Regarding the current criteria, we believe that wet grip performance is the most important parameter because of its impact on safety. Fuel efficiency performance is important as long as there is no trade-off between rolling resistance and wet breaking because they can put conflicting demands on tyres which should be prevented. Innovation in recent years has shown that it is possible to improve wet grip and fuel efficiency simultaneously. External rolling noise performance does not deliver useful consumer information.

-The range of performance parameters on the label is too limited. The label could be extended to snow and ice grip. Although good grip on icy road is one of the most important characteristic, there is no information on this in the current label. According to a study from Nokia tyres, the wet grip pictogram is misleading in Nordic countries.

-the impact assessment should consider sustainability and that additional comprehensive tyre wear tests are needed.

- the logo representing the parameter must be tested among consumers to ensure the comprehensibility. Overall the whole label should be tested upfront through consumer survey.

- Manufacturers and dealers need to make the label available to consumers before the purchase decision (alignment with the Energy labelling Directive).

- the possibility of using the database currently being set up for the EU energy label should be investigated for the tyre labelling scheme.” [ANEC/BEUC]

For the parameters where it is indicated that measurement methods do not exist, or are not accepted/reliable, further investigation may be required. If these parameters are not included in the current regulation, the Commission should now, at the very least, request that robust and representative methods are developed for these parameters. Considering that the standardisation community might not be interested in developing those without a request (or may even not have an interest in “widely accepting” methods that are available), such a Commission request would at least attempt to avoid facing exactly the same situation when a future review or revision takes place.Additionally, consumer understanding of the label should remain a priority, and hence, we invite the Commission to have a consumer understanding assessment, as for other Energy Labels under discussion. [European Environmental Citizen's Organisation for Standardisation]

The Label aims to encourage the market uptake of energy saving products and aims to encourage the manufactures in technological development. However, the tyre particularity is safety: tyre is the only contact between the vehicle and road. Therefore it is necessary to have a safety performance presented in the EU tyre labelling. Currently it is the information on the wet grip performance of a tyre. Wet grip and ice grip are technically nearly opposite tyre performances and in Nordic winter weather conditions the ice grip is the most critical tyre performance. From this it follows that the Label may offer a wrong view compared to what Nordic citizens need and the consumer may become mislead and buy a wrong tyre for his or hers needs. In this way the winter time road traffic safety is decreased and the inapplicability of the tyre Label may question the credibility of the EU energy efficiency policy in Nordic countries. The above-mentioned, however, concerns mainly the C1 class tyres. Tyres in class C2 could be added in the scope later when such test method specification has been developed. Tyres in class C3 should be left out of the ice grip marking.Winter tyre technologies improve road traffic safety and help to decrease the number of traffic accidents. There are big differences between different types of winter tyres. EU Tyre Labelling may create a safety risk in Nordic countries’ winter time road traffic. Snow and/or ice grip markings should be added to the EU Tyre Label. According to the Article 11 of the Reg. EC/1222/2009 it is possible to amend the Regulation to add information regarding ice and/or snow performance through delegated powers of the European Commission. [Nokian Tyres Plc]

“General Comment on Market Transformation: Goodyear supports the conclusion of the Viegand Maagoe study stating that it is premature to revise the labelling scale for any of the three tyre label performances, while efforts should be dedicated to further increase awareness and market surveillance efforts. Tyre development faces a multiple set of customer-oriented performance requirements which often conflict with each other. Tyre technology has been evolving and the EU tyre label has been a driver for that. According to the report from the European Commission (COM 2017-658/final) market penetration for the best energy efficiency classes (A and B) in fuel efficiency and wet grip is still very low (<1% for all tyre types). This reflects that the current scaling system of the three performance categories is already challenging and will remain such in the foreseeable future.

Third Party Verification: A highly developed market surveillance system with regular surveillance activities at Member States’ level as well as a meaningful set of penalties is important to ensure compliance with the regulation. In this context third party testing might be disproportionate to the available infrastructure of testing institutes/type approval authorities’ laboratories, while not proven as a need from effectiveness and efficiency perspectives. If only third party was allowed, this would create unacceptable delays and costs for the tyre industry, with disadvantages also to customers and end-consumers.

Snow/Ice Performance: When an ice performance test and logo are available, either category of winter tyres, i.e. snowflake-marked tyres, and ice tyres (with their future official marking) should be entitled to only one extra logo on the EU label. This is important to ensure parity in information for users of winter tyres in the Continental part of Europe and in Scandinavia. This is the finding of a consumer survey that Goodyear conducted in 2015 on consumers’ reactions to possible winter tyre information on the official tyre label. An extra logo (either an ice performance or the existing three-peak-mountain snowflake logo) should be added to the EU tyre label on a voluntary basis, provided that tyres pass the legal thresholds for relevant performance, with official test methods.

Registration Database: Consumers already have comprehensive access to tyre label grades through various tools in the current system: physical stickers (for C1 and C2 tyres), and availability of the label grades in the digital systems of tyre manufacturers, distributors, and dealers. Market surveillance authorities already have opportunity to share information on market surveillance initiatives via the existing ICSMS tool. Therefore and in light of additional management and administrative cost involved we do not deem it necessary to introduce another database at European level.“ [Goodyear]

“Independent testing is needed in order to guarantee some degree of credibility of the label information.

A public database containing data of all independently tested tyre with results and divergences (pressure on the manufacturers).

A public database containing data of all sold tyres is needed (for information AND controlling purpose), please check “Swiss solution”, established by the TCS (www.tcs.ch): http://www.bfe.admin.ch/energieetikette/00886/04758/05701/index.html).

Label information of each tyre belongs ON that specific tyre: not all the “same” tyres really are the “same” (year or even season/week of the production, country of origin of components, tyres already mounted on new cars SERIOUSLY! vary from the “same” tyres one can purchase…).

IDEA: as manufacturer, you can “certify” your tyre if tested by an independent authority, add shiny symbol to the label.

Reconsider noise pictogram (smileys? :-) / :-I / :-( , add colour?)

Reconsider noise evaluation scheme: make it absolute, not relative to the tyre dimension. Loud is loud, e.g. >71dB. Why should a loud tyre outperform a quieter one just because it’s wider? In terms of health annoyance, this makes no sense.

Please NOTE: as long as label values cannot be trusted (aka today’s situation), it is impossible to enforce “hard” and efficient measures (e.g. tax cuts).” [FOEN]

“Criticism of the EU tire labelling:

Wet grip characteristics: Basically, it can be stated that direct mapping of EU tire label data is not or only partially possible within the ADAC tire test, although the specific test procedures (wet braking from 80 to 20 km / h) are largely similar , This means that the ranking determined in the ADAC tire test by direct comparison of several tire models under identical conditions does not or only partially corresponds to the EU tire label classification of these tires. This highlights a specific weakness of the EU tire label classification method. The manufacturer's own tests of tires for the EU tire label classification cannot be carried out under the same conditions as in the ADAC tire test. The tests are carried out at different locations on routes with different coefficients of friction and under different climatic conditions. Admitted limits are given for the friction coefficients of the roadways and the climatic conditions. Also, the properties of the test tracks were set in relation to each other by means of ring comparisons. Nevertheless, the allowed differences should be normalized by using correction factors. When comparing the ADAC tire test results with the tire label classifications, it does not always appear to be guaranteed that these corrections to the raw data can adequately compensate for the differences in the framework conditions mentioned. This applies in particular to the correction factors of temperature and road friction coefficient.

Rolling resistance / fuel efficiency: The rolling resistance and fuel efficiency data also show differences between the ADAC tire test ranking and the EU tire label classifications. However, there are sometimes significantly different measuring methods in this test point. While determining the fuel efficiency classification of the EU tire label, the rolling resistance coefficient of the test tire is determined on a certified chassis dynamometer. The ADAC directly measures the fuel consumption of the same vehicle (within one test dimension) with the different test tires under the same conditions, The tires are loaded with 50 to 60%. Regardless of these differences in measurement methods, it remains to be proposed to reduce the tire load in rolling resistance measurements from the current 80% to a more realistic 50 to 60%.” [ADAC] [Machine translated]

As a representative of the media industry, we are fundamentally critical of labelling requirements insofar as they concern advertisements. In recent years, such EU legal acts have repeatedly intervened in protected fundamental rights positions - the right to freedom of communication and the right to freedom of occupation - by compelling the advertising industry to provide compulsory information on all kinds of products. A widening of the requirements for compulsory information in advertisements leads to a situation that makes the advertising as a whole unattractive.

If the European Commission considers that there is a need for media education to promote tire labelling, this should not happen again as a result of the burdensome media industry. Even if labelling requirements in technical advertising media can make sense in order to provide interested consumers with information about the product, they must by no means be extended to classic advertising media. In our opinion, e.g. also the creation of an online database (see question 21), where all relevant information for consumers can be retrieved, an appropriate measure to relieve the provisions on compulsory disclosures.

A more fundamental, proportionate and, on top of that, strengthening the European media sector's access to awareness raising and information for citizens would also be information campaigns by the European Union or its member states on classical media channels on a private-sector basis. [Verband Österreichischer Zeitungen] [Machine translated]

“As a representative of the media industry, we are fundamentally critical of labelling requirements insofar as they concern advertisements. In recent years, such EU legal acts have repeatedly intervened in protected fundamental rights positions - the right to freedom of communication and the right to freedom of occupation - by compelling the advertising industry to provide compulsory information on all kinds of products. A widening of the requirements for compulsory information in advertisements leads to a situation that makes the advertising as a whole unattractive.

If the European Commission considers that there is a need for media education to promote tire labelling, this should not happen again as a result of the burdensome media industry. Even though labelling requirements in technical advertising media may well make sense in order to provide interested consumers with information about the product, they must by no means be extended to classic advertising media. In our opinion, e.g. also the creation of an online database (see question 21), where all relevant information for consumers can be retrieved, an appropriate measure to relieve the provisions on compulsory disclosures.

A more fundamental, proportionate and, on top of that, strengthening the European media sector's access to awareness raising and information for citizens would also be information campaigns by the European Union or its member states on classical media channels on a private-sector basis.” [Österreichischer Zeitschriften- und Fachmedienverband (ÖZV)] [Machine translated]

The evaluation and update of the Regulation on Tyre labelling is closely linked to the Regulation on General Safety (EC no 661/2009). In the Regulation on General Safety the tyre limits for fuel efficiency, wet grip and noise are set. In July 2017 the Netherlands ministry of environment sent a letter to 4 director generals of the European Commission asking to start working on strengthening of the tyre limits and interest the Commission to a number of other tyre related issues among which improving the tyre label. Q 7b: The information on the label is limited to letters and colours. One of the reasons to start an public awareness raising campaign in the Netherlands is that the label gives very little information. We propose more information on the label to encourage a discussion between people buying tyres and retail. See the background document ‘Tyres in Europe’ that was attached to the letter to the Commission for an example how this can be done. Having a label as proposed by the Netherland would almost make the campaign redundant.Q 9a/b: In the Netherlands the tyre label is mandatory both in the shops and on the internet. That is not a problem. Another thing is whether garages/workshops advise people when their car is brought for inspection/maintenance and new tyres are necessary. Then usually just a phone call is made and information on label values is not transmitted. The customer would in most cases not be informed about the tyre label of the new tyres when picking up the car.Q 16: See the background document Tyres in Europe attached to the letter to the Commission for an example how this can be done.Q 18: The Netherlands is greatly concerned about microplastics in the environment. We do favour a limit on abrasion of tyres but not on mileage. And we would like to see a proposal for that from the Commission. Yet, we are very reluctant to put anything on the tyre label. The most important argument would be that the consumer would look at any indicator regarding wear/durability/abrasion as an indicator for mileage. Tyre manufacturers could get a better label when they increase the tyre tread. And as a result the emission of microplastics would increase. See for more details the document Tyres in Europe.Q 19: See the comment to Q 18 above. An argument of a lesser importance is that the label would be more difficult to understand and to interpret. Including an indicator for snow/ice (see answer to Q16) would make five indicators on the label. A5th indicator on the tyre label would be too much information. “[Dutch Ministry of Infrastructure and Water Management]

“Tyre labelling scheme should follow the same rules as any other energy label, notably be tested on consumers to check proper understanding when being designed/reviewed.

As regards measurement methodologies not being developed or agreed yet, a mandate should be issued asap to standardisation bodies by EC to make sure this situation will not be perpetuated and used as an argument to not take action in the future. In the meantime, transitional methods could be suggested and/or simple information provided (e.g. on abrasion and microplastics).” [The European Environmental Bureau]

We need to promote these tyres more and more by means of campaigning under municipalities that could start with including this in their public procurement procedures, see also www.better-tyres-now.eu  [DCMR EPA/EUROCITIES]

“A tyre labelling should be designed in a way allowing consumers to make a careful decision, giving incentives to tyre manufactures to improve their products and raising public awareness. In general, the information concerning safety, energy efficiency and environmental protection provided to end costumer must be more reliable. The Tyre Labelling Regulation has implemented a “self-declaration system”. Tyre manufacturers assess the performance criteria of their own products according to defined rules of testing and inform consumers about their own results. In contrary to the type approval system for tyres, using the same test procedures, there is no certification by a third party (independent verification). No evidence on competence for testing is required, e.g. accreditation as test laboratory or designation as a Technical Service. A label based on the neutrality and competence of a third party organization would make a positive contribution to the confidence of market participants and provide the consumer with a valuable means of orientation, enabling them to compare products realistically. Therefore a system of mandatory confirmation tests such as Conformity of Production (CoP), performed by third-party laboratories, should be implemented. Concerning the implementation of new procedures for the assessment of tyres we refer to the new European regulations on emissions and fuel consumption. According to these regulations “certified values” like the tyre rolling resistance coefficient are implemented to provide a more realistic label on emissions and fuel consumption of new vehicles. The tyre manufacturer may test in a laboratory of the Technical Services (TS), as defined in Article 41 of Directive 2007/46/EC, where the TS performs the testing in its own facility as referred to in paragraph 3.1. Or the tyre manufacturer may test in its own facilities under the condition that:

a.    A representative of a Technical Service designated by an approval authority is present, or

b.    The tyre manufacturer is appointed as a Technical Service of Category A in accordance with Directive 2007/46/EC Art. 41” [Verband der TÜV e.V.]

 For the parameters where it is indicated that measurement methods do not exist, or are not accepted/reliable, further investigation may be required. If these parameters are not included in the current regulation, the Commission should now, at the very least, request that robust and representative methods are developed for these parameters. Considering that the standardization community might not be interested in developing those without a request (or may even not have an interest in “widely accepting” methods that are available), such a Commission request would at least attempt to avoid facing exactly the same situation when a future review or revision takes place. Additionally, consumer understanding of the label should remain a priority, and hence, we invite the Commission to have a consumer understanding assessment, as for other Energy Labels under discussion.” [ZERO - Associação Sistema Terrestre Sustentável]

Continental welcomes the introduction of the EU Tyre Labelling Scheme as a powerful tool promoting tire design innovation that balances environmental and safety criteria and encouraging respective consumer choices. Prerequisite for a positive effect of tire labels is broad awareness and that they are well enforced, so customers consider them and can be sure that the actual tire performance meets the declared grading, when they buy a tire. Ensuring consumer awareness and understanding as well as enforcement should be the overall objectives when considering potential amendments of the Labelling Scheme.Q 14+15: Third party verification and market surveillanceContinental is convinced that market surveillance of label performance through regular spot check testing (not simply verification of documents) with meaningful penalties in case of proven non-compliance provide the most effective and efficient tool to ensure reliable labelling and a level playing field. The self-certification requirements reflect the available testing infrastructure. If only third party testing was allowed, this would create unacceptable delays and costs for the tyre industry, with disadvantages also to consumers. Continental welcomes and encourages more visible enforcement actions and an EU wide coordination of activities, e.g. the exchange of information on candidates tested among EU Member State Authorities.Q 16: Snow and Ice PerformanceHaving the option to indicate on the EU Tyre Label that the respective tyre is suitable for winter conditions, would be a valuable consumer information. This should be done by adding a respective "marking", which is based on a legally defined test (e.g. the Three-Peak-Mountain-Snowflake Symbol) to the Label. Continental does not support adding complexity to the Label through the addition snow or ice performance "grading" to the label. Q 17: Re-treaded bus, truck/ lorry tyresPrerequisite of including re-treaded C3 tyres in the EU Tyre Labelling Scheme is that it improves comparability of the performances of re-treaded and new tyres. The requirements for Label class setting of retreaded tires need to be set accordingly.Q 19: Abrasion and MicroplasticsThe contribution of tire road wear particles to microplastics in different environmental compartments is an important and complex question which the tire industry investigates with urgency. At present, many uncertainties prevail, while it is acknowledged that abrasion largely depends on external factors such as road surface and topology, driving behaviour etc. Appropriate mitigation measures need to be defined once a more robust scientific understanding has been built. [Continental Reifen Deutschland GmbH]

For the parameters where it is indicated that measurement methods do not exist, or are not accepted/reliable, further investigation may be required. If these parameters are not included in the current regulation, the Commission should now, at the very least, request that robust and representative methods are developed for these parameters. Considering that the standardization community might not be interested in developing those without a request (or may even not have an interest in “widely accepting” methods that are available), such a Commission request would at least attempt to avoid facing exactly the same situation when a future review or revision takes place. Additionally, consumer understanding of the label should remain a priority, and hence, we invite the Commission to have a consumer understanding assessment, as for other Energy Labels under discussion. [Quercus ANCN]

”The preparatory study to this consultation shows that awareness of the label has increased from 30% in 2012 to 53% in 2015 (p.27). This is significant, given that the Regulation has only applied since 2012. It is thus difficult to argue that there is an awareness deficit; a few basic steps such as informing customers even when they are not given a choice of tyres appear as simple, logical and efficient steps to further improve awareness.

Furthermore, TV and radio advertisements (by and large 30-second spots) are not optimal platforms for conveying technical information in a meaningful way to consumers. The study recognises that including labels in advertisements would present a number of obstacles as “tyres of the same model with different dimensions often have different label values” (p.76). Conversely, the potential negative impact that mandatory information messages would have on TV and radio revenues could be significant (less time available for advertising and less attractiveness for advertisers).

Hence, not only do mandatory mentions of the label in advertisements seem inefficient in terms of raising awareness, they could also have critical unintended consequences on the broadcasting industry. Technical promotional material should therefore remain the natural vehicle for information on tyre labels. We remain available to provide additional information on this matter.” [European association of television and radio sales houses]

I. Request for modification of Article 1, (2), 3, of Regulation (EU) No 1235/2011 of 29. Nov 2011, amending Regulation (EC) No 1222/2009 by:1. Cancelling the Subtrahend – 0,03 in Formula G = G(T) - 0.03, Calculation of wet grip index (G), where G(T) = wet grip index of the candidate tyre as measured in one test cycle.2. Cancelling Wet Grip Classes E and F for C1, C2 and C3 tyres in current Tyre Label table.Reason: Formula G = G(T) – 0.03 in (EU) No 1235/2011 causes wet grip class F for C3 tyres to violate, and classes E for C3, and F for C1 and C2 tyres being only 0.02 G above Type-Release with Regulation No 117 (UNECE) [2016/1350]. Required Minimum Type Release Wet Grip Index for Normal Tyres:6.2.1 Class C1, with (G) ≥ 1,16.2.2, Class C2, with (G) ≥ 0,95 6.2.3, Class C3, with (G) ≥ 0,80.Comparison of Wet Grip Class F, normal C1 Tyres,:UNECE Type Release, Wet Grip Index G, with G ≥ 1,1 (larger or equal), and correspondingEU Tyre Label, Wet Grip Index G with G ≤ 1,09 (smaller or equal).II. Request for permanent marking of the Tyre Label classification C1, C2 and C3 by each Tyre Manufacturer on their new tyres for identification. Loose paper identification is uncontrollable. [European Association for Accident Research and Analysis (EVU), Graz, Austria]

“Current marking applies only to new tires. Today there are no test methods and information about how tire properties change in wear and tear. It would be desirable to investigate the possibility of also obtaining information in the tire label regarding performance throughout the lifetime.” [Däckbranschen Sverige AB] [Machine Translated]

“In principle, the ZAW supports the objective of Regulation (EC) No. 1222/2009 (hereinafter referred to as the "Regulation") to provide consumers with environmentally relevant information on tires that enable them to make informed purchasing decisions. As correctly stated in the VO (EG 17), the time and place of the purchase decision must be taken into account. Therefore, it must be ensured that all environmentally relevant information, including any graphic prescriptions (labels), is made available to the consumer only where he / she takes note of the information in a manner relevant to the purchase decision. This does not usually take place via the media advertising, but in the course of the further information process significantly via other sources, especially brochures, test reports, information on seller or manufacturer websites and at the point of sale.

The ZAW therefore rejects compulsory information in media advertising as a means of informing and informing the purchaser of disproportionate and not expedient. Forced information in advertising significantly curtails the legitimate communication interests of the advertising economy and the need for advertising financing essential to free and independent media. Mandatory information inevitably leads to the reduction of freely designable content and thus to censorship. At the same time, this endangers the financing of the media and thus also those editorial contents that are indispensable for public opinion formation and private behavioural change on environmental and climate issues.

These correlations have been taken into account by the current regulation with its differentiated regulations on compulsory information in an appropriate manner. These are then provided at the point of sale and in technical promotional material. On the other hand, media advertising is rightfully explicitly excluded from the information obligations provided for in the regulation (see EC 18). From the point of view of the German advertising industry, this is the right way to ensure an informed purchasing decision by the consumer without jeopardizing the refinancing of the media and thus the information of the consumers through the media

This balanced information system must therefore be retained and in the future transferred to other energy labelling regimes (notably the EU Car Labelling Directive 1999/94 / EC).

In any case, in the context of a possible revision of the Regulation, the obligation to disclose environmentally relevant characteristics may be extended to media advertising. An extension to media advertising would curtail the legitimate communication interests of the advertising industry and damage the existence of advertising financing necessary for free and independent media without an informational added value for the consumers.” [Zentralverband der deutschen Werbewirtschaft] [Machine translated]

“As Solvay, a key player in silica for the tire industry, we want to emphasize 3 points:

1) To ensure people safety (wet grip) in winter conditions, we recommend to create a Snow and Ice label

2) To raise people awareness on tire labelling and performance, we suggest to improve the transparency of the tire park evolution by creating and publishing a yearly outlook of the number of tires sold with their label characteristics: Rolling Resistance at A, B or C ...level, Wet Grip at A, B or C....level, etc....

3) It is important to monitor how the overall tire performances (Rolling Resistance, Wet Grip, Noise) age during the tire lifecycle (e.g.: performance variation after 10 000 Km, 20 000 Km, above 30 000 Km)” [Solvay]

ANWB: Revision standardised measurement methodology required, because now not always covering reality e.g.- Wet grip in range +5 - +30 degr. C, range too big;- Rolling resistance measured with straight wheel camber, this is not the reality;- Only one single reference tyre;- May be tested with specially prepared test vehiclesTCS: The mobility Club tyre tests show that manufacturers' EU label declarations often significantly deviate from the real measured values. It should be noted that not only better, but also lesser tires compared to the labelled ones are commercially available.Reasons can be:- The label is a self-certification of the manufacturer and can follow a targeted marketing strategy;- Control possibilities of the label values by the authority are questionable;- The classification of summer, winter, and all-season tires is determined during measurements applying temperature windows;- A uniqueness of the label values are not always given:o Cautious vs. Optimistic interpretation of the measured values;o The boundary conditions are too broadly defined (road test surface, temperatures, test vehicle ...);o All tire dimensions are compared with a reference tire (SRTT) dimension 225/60 R16 in the test criterion wet grip. With this classification, no difference is made between different tire dimensions.o This means that (even with the same product quality) narrower tires can systematically fall into worse wet grip classes than wider ones;o The label says nothing about the absolute, achievable braking distances;o It may happen that narrower narrow tires have a shorter braking distance than better rated wide tires (when measuring on the respective tires for the tire)."That's why the EU tire label is today only use-able for the consumer within very narrow limits as purchasing orientation."Upon request from the EC the TCS test report (in German) can be made available in which TCS has compared their own proprietary tyre test results with the EU label values for the Swiss authorities [Fédération Internationale de l’Automobile (FIA Region I)]

“Under-inflated tyres can increase rolling resistance, which in turn can increase fuel consumption by up to 4% and increase CO2 and other emissions. Under-inflated tyres can also reduce tyre lifespan by up to 45%, and is the leading cause of tyre failure. Consumers are reliant on the tyre pressure monitoring system (TPMS) present within modern vehicles, instead of regularly checking and maintaining tyre pressure which would require frequent, inconvenient, intervention from the consumer. While the TPMS provides an effective indication of significant pressure loss e.g. in the case of a puncture or blowout, it does not provide an effective system for optimizing air pressure on a day-to-day basis including the gradual tyre pressure loss which occurs over time under real in-use conditions.

Tackling the issue of under-inflation at source (by maintaining optimal pressure for longer, via improved air retention of the tyre itself) would reduce the need for consumer monitoring and intervention. As tyre regulations and standards continue to progress, the goal should be to drive consistent and reliable performance and efficiency improvements over the lifetime of the tyre under real use conditions. A key aspect is inflation pressure loss rate (IPLR) performance. Specifying tyres with a maximum IPLR of e.g. 2% or 2.5% (which could also be progressively reduced in response to market demands and technology developments) should promote improved IPLR performance of tyres in the EU.

A simple and cost effective solution is already available with conventional materials, equipment and tyre building technology. Material composition of the tyre inner liner is key to IPLR performance, with increasing halo-butyl content being the most important factor. Gauge also has an effect but is only a secondary contributor. Other components such as oils, fillers and recycled scrap can also have a negative impact. It is also advisable to review the current rolling resistance test procedure (currently performed at optimum pressure) to fully assess actual in-use performance.

Under-inflation will be even more important as electrical and autonomous vehicles enter the market place. As internal combustion engines are less efficient than electric vehicles from an energy conversion standpoint, losses from rolling resistance have hitherto had less of an impact. However, hybrids and electric vehicle powertrains are more efficient and therefore tyre rolling resistance has a greater overall impact on energy use.

ExxonMobil recommends the Commission gives due consideration to:

• Tyre air retention criterion / specification within a targeted amended, or fully revised, EU Tyre Labelling Regulation

• A revised rolling resistance coefficient (RRC) standard test and rating that requires RRC average over time vs. a single data point under optimal conditions

• Providing e.g. CO2 credits for OEMs to increase the adoption of tyre technologies that can help improve in-use tyre performance” [ExxonMobil Petroleum & Chemical BVBA]

“Sweden’s recommendation on consumer information regarding tyre performance during winter conditions

The energy label for tyres should include consumer information on tyre performance during winter conditions. Such information is necessary to help the consumer choose the right type of winter tyre. Today the energy label for unstudded tyres includes information on tyre performance on wet surfaces, but does not include information about tyre performance on snowy or icy surfaces. Therefore, when Swedish consumers receive information that Central European unstudded tyres perform better than Nordic unstudded tyres in wet conditions, but receives no equivalent information on the performance of such tyres on snow or ice, such consumers may be inclined to believe that the tyres even perform better in typical Nordic winter conditions. In other words, without complementary information about tyre performance under snowy and icy conditions, such consumers could choose the wrong type of winter tyre. This is particularly true when consumers buy tyres on the internet without the possibility of speaking with a representative who can answer questions about the product.

Furthermore, consumer information should clarify that tyres that are not within the scope of the regulation, such as studded tyres, may not bear an energy label. During market surveillance, the Swedish Energy Agency observed that many studded tyres are nonetheless labelled, which could confuse the consumer.” [Swedish Energy/Chemical/Transport Agencies]

One of our main concerns it to improve knowledge about, quality and marking of winter tyres and to ensure that these tyres are used. The UNECE R117 Annex 7 Alpine symbol fulfils the requirement for winter tyres. [Nordic Logistics Association]

“The Advertising Association supports the Regulation’s objective of providing consumers with the relevant environmental information that enables them to make informed purchasing decisions.

The Regulation acknowledges that relevant information should be provided to consumers at the appropriate point during the purchase process, i.e. the time and place of the purchasing decision. Advertising is generally only the starting point of the purchase process, meaning that it is more appropriate for relevant environmental information to be provided via technical promotional material and at the point of sale. Indeed, media advertising is explicitly excluded from the information obligations set out in the Regulation (Recitals 17 and 18).

We therefore reject any extension of compulsory information requirements in media advertising as a disproportionate and inefficient measure. An independent and pluralistic media ecosystem depends on advertising. Any extension of information requirements for advertising would put the financing of the media at risk. There is only a limited amount of information that can practically be included in advertisements, and extending the requirements would result in advertisers choosing alternative ways to promote their products rather than through placing advertisements in the media.

We support the rules set out in the current Regulation as the most appropriate way to ensure a consumer makes an informed purchasing decision, without jeopardising the financing of the wider media ecosystem. This balanced system must be retained in this Regulation, and in the future should be reflected in other energy labelling regulations (notably the EU Car Labelling Directive 1999/94/EC).” [Advertising Association]

“In principle, the AIG supports the objective of Regulation (EC) No. 1222/2009 (hereinafter referred to as the "Regulation") to provide consumers with the relevant environmental information on tyres that enables them to make informed purchasing decisions.

As stated in the Regulation (recital 17), the time and place of a purchase decision must be taken into account. Relevant environmental information, including any graphic information (labels), is therefore made available to the consumer only at the appropriate point during the purchase decision process. This is usually provided through brochures, test reports, information on seller or manufacturer websites, and at the point of sale, rather than through media advertising.

AIG therefore rejects the notion of extending compulsory information requirements in media advertising (Question 12.3) as disproportionate and inexpedient. Mandatory information requirements in advertising significantly curtail the legitimate communication interests of the advertising economy through reducing advertisers’ ability to design content freely. Ultimately, this impacts the advertising revenue which is essential to supporting the free and independent media content that plays a vital role in public opinion-forming and behavioural change on environmental and climate issues.

This has been taken into account in the current Regulation, which includes differentiated requirements on the provision of mandatory information via appropriate means, i.e. this information must be provided at the point of sale and in technical promotional material but not in media advertising. Indeed, media advertising is explicitly excluded from the information obligations set out in the Regulation (recital 18).

The AIG believes this is the right way to ensure a consumer makes an informed purchasing decision without jeopardising the refinancing of the media ecosystem. This balanced system must be retained in this Regulation, and in the future transferred to other energy labelling regulations (notably the EU Car Labelling Directive 1999/94 / EC).

Under no circumstances should the requirement to disclose relevant environmental properties in media advertising be extended in the course of any revision of the Regulation. The Regulation’s objective of enabling consumers to make an informed purchase decision can and has been achieved through the current information requirements. Extending these requirements to media advertising would curtail the legitimate communication interests of the advertising industry and severely damage the financing of the media, without providing added value for consumers.” [Advertising Information Group]

“Incentives should be created to develop tires with less microplastic abrasion. With regard to microplastic abrasion, grading / differentiation in labelling would be important in order to provide the consumer with information for a purchase decision.” [BDEW Bundesverband der Energie- und Wasserwirtschaft] [Machine translated]

“1.The regulation should integrate a clear obligation to manufacturer (supplier) to fulfil compliance evaluation procedure, including periodical control of production (to ensure the declared values are still valid). Regulation does oblige the manufacturer to provide technical documentation on request (art.4), but it is not sufficient. In practice the documentation is often just compiled on request, sometimes it is just an mail, explaining how the declared values are defined. Such an approach (although compliant with an obligation "to provide" a technical documentation) does not contribute to reliability of tyre labelling.

2. The text of regulation may be improved for more clarity. Market surveillance authorities and even laboratories have sometimes difficulties to interpret the text in the same way (experience from the recent cross-border market surveillance campagne). Examples of points to ameliorate: content of technical documentation (should be more precise), verification procedure (not clear which values should be taken, corrected or not), alignment procedure (more accessible language is necessary, results of alignment readily available). Also the meaning "laboratory" should be clarified. Which laboratories are allowed to perform activities under regulation?” [Federal Ministry of Environment]

“EMMA and ENPA are happy to submit a short contribution as many European publications today include advertising from tyre manufacturers. We would in particular like to comment on the suggestion to extend technical information on tyre efficiency to advertising, specifically in magazines and newspapers. It is our view that a mandatory inclusion of such information would be inefficient and would in the process have negative effects on the value of advertising in both print media and digital media. Including technical information in advertising spots is ineffective for several reasons: there is very limited space to allow the inclusion of detailed information in an ad displayed in a publication, therefore a prominent space-consuming label would render the ad valueless for advertisers. Essentially, the purpose of advertising is to inform the consumer of the existence of the product. The moment when consumers decide to buy a product happens at a later stage in the purchase decision process, for instance in the sales room or in the online shop. Therefore it would make sense to include detailed technical information at that time in the process. In that connection the current directive imposes stringent information obligations. Nevertheless, the Review study on the Regulation (EC) No 1222/2009 on the labelling of tyres pointed to several weaknesses in terms of enforcement of the information obligation in chapter 7 and 8 (lack of clarity on the responsibility of dealers in terms of information obligations, difficulties for market surveillance authorities (MSAs) to inspect how information is provided, information not displayed in the shop itself as many of the tyres are in the stock rooms, consumers not aware of the labels etc.). Finally, if mandatory information in advertising is introduced, companies producing inefficient tyres will simply abstain from using traditional advertising methods in the press and will revert to other marketing techniques to the detriment of publishers.For all these reasons we would argue that core progress can only come from either greater consumer responsibility which can be encouraged through more awareness-raising on environmental issues (in that regard the press sector contributes to inform and educate citizens through its editorial content) and/or better enforcement of information obligations at the point of sales.” [EMMA & ENPA]

“Labelling the tires can be of great benefit to consumers. In order for this benefit to actually exist, the manufacturer's information must, however, be checked by the state, so that the labels do not endorse and often spoil the advertising of tire manufacturers! The last ADAC winter tire test showed numerous differences between tire markings and actually determined test results!” [Consumer] [Machine translated]

As tyres are characterised by a number of parameters which are interrelated, improving one parameter may have an adverse impact on others. Those issues are essential, especially when it comes to road safety and to the customer’s welfare. In that sense, AER supports the principle of helping consumers to make informed choices when purchasing tyres or a product containing tyres.

In the current Tyres Labelling Regulation No 1222/2009, obligations are imposed on the vehicles suppliers and vehicle distributors in article 6. The latter are, inter alia, responsible for providing end-users with information for each of the tyres offered. In addition, it is stressed that this information shall be at least included in the technical promotional material. An exception is however made in Recital 18 which outlines that this obligation does not include advertisement in radio broadcasting formats.

AER supports the current phrasing and calls for the European Commission to maintain it. Indeed, AER believes that, especially when it comes to radio, advertising is not the right place to insert detailed information. It does not and cannot provide all information necessary for the final purchase decision. The consumers’ decision is based on many other sources, such as brochures and websites, and information collected at the point of sale. Information is therefore much more useful to the consumer in dedicated information materiel, at the point of sale or online, when the decision to purchase is being performed.

AER questions the effectiveness of mandatory information in media in general, and especially on the radio. In the spirit of Better Regulation, AER would like to stress that the arguments set forward in this submission can be transposed to any piece of regulation dealing with advertising, especially with regard to radio: advertising is not the right place to insert detailed information. This argument is particularly relevant, considering the recently adopted Energy Labelling Regulation, where radio was singled-out and recognised as different from any other medium when it comes to terms and conditions / warning messages inserted in advertising.

AER can only answer in an efficient manner the question set forth by the public consultation with regard to advertising (question 12).

Question 12. Raising awareness. The study found that some consumers and organisations were not aware of tyre labelling or the benefits of investing in fuel efficient tyres. Which of the following options (if any) would you like to see included in the Regulation in order to raise awareness?

Whilst AER believes it is key to help consumers in making informed choices when purchasing tyres or a product containing tyres, it rejects the idea of extending the label’s display to advertising. Indeed, findings show that consumers, when searching for detailed information before making a purchase decision, do not seek such information in advertising. Information is perceived to be much more useful at a later stage than when advertising: through websites, in information brochures or at the point of sale – Information is more useful when the decision is taken to perform the purchase.

Besides, radio is a non-visual medium: warning requirements / terms and conditions (or labels) in advertising are particularly burdensome – when detailed messages are to be communicated in an advertisement, these are to be broadcasted in an added time-space to the latter. This increases the amount of time, hence the price, of the considered commercial message. In addition, needless to say, it lessens the commercial impact of the advertisement (a usual ad lasts for 15-40 seconds). These combined effects impact broadcast media, and radio in particular, and constitute factors that can deter advertisers away from using radio.

However, commercially funded radio can only broadcast programmes free of charge to millions of European citizens thanks to the revenues it collects by means of advertising – The only viable business model for radio nowadays and for a foreseeable future is broadcasting of free-to-air programmes. Advertising is the prerequisite to produce useful and attractive content, and to ensure radio is the most intimate medium. Radio listeners can thereby access for free to entertaining and informative content. In that sense, radio plays a fundamental role in today’s society: it is entrusted with many public interest obligations, and it is an essential actor of cultural diversity, media pluralism, access to creativity, social inclusion and disaster relief.

Inserting compulsory information / labels / terms and conditions in advertising, and especially radio advertising, does not only hinder commercially funded radios’ ability to produce content, it is also bound to miss its aim – informing the consumer. Consequently, AER calls for the status quo regarding advertising rules contained in the Tyre Labelling Regulation: i.e. no labels or terms and conditions inserted in tyre advertisements in billboards, newspapers, magazines, radio broadcasting, television and similar online formats.

Radios consist of a myriad of small and medium sized enterprises. Moreover, on-air broadcasting radios reach massive audience on a daily basis in all EU Member States: 80% of the EU population on average listens to radio for at least 2 or 3 hours per day, as shown by national audience measurement. Commercially-funded radios indeed constitute a unique network of small and medium-sized enterprises (SMEs), contributing to cultural diversity, media pluralism, access to creativity, social inclusion. They also offer free-to-air services of general interest:

- they evolve in highly competitive environments

- their programmes encompass, broadly speaking, all possible formats, from debates to music-only- As for the music broadcast, within one market, as soon as there is demand expressed, it has to be fulfilled; so, most of the musical expressions are represented

- most of them are non-politically affiliated, and certainly keep the freedom to express their opinion or to participate to the public expression of the opinions of their listeners

- their audiences are local, regional, or national

- they strive to develop on all possible platforms

- during natural, major or minor disasters, radio is one of the first tool to inform the

Public. Radio is the most intimate medium, and has been so for the past 50 years at least: it is indeed ubiquitous, mobile, simple-to-use and free-to-air. All these features enable our audience to cultivate a personal relationship with our programmes, our DJs, our hosts, and our brands. Our listeners thereby access programming they enjoy, and useful information. [The Association of European Radios]

“ETRMA would like to elaborate on the following specific questions from the Questionnaire:

ETRMA firmly believes that Tyre Labelling has encouraged tyre manufacturers to upgrade their products in a context of increased competition on the European market, and has offered the possibility for producers to benefit from product differentiation, based also on product performance quality.

The measure has the potential to increase informed choices in tyres by empowering consumers and fleet owners to focus more on a set of important, standardised performances when purchasing a tyre.

However, as it was demonstrated in the Viegand Study, “it is considered premature to revise the labelling scale requirements for both wet grip and fuel efficiency, and even noise, while efforts should be dedicated to increase awareness and market surveillance efforts„; ETRMA supports this analysis.

Moreover, the EU tyre industry has taken a proactive approach in reducing CO2 emissions through advanced technologies, while promoting road safety and other key performances at the same time. Because tyres are technologically complex products, tyre development faces a multiple set of customer-oriented performance requirements which often conflict with each other. It is worth mentioning that the performances rated on the tyre label are the results of complex engineering developments that consider background antagonistic factors.

Finally, ETRMA stresses the need for a holistic market study that looks at the current tyre distribution – in terms both of units and volume – at least in the top three classes for both rolling resistance and wet grip.

Specific comments:

Adaptation to technical progress – necessary revision to wet grip test method C1:

The experience accumulated so far by the Industry and by the MSAs on wet grip test method for passenger car tyres, indicates an opportunity and the need for further improving the accuracy of the method.

The tyre industry has engaged serious activities (1) to improve the reproducibility of the current C1 wet grip test method, keeping on average similar wet grip indexes values and ratings as current test procedure (to avoid gaps with the current regulatory framework); and (2) drive the global standardization (ISO) towards this improvement of reproducibility, while promoting harmonization in the different countries (especially EU / US / Japan).

ETRMA is recommending introducing the new revised test method at the current planned revision of the tyre label scheme.

(Q11): Information in Vehicle documentation:

We would like to stress the fact that information provided in the vehicle documentation need to be more accurate. Today - despite the fact that the text of the regulation is clear – the customer has no chance to make any choice. The accuracy of the information is important when the consumer buys a new vehicle and when he will replace his tyres (at least with the same grades or better). See an example below of what one vehicle manufacturer provides in the brochure when you have the option to select alternative sizes (=tyres):

(Q12): Raising Awareness

Member States should be encouraged to ensure that their Central Governments as well as local authorities are aware of the requirement to purchase tyres in the both highest fuel efficiency and safety class and to include these aspects in their tenders for service contracts in accordance with the requirements in tyre label regulation as well as in Annex III of the Energy Efficiency Directive1.

These measures are clearly requested under the Clean Vehicle Directive!

(Q13): Pre-sale provision of information

Dealers and Points of Sale must show the label to the customer for each tyre under consideration.

(Q14): Third party testing

Industry does not support introducing independent third party testing of the tyre performance:

- the testing requirements are clearly defined in the regulatory texts;

- the national authorities have familiarized with the testing requirements since the introduction of the label scheme;

- should regular market surveillance activities with meaningful penalties in case of found non-compliance be deployed, ETRMA is of the opinion that there is no need for introducing third party testing. In fact, this might be disproportionate to the available infrastructure of testing institutes/type approval authorities labs, while not proven as a need from effectiveness and efficiency perspectives. If only third party was allowed, this would create unacceptable delays and costs for the tyre industry, with disadvantaged also to consumer.

- the European tyre industry does not see any benefit and does not recommend to replace the current self-certification requirements .

The tyre industry acknowledges the need for, on the one hand, increased awareness and use of the tyre label by users and professional operators, and on the other hand continuous and effective market surveillance. In other words, there is still a large potential for the full establishment of the current label scheme on the EU market and its delivering on the original policy objectives of the tyre labelling regulation.

(Q15): Market Surveillance

Increased, more coordinated, more visible enforcement actions through market surveillance is needed. To do so, national authorities need a sound infrastructure, good organisation, appropriate legal powers, suitable facilities and skilled officers, benefiting from high quality training. Meaningful penalties must be established by Member States in case of non-compliance.

(Q19): Abrasion

The Report from the Commission to EP/Council (COM 2017-658/final) states that abrasion depends largely on external factors (i.e. tyre pressure, road surface, load, driving styles, etc.). While the European Tyre industry fully contributes to research on TRWP, ETRMA believes that the labelling scheme is by no means appropriate to address this complex question.

Furthermore, there is currently no harmonised and standardized test method. Industry has launched an ambitious programme that will require efforts and resources in the coming years, to assess the feasibility of establishing a standardized test method measuring tyre tread abrasion rate.

(Q21): Adding a requirement for suppliers and distributors to upload tyre information to a digital registration database:

ETRMA supports all initiatives that will positively influence/facilitate the consumer purchasing behaviour, while also strengthening market surveillance in a cost-effective way. The change in consumer behaviour will encourage increased innovation and research for high performing tyres, including the parameters for fuel efficiency and safety. However, it is essential that such a tool is thoroughly defined and assessed in terms of objectives, final users, workload, process, accessibility and data security, management costs, etc.[ETRMA] 

From inception IA Feedback:

We welcome the long-awaited evaluation1 of Regulation (EC) No 1222/2009. In order to ensure the desired prescription success, the EU regulation, which is directly applicable in all member states, urgently needs to be supplemented and substantiated in some respects.

We therefore demand in particular:

·Inclusion of further labelling requirements for advertising material

·Specification of the information requirements at the point of sale

·Specification of concrete and ambitious tasks for the market surveillance authorities

·Introduction of reporting obligations to the EU Commission

·Commitment to fraud-proof and realistic testing procedures

Based on our own market surveillance activity, regulatory compliant tire labelling is sluggish. Market surveillance takes place only marginally. There are hardly any incentives for consumer information. At the same time, the field of application of the labelling obligations has been kept very tight so far and is significantly behind the comparable labelling regulations. We also note that the market share of fuel-efficient tires is increasing only hesitantly.

There is no doubt about the raison d'être of the regulation. Legislative requirements at EU level are necessary to achieve important Community objectives. 20% to 30% of the fuel consumption of vehicles is attributable to the tires. As the EU Commission points out in recital 4 of the Regulation, the regulation can reduce tire rolling resistance significantly in terms of energy efficiency in road transport and thus reduce pollutant emissions. Information measures are included in the EU's energy efficiency and climate change policies. Information about external rolling noise enables the inclusion of harmful traffic noise in the purchase decision. Information on wet grip is used for road safety.

According to recital 2, the regulation aims to reduce total energy consumption by 20% by 2020. This common objective of significant energy savings in the area of ​​tires through informational measures by economic operators towards consumers is thus far missed. Nor does the Regulation, as it stands, take into account the need for effective monitoring of obligations on manufacturers, suppliers and distributors.

Specifically, we therefore consider the following remedial measures necessary:

 Incorporate additional labelling requirements for promotional material to improve informed consumer choices.

A clear tire marking must be used for all advertising measures. Any tire purchased or directly offered for sale is well-perceived by the end user, clearly visible, legible, uniquely identifiable to the tire and accessible to the end user. This applies to both print advertising and advertising in electronic media. The labelling requirements for tires should be based on those for passenger cars in accordance with Directive 1999/94 / EC and Recommendation 2003/217 / EC. On websites, the marking must take place immediately at the moment when concrete tire characteristics such as advantages, price or technical features are advertised, in order to prevent the labelling from being hidden on bottom and following pages. If possible - for example when advertising on the Internet - the label should be displayed at the same time.

Complete illustration of the tire label in distance selling using remote communication means.

If consumers can purchase tires directly without first seeing them, complete information must be guaranteed. This requires, in particular, an image of the label due to its recognition value and graphic underlines to enable comparisons. Therefore, the label must be displayed clearly visible in the immediate context of the sale offer the label. The labelling requirements for advertising must also be met in the case of direct purchase opportunity.

Specification of the information requirements at the point of sale

There is a need to anchor expanded information requirements at the point of sale and exhibition to ensure informed purchasing decisions.

The marking at the point of sale and exhibition must be clearly visible, legible, clearly identifiable to the tire and accessible to the end user.

Inclusion of mandatory labelling of tires on new vehicles

Vehicle manufacturers, suppliers and / or dealers must also be held accountable in order to fully exploit savings potential at an early stage and to set incentives for energy-related improvements.

 Defining concrete and ambitious tasks for market surveillance authorities to increase the efficiency of market surveillance

Authorities must be required to carry out periodic random checks on the fulfilment of legal requirements for tire marking and others. by the obligated parties in a statistically significant number. By means of supplementary laboratory tests, the content accuracy of the label must also be checked. Violations must be punished with appropriate sanctions (in particular by means of dissuasive fines). Market surveillance needs to focus on the effective enforcement of the Regulation and the removal of existing enforcement deficits. Necessarily, enforcement rules must therefore aim at a discretionary exercise aimed at improving environmental and consumer protection ("target" intending a certain behaviour rather than "can").

Introduction of annual reporting obligations to the Commission

The nature and number of their inspections must be reported by market surveillance authorities in annual reports from the EU Commission.

Fraud-proof and realistic test procedures

In view of corresponding negative experiences in the field of car type approval and the energy consumption labelling of energy-related products, we call for a review of the test procedures for fraud-proofing and realistic modelling of consumer driving behaviour. It must be ensured that the test methods for energy efficiency, wet grip and rolling noise reflect the actual consumer behaviour. Any bypasses in tests by special software or hardware or similar must be avoided by taking precautions. The test methods and standards must be able to recognize intentional or unintentional circumvention.

 Introduction of a publicly accessible product database

Similar to the requirements set out in the new EU Energy Labelling Regulation, obliged parties are required to place the required product information on the tires they have made available on the market into a European product database. The database must be free and fully accessible to public authorities, consumers and consumer protection associations.[Deutsche Umwelthilfe e.V.] [Machine translated]

”BIPAVER would like to contribute with its opinion to the Ex-post evaluation of the European Tyre Labelling Scheme in regard to a possible integration of retreaded tyres.

BIPAVER, as the representation of the independent retreading industry in Europe, generally supports the European Labelling Scheme, although retreaded tyres are at the moment not part of it. The international member associations with their national members are in favour of creating a transparent and neutral tool to inform their end user and fleet customers about the ecological, environmental and safety relevant features and properties of tyres, retreaded in particular.

The EC statement that “the cheapest, cleanest, and most secure energy is the energy that is not used at all”, extend by the ecological use of resources and the prevention of unnecessary waste absolutely corresponds with the principle of tyre retreading. It is a known fact that reusing a used tyre/casing implicitly contributes importantly to the sustainability. Reuse leads directly to less waste into the environment, as well as an important reduction of raw materials. Approximately 100 litres of crude oil and 69 kg of other materials are required to manufacture an average new truck tyre, a retread only needs 30 litres of crude oil and merely 15-20 kg of materials. Therefore, the carbon footprint diminishes from 220 kg of CO2 emission to only 39 kg, also due to the need of less energy. In addition a modern quality retread delivers comparable performances to a new tyre at a fraction of its price.

That makes the retreaded tyre per definition an ecological, economical and sustainable product which should be generally supported by the EC and its member states. Taking into consideration that the “base” of a high quality retreaded tyre is a retreadable high quality casing it is also common sense to motivate new tyre manufacturers to build appropriate tyres ensuring a possible second or third life as retread instead of distribution

“cheap one-way” products. Enabling the retreaded commercial tyre to “visually” prove its capabilities by integrating into the EC’s labelling schema will promote its market acceptance and competitiveness. Therefore BIPAVER, in cooperation with ETRMA/ETRTO, proactively works to find an adequate system for the integration. With the RETRYE project, an EU co-funded analysis about the impact of retreading parameters to Rolling Resistance, Wet Grip and Noise, BIPAVER and the especially created consortium gained fundamental supporting know-how. Due to the aftermarket share of 35- 40% in Europe retreaded truck and bus tyres have an important contribution in the segment of commercial vehicles providing a huge positive impact and added value to the circular economy. The constraints of an integration are the vast diversity of possible products combinations in a retreading plant/workshop due to the combinations of tyre sizes, casings and tread pattern and the typical SME character of the independent retreading industry. Unlike a type homologated new tyre, million times produced the same way, it is the individuality of each retreaded tyre that makes it so difficult to find an appropriate labelling method. Accurate, reliable and repeatable in relation to the required label performance parameters but affordable and economically feasible for the SME retreader. Not being a threat but certainly a challenge for the complete retreading business, new tyre industry driven or independent, BIPAVER constructively participates in the solution process. Underlining the fact that the retreaded tyres, as an ecological, environment friendly and sustainable product deserves more support and attention than actually given in society and politics.

For further consultation regarding this subject we recommend the EY study about “The socio-economic impact of truck tyre retreading in Europe – The circular economy of tyres in danger”, from October 2016. The document is available as download under http://www.etrma.org/library-2  [BIPAVER]



Annex 3: Who is affected and how?

1.Practical implications of the initiative

The revised Tyre Labelling Regulation will include the following new measures:

For tyre manufacturers:

·to re-adjust the tyre label classes for both fuel efficiency, wet grip and external rolling noise.

·to register all new tyre models placed on the market in a product registration database and at the same time make electronic versions of the label, product information sheet and technical documentation available in the database.

·to test tyres in laboratories approved under the type-approval process in the General Safety Regulation and use the results for establishing of the label performance parameters.

·on a voluntary basis to include icons for snow and ice performance on the label.

·to provide along with the label a product information sheet (as also provided for energy related products covered by the Framework Energy Labelling Regulation).

For suppliers:

·to show the label when tyres are offered for sale online.

For vehicle dealers:

·to provide the label for tyres on new vehicles offered for sale and in case of purchase through leasing contracts or as part of a fleet solution.

Member States:

·to carry out information campaigns in cooperation with European Commission.

·to give higher priority to joint enforcement actions.

The requirements described above will result in substantial benefits for citizens, society, manufacturers and wholesalers/retailers. Citizens will receive benefits in the form of saved fuel (lower fuel costs) and increased safety and health. Society will receive high benefits in terms of substantial reductions of CO2 emissions and reduced costs related to accidents and noise pollution. In addition, manufacturer and wholesalers/retailers will benefit from increased turnover and employment.

The requirements will also increase administrative burdens for manufacturers, dealers (of tyres and vehicles), Member States and the European Commission. The estimated administrative costs are described in more details below the summary tables.



2.Summary of costs and benefits

Overview of benefits total for all preferred options. All benefits are direct benefits.

I. Overview of Benefits (total for all provisions) – Preferred Option

Description

Amount

Comments

Reduction of CO2 emissions

10 MT per year in 2030

Society receives the benefits

Increased safety (reduction of fatalities)

€737 million per year in 2030

Society receives the benefits, but also citizens

End-user net savings

€2.2 billion in 2030

Citizens (and end-users) receive the benefits in terms of reduced fuel costs

Increased employment

235 673 more jobs in 2030

Manufacturers, wholesalers and retailers will have this benefit

Increased turnover

€ 8.7 billion in 2030

Manufacturers, wholesalers and retailers will have this benefit



Overview of administrative costs (all costs are direct costs) compared to baseline. Numbers are in million EUR. Where no figures are mentioned the extra cost are considered insignificant. In addition “n.a.” indicates that it has not been possible to estimate the costs.

II. Overview of costs – Preferred option

Options

Manufacturers

Dealers

Member States

EU/Commission

Information campaigns

10

(only once)

2

(only once)

Joint enforcement actions

0.02 per year

0.5-1 per year

Mandate to revise testing methods 5

n.a.

n.a.

Online labelling

3

(only once)

Labelling of tyres delivered with vehicles at all times 6

50 per year 7

Provision of label for C3 tyres 8

6 per year 9

Inclusion of snow and ice performance

Re-adjustment of the label

40

(only once) 10

30

(only once)

Tyre registration database

0.25 per year

0.1 (only once) and 0.01 per year

Technical documentation and product fiche content

120 per year 11

Amendment of current Annex V on test methods for wet grip of C1 tyres

Amendment of current Annex IVa on laboratory alignment procedure for the RRC

Extension of type approval procedure

0.65 per year

Total

127 per year

40 only once

50 per year

30 only once

0.02 per year

13 (only once)

0.5-1 (per year)

2.1 (only once)

3.Estimation of administrative costs 

Administrative and compliance costs have been estimated for each of the measures included in the preferred option. Administrative costs are defined as “the cost incurred by enterprises, the voluntary sector, public authorities and citizens in meeting legal obligation to provide information on their action or production, either to public authorities or to private parties 12 ”.

Information campaigns (EU/national)

It is very difficult to estimate the costs for information campaigns EU-wide. The costs will depend of the type of campaign and the possibilities for cooperation with manufacturers and dealers. In practice the costs will also depend on the available budget in the individual Member States. For this purpose, it is estimated that the average Member State cost for information campaigns will be €0.3 million corresponding to €8.4 million in EU-28 (rounded to 10 million in the table above). Member States’ costs could eventually be reduced if the Commission support this action through a funding programme.

Joint enforcement actions

This measure includes activities to foster cooperation as well as exchange of information between MSAs to extend and improve market surveillance and enforcement. The measure will require more involvement from Member States and allocation of additional resources for market surveillances and related activities. The Commission will take an increased role in the market surveillance for tyres by supporting of activities to enhance EU level cooperation. It is estimated that all Member States allocate three working days per year for market surveillance for tyres in addition to the current allocation. This will correspond to around €0.020 million per year in EU-28 13 . In addition the Commission will contribute with around €0.5-1 million per year.

Mandate to revise the testing method

The Commission will draft and submit a standardisation request (mandate) to initiate development of more reliable, accurate, repeatable and reproducible test methods for the tyre performance parameters on the label and development of test methods related to mileage and abrasion.

The administrative costs for drafting and submission of the mandate will primarily be on the Commission. But a wide group of interested stakeholder (including social partners, consumers, SMEs, industry associations and EU Member States) will be involved through a consultation process before the mandate is finalized. Also, the European Standardisation Organisations (ESOs) will be involved as they have the right to refuse a mandate if they do not think the standard can be produced. Even though various stakeholders are involved the working hours per stakeholder is relatively limited and no stakeholders (except the ESOs) are obliged to contribute. The costs for the mandate will appear only once and are considered as insignificant.

However, the development of the standard(s) will require a considerable amount of work in the relevant European standardisation organisations and among various stakeholders involved in European standardisation such as national standardisation bodies, Small Business Standards 14 (SBS), Environmental NGOs (ECOS 15 ), consumer interest groups (ANEC 16 ), interested manufacturers and Member States.

It is not possible to quantify the costs because the work to be carried out is not yet known in detail. The administrative burden from some of the stakeholders will be limited because their participation in the standardisation work is funded by the European Commission Union and EFTA (SBS, ECOS and ANEC). Traditionally industry plays an important role in the development of standards. However, participation in standardisation work is voluntary and no manufacturer is obliged to bear the costs. Online labelling

This measure is not expected to give rise to significant implementation costs. The costs of producing graphics and other electronic files required to convey the necessary label are already covered when complying with the existing regulation. The proposed requirement to show the label when products are offered for sale online is expected to require very little extra work for dealers. Due to the product registration database dealers will have easy access to the necessary electronic files.

For Member State MSAs, the Impact Assessment with regard to labelling of energy-related products on the Internet 17 estimates that there could be transitional costs to add new capabilities or to obtain shared use of services from other agencies charged with on-line market surveillance. These costs will vary by country; they are provisionally estimated at €0.1 million per Member State 18 corresponding to €2.8 million in EU-28 (rounded to 3 million in the table above).

Labelling of tyres delivered with vehicles at all times (new tyres on new vehicles) 19  

Today, vehicle suppliers and dealers are only obliged to inform end-users about the tyre performance parameters of the tyre on a new vehicle for sale in case the end-user can choose between different tyres to be fitted to the new vehicle. By this measure the obligation is extended to cover all new tyres on new vehicles for sale. In addition, leasing companies will be responsible for providing the relevant tyre label information and the label itself to the lessees of new vehicles. Tyres provided with vehicles will primarily be tyres delivered as OEM tyres. There will be no extra costs for the manufacturers of OEM C1 and C2 tyres because they are already obliged to provide the label information and the label for all tyres in the scope of the regulation (there is no exemption for OEM tyres). Suppliers of C3 tyres are only obliged to provide the label information not the label itself. Therefore, the measure will result in some increased costs for the manufacturers of OEM C3 tyres 20 .

There will be some additional costs for vehicle dealers and leasing companies because they will be obliged to provide the end-users with the label for the tyres on the vehicle for sale or available for leasing (for new vehicles). The additional time spend for delivering of this information is considered marginal compared to the time spent delivering other information in connection with sale or leasing of vehicles. If vehicle sellers and lessors for each vehicle spend 5 minutes on the provision of the tyre label information and the label the total extra costs will be around €50 million per year 21 . This estimate is based on the number of OEM tyres (C1, C2 and C3) sold per year and the number of tyres per vehicle. It is not possible to divide the costs between vehicle sellers and leasing companies due to lack of data. Often the same company provides both services.

Provision of label for C3 tyres

In the TLR, the label information (information about the tyre performance parameters) should be delivered for C3 tyres but not the actual printed label. Implementation of this measure will lead to extra costs for manufacturers of C3 tyres for printing the label but not for establishment of the tyre performance parameters. The costs for printing the label are estimated to be €0.3 per tyre corresponding to around €6 million per year in EU28 (sale of C3 tyres is 18.8 million including OEM tyres). In practice C3 tyres are sold in batches of up to 10 tyres. If only one printed label is printed per batch the costs could be reduced significantly. This estimation covers both sale of replacement tyres and sale of OEM tyres. The replacement sale also includes C3 tyres provided for fleet solutions.

Snow and ice performance on the label

The obligation to show the snow performance (3-PMSF-logo) and/or ice performance on the label is voluntary, so that only tyres designed for winter conditions could bear the logos. The 3-PMSF logo is already used today on the side of the tyre thread for snow tyres that meet the minimum level of performance on snow (braking and traction) determined in the UNECE Regulation 117 22 . The test cost required for use of the 3-PMSF logo varies between € 6.400 – 10.000 depending and the tyre type. But because the logo is already widely used the extra costs for manufacturers are considered being low.

While safety is of a major concern for the consumers the manufacturers providing safe tyres for winter conditions should be able to pass their extra costs for application of the logo on to consumers. There will be no additional costs for the dealers.

Re-adjustment of the label

The current label is no longer accurate because of the GSR banning bottom classes and the fact that for wet grip the current label has an empty class in the middle of the A-G range.

This measure does not involve a full “rescaling” of the label as envisaged under the Energy Labelling Framework Regulation for products where the top class was overpopulated and A+, A++ and A+++ classes had to be added. It would be similar to the situation where a more stringent tier of requirements is introduced after a certain date in current energy labelling regulations. When this happens, suppliers have to print out the new label and fix it to the product. There is no requirement to change the labels on products that are already placed on the market.

The cost for manufacturers to print the new labels will be around €42 million (rounded to €40 million in the table above) for replacement sale of C1 and C2 tyres 23 at a cost of €0.3 to print the label 24 .

Tyre registration database

In the Impact Assessment accompanying the framework Energy Labelling Regulation it is estimated that the time required for suppliers to register data in the product registration database will be 2 hours per product taking into account that the manufacturers are already obliged to assemble all the required information and documentation and to make this information available to authorities on request. With around 4.000 new models 25 of C1, C2 and C3 tyres placed on the market per year the estimated costs for registration in the product database will be around € 0.2 million per year. For labour costs an average tariff of EU-28 of 25.4 Euro/hour 26 is used. Training of staff to become acquainted with the system is a one-time investment and not considered significant.

The burden for Member States’ MSAs to obtain documents is significantly reduced by this measure. The extra costs for the Commission will be low because it is already obliged to establish and maintain a database for energy related products under the Energy Labelling framework Regulation. It is foreseen that tyres will be included in this database. In the Impact Assessment accompanying the framework energy labelling regulation it is estimated that the cost of establishment of a database for 30 product groups will be €3 million in investment and € 300.000 annual in maintenance costs. It is estimated that the costs for extending the database to tyres will be 1/30 of this amount corresponding to €100.000 for establishment and €10.000 per year for maintaining the database.

Technical documentation and product fiche content

Clarification of the required content of the technical documentation will not cause additional costs because the manufacturers already have to draft technical documentation (but the content is not defined). It is considered that a clear description of the required content will make it easier for the manufacturers to compile the documentation, however the savings will not be significant. In addition, it will probably be easier for Member States to evaluate the received documentation and Member States’ costs for market surveillance could be reduced. It is however assumed that they spend the freed-up time on other market surveillance activities instead thereby contributing to higher compliance rates.

According to the current TLR manufacturers are not obliged to provide a product information sheet. If the manufacturers get an obligation for provision of a product information sheet their costs will increase. The costs are assumed to correspond to the cost of printing of an additional label i.e. €0.3 per sheet. It is assumed that the information that should be included in the product information sheet is already available. It could for instance be the fuel efficiency expressed as the measured value (only the fuel efficiency performance class is on the label). If the manufacturer provides one sheet per tyre sold the extra costs will be €116 million per year (rounded to 120 in the table above). In principle it could be enough to provide a product information sheet per batch of tyre (typically 4 tyres). In this case the additional costs could be reduced to €30 million per year.

There will be no extra costs for dealers or Member States.

Amendment of current Annex V on test methods for wet grip of C1 tyres

For C1 tyres it is proposed to change the wet grip measurement method in the TLR to ISO 23671:2015. The ISO standard to some extent builds upon the ATSM standards applied in the current TLR. In addition, a reference tyre is used to limit the variability in line with the procedure in the current methodology. Against this background assumed that there will be only minor extra testing costs related to the amendment.

However, some initial extra cost could probably be expected for some testing laboratories.

Amendment of Annex IV on laboratory alignment procedure for the measurements of Rolling Resistance Coefficient (RRC)

These measures could require some extra costs for testing laboratories to implement new testing routines and calculation methods. However, the methods have been developed in cooperation with manufacturers and testing laboratories and it is considered that the procedures are already known and could be implemented with only marginal extra costs. There will be no extra costs for Member States, dealers or the Commission.

Mandatory and independent third-party testing (testing in approved laboratories)

It is proposed that tests carried out on approved laboratories according to the type-approval process in the General safety Regulation 27 should also be used for energy labelling of tyres. The extra costs on manufacturers could be low because tyres must already be tested on the approved laboratories according to the type-approval process in the General safety Regulation. However, it is assumed that more tests are required per product family group to establish the tyre performance parameters with the accuracy needed for labelling. It is assumed that the manufactures must carry out additional tests for 20% of new models on the market each year. This will correspond to extra costs for the manufactures of €3.5 million per year 28 (rounded to €4 million in the table above).

For Member States, the use of approved testing laboratories is expected to reduce the need for verification tests. In principle few Member States are currently conducting testing, so there will be few savings, but the need to increase the market surveillance budget in Member States is less.

Annex 4: Analytical methods

The quantitative modelling in Excel files for the Impact Assessment was prepared by the external consultant, Viegand Maagøe A/S. The calculations were prepared in several Excel files with data gathered from European databases, the tyre industry, scientific articles and other studies. This Annex describes in detail the data and assumptions the models are based on.

1.General assumptions

-The development of RRC and WG are based on expected market shares of each label class in the future, which differs in each scenario.

-vehicles with C1 tyres, fleet consists of 41% diesel and 59% petrol (ACEA 29 , 2017)

-vehicles with C2 tyres, fleet consists of 88% diesel and 12% petrol (ACEA, 2017)

-vehicles with C3 tyres, fleet consist of 96% diesel and 4% petrol (ACEA, 2017) 30

-vehicles with C1 tyres are driven 13,500 km per year on average

-vehicles with C2 tyres are driven 21,000 km per year on average

-vehicles with C3 tyres are driven 57,500 km per year on average

-EU HICP (Harmonised Index of Consumer Prices) rates are used to convert all prices to 2017 fixed prices: http://ec.europa.eu/eurostat/tgm/table.do?tab=table&init=1&language=en&pcode=tec00118&plugin=1

-Vehicle fleet data was obtained from ACEA: http://www.acea.be/statistics/article/Report-Vehicles-in-Use  

-Fuel prices were obtained from: https://www.eea.europa.eu/data-and-maps/indicators/fuel-prices-and-taxes/assessment-7  

-Road safety and accident data was obtained from: https://ec.europa.eu/transport/road_safety/specialist/statistics_en#  

-Road safety costs was obtained from: https://ec.europa.eu/transport/road_safety/specialist/knowledge/measures/monetary_valuation_of_road_safety_en and http://heatco.ier.uni-stuttgart.de/HEATCO_D5.pdf  



2.Information effect

The methodology to assess effect of label information on purchase behaviour is based on the article “The Impact of Sustainability Information on Consumer Decision Making” 31 . In that article over 40,000 online purchases were assessed, and it was found that certain types of sustainability information had a significant impact on purchase intentions. Direct users—those who intentionally sought out sustainability information—were most strongly influenced by sustainability information, with an average purchase intention rate increase of 1.15 percentage points for each point increase in overall product score, reported on a zero to ten scale. However, sustainability information had, on average, no impact on non-direct users.

-Direct users were assumed to be those finding the label parameter in question “very important” according to the 2016 consumer survey.

oFind fuel efficiency “very important”: 34%

oFind wet grip “Very important”: 62%

oFind external rolling noise “very important”: 21%

-Also, for each scenario it was considered how many already end-users the label in their purchasing decision, and only the additional influenced end-users were assumed to be impacted.

3.Stock model assumption

Sales figures were received from the industry organisation ETRMA 32 back to 2003 and backed up by sales data from the market research organisation GfK 33 . The sales data are seen in the table below.

Table 1: Tyre sales in million units

Sales in millions

2006

2008

2010

2012

2014

2016

2017

C1 replacement

231.46

224.30

249.72

226.42

236.60

248.10

253.31

C1 OEM

59.09

77.61

74.64

71.12

73.80

79.47

80.06

C2 replacement

25.72

24.92

27.75

25.16

26.29

27.57

28.15

C2 OEM

4.96

7.51

4.98

4.98

5.35

6.68

6.72

C3 replacement

12.76

11.42

11.56

9.61

12.19

13.97

14.88

C3 OEM

3.35

4.74

2.72

3.33

3.20

3.65

3.94

Total

337.33

350.50

371.36

340.62

357.44

379.44

387.06

Source: ETRMA and GfK

Average tyre lifespans were based on assumptions of the expected tyre life in km and km driven per year for each vehicle type as shown in the table below. The assumptions were primarily based on background data from the Ecodesign Impact Accounting 34 .

Table 2: Assumption on tyre lifespans and mileage

Tyre type

Expected life in km

Average distance driven per year, km

Average tyre lifespan, years

C1

56 700

13 500

4.2

C2

71 400

21 000

3.4

C3

200 000

57 500

3.5

Source: Ecodesign Impact Accounting background calculation model, 2017.

Further assumptions used in the stock model:

Table 3: Further assumptions made in the stock model

C1 share out of C1 + C2 sales

90%

Share of C1 OEM

21% of C1 replacement market

Share of C2 OEM

25% of C2 replacement market

Share of C3 OEM

25% of C3 replacement market

Number of tyres per vehicle in stock – C1 (Calculated)

5.7 (approx. 1/3 have two sets of tyres)

Number of tyres per vehicle in stock – C2 (Calculated)

4.1 (approx. 2,5% have two sets of tyres)

Number of tyres per vehicle in stock – C3 (Calculated)

12.7 (different number of wheels on different trucks/busses)

Sources: ETRMA, Ecodesign Impact Accounting

4.BAU Scenario assumptions

The following data and assumptions were used in the modelling of the current tyre labelling framework:

-The OEM performance level for RRC, WG and Noise was assumed equal to the no-label performance levels (based on 2008 Impact Assessment). I.e. only the replacement tyres are affected by the label (because very few users are actually offered a choice between different tyres when purchasing a new car, and are thus not shown the label / label values)

-2012-2017 based on real-life data from TOL (<1% difference from GfK data) giving market distributions for rolling resistance, wet grip and noise (see tables below)

-From 2004 to 2012: Linear interpolation from 2008 Impact Assessment estimated performance in 2004 to actual data in 2012.

The review study showed a low degree of market surveillance, and the few tests that have been performed show a high rate of non-compliance. The preliminary results from the MSTyr15 project 35 showed that the non-compliance was at the magnitude of 15%. This low compliance rate is taken into account in the BAU Scenario, and an assumption regarding the magnitude of non-compliance of two classes was made:

-15% of tyres on the market do not live up to the declared performance.

-The non-compliant tyres are on average 2 classes lower than stated on the label.

Table 4: Current label Rolling resistance market shares for C1 tyres

RRC class

A

B

C

E

F

G

 Market

average

Market average with non-compliance

Class average

6.3

7.4

8.7

10

11.5

12.4

2012

0%

3%

29%

42%

24%

1%

9.92

10.28

2013

1%

6%

36%

39%

17%

1%

9.64

10.01

2014

0%

5%

36%

43%

15%

1%

9.63

10.00

2015

0%

5%

38%

42%

14%

0%

9.57

9.93

2016

0%

5%

34%

43%

17%

1%

9.68

10.05

2017

0%

6%

37%

42%

15%

1%

9.59

9.96

Source: Data from TOL (Tyres On-Line, Germany).

Table 5: Current label Rolling resistance market shares for C2 tyres

RRC class

A

B

C

E

F

G

Market

average

Market average with non-compliance

Class average

5.3

6.4

7.7

8.9

10.2

10.8

2012

0%

1%

26%

56%

15%

2%

8.80

9.13

2013

0%

4%

20%

44%

28%

3%

8.97

9.30

2014

0%

6%

25%

41%

25%

2%

8.82

9.15

2015

0%

5%

29%

40%

24%

1%

8.77

9.10

2016

0%

4%

25%

42%

27%

3%

8.92

9.25

2017

0%

4%

28%

41%

25%

2%

8.83

9.16

Source: Data from TOL (Tyres On-Line, Germany).

Table 6: Current label Rolling resistance market shares for C3 tyres

RRC class

A

B

C

D

E

F

Market

average

Market average with non-compliance

Class average

3.8

4.7

5.7

6.7

7.7

8.6

2012

2%

10%

33%

37%

16%

3%

6.07

6.43

2013

2%

11%

33%

37%

15%

2%

6.34

6.70

2014

1%

10%

36%

36%

14%

2%

6.30

6.66

2015

1%

7%

29%

38%

20%

5%

6.28

6.64

2016

1%

7%

29%

40%

18%

4%

6.54

6.90

2017

0%

16%

44%

26%

13%

1%

6.50

6.86

Source: Data from TOL (Tyres On-Line, Germany).

The rolling resistance values from 2017 to 2030 in the BAU Scenario was forecasted based on historic data on market distributions of label classes. The forecasts were made for the years 2025 and 2030, and a linear interpolation of average market values was used in between.

Table 7: Forecast of fuel efficiency label distribution in the BAU scenario for C1 tyres

RRC class

A

B

C

E

F

G

Market

average

Market average with non-compliance

Class average

5.3

6.4

7.7

8.9

10.2

10.8

2025

3%

11%

45%

40%

1%

0%

9.03

9.40

2030

3%

14%

48%

35%

0%

0%

8.90

9.27

Source: estimated based on historical development

Table 8: Forecast of fuel efficiency label distribution in the BAU scenario for C2 tyres

RRC class

A

B

C

E

F

G

Market

average

Market average with non-compliance

Class average

5.3

6.4

7.7

8.9

10.2

10.8

2025

0%

6%

40%

54%

1%

0%

8.37

8.70

2030

0%

6%

43%

50%

1%

0%

8.25

8.58

Source: estimated based on historical development

Table 9: Forecast of fuel efficiency label distribution in the BAU scenario for C3 tyres

RRC class

A

B

C

D

E

F

Market

average

Market average with non-compliance

Class average

3.8

4.7

5.7

6.7

7.7

8.6

2025

2%

8%

33%

54%

3%

0%

6.18

6.54

2030

2%

9%

34%

54%

1%

0%

6.13

6.49

Source: estimated based on historical development

The wet grip market averages and forecasts were calculated in a similar way:

Table 10: Current label Wet grip market shares for C1 tyres

Wet grip class

A

B

C

E

F

Market

average

Market average with non-compliance

Class average

1.6

1.47

1.32

1.17

1.04

2012

9%

24%

55%

8%

3%

1.36

1.32

2013

15%

31%

44%

7%

3%

1.39

1.35

2014

17%

31%

43%

7%

2%

1.40

1.35

2015

19%

33%

41%

7%

1%

1.41

1.36

2016

18%

31%

41%

9%

2%

1.40

1.35

2017

20%

32%

38%

7%

2%

1.41

1.36

Source: Data from TOL (Tyres On-Line, Germany).

Table 11: Current label Wet grip market shares for C2 tyres

Wet grip class

A

B

C

E

F

Market

average

Market average with non-compliance

Class average

1.45

1.32

1.17

1.02

0.9

2012

2%

29%

61%

8%

1%

1.21

1.16

2013

3%

27%

56%

13%

1%

1.20

1.15

2014

5%

31%

49%

15%

1%

1.21

1.16

2015

6%

32%

45%

17%

0%

1.21

1.16

2016

6%

30%

43%

20%

1%

1.20

1.16

2017

8%

34%

38%

18%

1%

1.22

1.17

Source: Data from TOL (Tyres On-Line, Germany).



Table 12: Current label Wet grip market shares for C3 tyres

Wet grip class

A

B

C

D

E

Market

average

Market average with non-compliance

Class average

1.3

1.14

1

0.85

0.7

2012

11%

65%

21%

3%

0%

1.12

1.07

2013

4%

46%

47%

2%

0%

1.07

1.03

2014

5%

47%

45%

3%

0%

1.08

1.03

2015

6%

53%

38%

3%

0%

1.09

1.04

2016

2%

39%

54%

4%

0%

1.06

1.01

2017

3%

42%

51%

4%

0%

1.06

1.02

Source: Data from TOL (Tyres On-Line, Germany).

Table 13: Forecast of wet grip label distribution in the BAU scenario for C1 tyres

Wet grip class

A

B

C

E

F

Market

average

Market average with non-compliance

Class average

1.6

1.44

1.3

1.14

1

2025

35%

30%

30%

4%

1%

1.44

1.39

2030

40%

31%

25%

3%

1%

1.46

1.41

Source: estimated based on historical development

Table 14: Forecast of wet grip label distribution in the BAU scenario for C2 tyres

Wet grip class

A

B

C

E

F

Market

average

Market average with non-compliance

Class average

1.45

1.3

1.14

1.0

0.9

2025

10%

45%

37%

8%

0%

1.23

1.19

2030

12%

47%

34%

7%

0%

1.24

1.20

Source: estimated based on historical development

Table 15: Forecast of wet grip label distribution in the BAU scenario for C3 tyres

Wet grip class

A

B

C

D

E

F

Market

average

Market average with non-compliance

Class average

1.3

1.14

1

0.85

0.7

0.6

2025

5%

47%

44%

4%

0%

0%

1.07

1.03

2030

5%

49%

42%

4%

0%

0%

1.08

1.04

Source: estimated based on historical development

The noise levels were calculated based on average measured values, and likewise forecasted to 2030 based on historical data:

Table 16: Average market noise levels in Current label scenario

Year

C1

C2

C3

2012

70.81

71.93

71.78

2013

70.67

71.98

72.19

2014

70.86

72.07

72.05

2015

70.80

72.03

71.71

2016

70.84

72.15

71.71

2017

70.73

71.97

71.69

Source: Data from TOL (Tyres On-Line, Germany).



Table 17: Forecast of average market noise levels in BAU scenario

Year

C1

C2

C3

2025

70.59

72.02

71.55

2030

70.50

72.05

71.46

Source: estimated based on historical development

5.Policy Option 2 scenario assumptions

-The same development of performance as BAU until 2017.

-Non-legislative scenario, which means the scope will not change, and hence it will only affect replacement tyres.

-Information campaigns will affect the choice only for end-users who find the parameter in question important, and who were not aware of the label beforehand. These shares were based on a consumers survey from 2016:

oNot aware of the label: 59%

§Assumed that the “aware” share go up from 41% to 60% increase 19%.

§For replacement tyres only (OEM not included).

-OEM tyres will stay on the BAU level.

-The non-compliance will decrease slightly, to 14% (with 2 classes lower than stated on the label) due to the concerted market surveillance activities

The rolling resistance values from 2017 to 2030 in the policy option 2 scenario is the same as for the BAU scenario, however, due to the information and increased market surveillance effects, the RRC changes. The same is true for Wet grip and noise levels.

6.Policy Option 3 Scenario assumptions

Inclusion of snow and ice indicators on the label:

-Assume that including the 3-PMSF logo on the label will cause fewer and less severe accidents on snowy roads.

-Assume that the ice indicator on the label will cause fewer and less severe accidents on icy roads, since the ice grip performance of the tyre is oppositely correlated to the its wet grip performance, and this will inform customers to buy the correct tyres for the icy conditions.

Require all OEM tyres to be labelled / information to be given to the end-user:

-Assume that OEM tyres will improve in addition to the improvement of replacement tyres.

oBy 2025 they will follow the same development as replacement tyres.

Alignment with the Energy Labelling Framework Regulation (online labelling, registration database etc.):

-Assume that online labelling will affect the purchase for users buying online.

-The effect for each parameter affects those who found the parameter “very important” in the 2016 consumer survey, and who purchase online and / or would use the registration database to search for information:

oShare that would use the database to search for information: 51% 36 .

oExpecting to purchase online: 21%.

§Average of 21% and 51% = 36%.

-Re-adjustment of the label for wet grip and rolling resistance:

oAdding a new class “A” on top means a few percent of users will buy these improved tyres (see tables below).

-Increased market surveillance and information and extension of the type approval process:

oThe non-compliance rate will fall to 7% (from 15% in BAU).

The rolling resistance values from 2017 to 2030 in the policy option 3 scenario is based on a re-adjustment the label with a new class A on top of the scale. Furthermore, the mandatory labelling of OEM tyres means that they will reach the same performance level as replacement tyres by 2025. The forecast of rolling resistance and wet grip levels for both OEM and replacement tyres are shown in the tables below. Note that these values are then affected by the additional information requirements and the changes in non-compliance.

Table 18: Forecast of fuel efficiency label distribution in the PO3 scenario for C1 tyres

RRC class

New

A

B

C

D

E

 Market

average

Class average

5.1

6.3

7.4

8.7

10

11.5

2025

1%

4%

10%

44%

40%

1%

8.99

2030

2%

4%

13%

47%

34%

0%

8.81

Source: estimated based on historical development

Table 19: Forecast of fuel efficiency label distribution in the BAU scenario for C2 tyres

RRC class

New

A

B

C

D

E

Market

average

Class average

4.1

5.3

6.4

7.7

8.9

10.2

2025

0%

1%

5%

39%

54%

1%

8.28

2030

0%

2%

5%

42%

50%

1%

8.21

Source: estimated based on historical development

Table 20: Forecast of fuel efficiency label distribution in the BAU scenario for C3 tyres

RRC class

New

A

B

C

D

E

Market

average

Class average

2.8

3.8

4.7

5.7

6.7

7.7

2025

0%

1%

8%

30%

57%

4%

6.25

2030

1%

1%

8%

32%

56%

2%

6.17

Source: estimated based on historical development

Table 21: Forecast of wet grip label distribution in the PO3scenario for C1 tyres

Wet grip class

New A

A

B

C

D

E

Market

average

Class average

1.71

1.6

1.44

1.3

1.14

1.0

2025

5%

34%

28%

29%

3%

1%

1.45

2030

10%

38%

29%

20%

2%

1%

1.49

Source: estimated based on historical development

Table 22: Forecast of wet grip label distribution in the PO3 scenario for C2 tyres

Wet grip class

New A

A

B

C

D

E

Market

average

Class average

1.56

1.45

1.3

1.14

1.0

0.85

2025

3%

10%

44%

36%

7%

0%

1.24

2030

6%

11%

45%

32%

6%

0%

1.26

Source: estimated based on historical development

Table 23: Forecast of wet grip label distribution in the PO3 scenario for C3 tyres

Wet grip class

A+

A

B

C

D

E

Market

average

Class average

1.41

1.3

1.14

1.0

0.85

0.7

2025

2%

5%

46%

45%

2%

0%

1.08

2030

4%

3%

51%

40%

2%

0%

1.09

Source: estimated based on historical development

7.Policy Option 4 scenario assumptions

Policy option 4 is a combination of policy option 2 and policy option 3, and the quantification is thus based on a model including all of the impacts form the two scenarios.

The rolling resistance values from 2017 to 2030 in the policy option 4 scenario is the same as for the policy option 2 scenario, however, due to the information and increased market surveillance effects, the RRC changes. The same is true for wet grip and noise levels.

8.Effect of Rolling resistance on fuel consumption 

-Based on the calculations from the official “fuel savings calculator” 37 .

-Fuel savings calculator is based on measurements performed by IDIADA for the European Commission 38 .

-In the calculations a share of 50% urban driving and 50% non-urban driving was assumed.

The following formula correlating fuels savings (in %) and change in rolling resistance from the basis of the fuel savings calculator, and is the one used in this study:

Where RRCold in this case refers to BAU1 (actual data), RRCnew refers to BAU0 rolling resistance and K is a factor calculated by IDIADA based on actual measurements of cars driven on a test lane with different tyres. The K factor depends on the type of tyre (and thus vehicle), the share of urban and non-urban driving and whether the rolling resistance is increasing or decreasing. K-factors are shown in  Table 24 . In the scenario calculations 50/50 share of urban and non-urban driving was assumed.

Table 24: K-factors used in calculation of fuel consumption from RRC development

RRC development

Road type

C1

C2

C3

Increase in RRC

Urban

0.104

0.098

0.095

Non-urban

0.158

0.118

0.112

Decrease in RRC

Urban

0.145

0.109

0.106

Non-urban

0.183

0.125

0.118

Source: IDIADA background report on the fuel savings calculator

9.Effect of Wet grip on safety

The societal costs related to a change in tyre wet grip rating were estimated using a methodology from a 2014 study by TNO on Potentials benefits of Triple-A tyres in the Netherlands 39 . The general approach is shown in the figure below. It shows a relation between the grip level of the tyre, the braking distance and the resulting impact speed of an accident. The degree of personal injury (fatal, severe, slight) can be described as a function of impact speed. Consequently, the distribution between fatal, severe and slightly injured people can be translated into societal costs. 

Figure 1 Methodology flow diagram 40

Data and assumptions

-Data was gathered through a number of sources but are all based on data from the CARE database - Community database on Accidents on the Roads in Europe. Direct sources are referenced in footnote when relevant.

-Road accident fatalities 41 are divided into mode of transportation:

oPassenger cars (C1 tyres)

oLorries <3.5 tons (C2 tyres)

oHeavy goods vehicles >3.5 tons (C3 tyres)

oBuses (C3 tyres)

oPedestrians and bicycles (assumed to be inflicted by vehicles)

·Number of injuries is not distributed by mode of transportation 42 and is therefore assumed to be the same as for fatalities. The distribution between severe and slight injuries is based on severe injuries reported in 2014 43 :

o10% Severely injured

o90% slightly injured

·The distribution of accidents by road type is divided into the following based on 2015 numbers 44 :

oUrban – 37,3%

oRural – 55,0%

oMotorway – 7,8%

oThe distribution is assumed to be the same through the whole modelling period.

·Projections of fatalities and injuries in the baseline up to 2030 are based on historic trends.

Wet grip

Wet grip refers to the capacity of a tyre to brake on a wet road. The wet grip is applicable to all tyre types (C1, C2, C3), and is determined based on the wet grip index (G) according to the A-G scale specified in Table 25 . The value of the wet grip index should be calculated based on either the average deceleration in m/s2 or the peak brake force coefficient, which is unitless, and compared to a Standard Reference Test Tyre (SRTT).

Table 25: G limit values for wet grip scales of the three tyre types C1, C2 and C3

C1 tyres

C2 tyres

C3 tyres

G

Wet grip class

G

Wet grip class

G

Wet grip class

1,55 ≤ G

A

1,40 ≤ G

A

1,25 ≤ G

A

1,40 ≤G ≤ 1,54

B

1,25 ≤ G ≤ 1,39

B

1,10 ≤ G ≤ 1,24

B

1,25 ≤ G ≤ 1,39

C

1,10 ≤ G ≤ 1,24

C

0,95 ≤ G ≤ 1,09

C

Empty

D

Empty

D

0,8 ≤ G ≤ 0,94

D

1,10 ≤ G ≤ 1,24

E

0,95 ≤ G ≤ 1,09

E

0,65 ≤ G ≤ 0,79

E

G ≤ 1,09

F

G ≤ 0,94

F

G ≤ 0,64

F


Regulation 661/2009 sets out minimum wet grip requirements for C1 tyres only. For normal tyres the limit value is ≥1.1.

Braking distance

There is a clear relation between wet grip level and braking distance as seen in the table below. E.g. wet grip level F has a 55% longer braking distance than wet grip level A. To simplify the calculations a linear trend has been assumed making it possible to calculate the change in braking distance as a function of wet grip index (G). The ratio is assumed equal for all three tyre types (C1, C2, C3), but will of course vary due to different wet grip intervals.



Table 26: Braking distance for different wet grip levels compared to rating A. Assumed equal for C1, C2 and C3 tyres.

Tyre label

Increased braking distance (index A=100)

A

100

B

111

C

124

D

132

E

141

F

155

Impact speed

The TNO study acquired data on the average impact speed for accidents at three different road types: urban, rural and motorway as seen in the table below. This data is assumed to be the reference in the baseline scenario.

Table 27: Average initial vehicle speed and impact speed of different accident scenarios.

Accident scenario

Urban road car to car

Rural road car to car

Motorway car to car

Initial speed (km/h)

50

80

120

Impact speed (km/h)

30

46

91

For simplification it is assumed that a change in braking length will give an equal change in impact speed. E.g. a 10% reduction in braking length will reduce the impact speed in an accident by 10%. In reality, the relation between braking distance and impact speed will have an exponential trend and will vary depending on the initial speed.

Personal injury

The impact speed can be translated into injury risk for different levels of injuries (slight, serious, fatal) as seen in the figure below. The higher the impact speed the higher is the risk of a fatal accident.

Figure 2 Injury risk of passenger car occupants as a function of impact speed (km/h). 45

Based on the average accident impact speed the distribution of injury types has been calculated in the table below. This is the baseline injury distribution. Since this is a theoretic distribution it is only used to determine the relative change for the three injury types between the baseline and each scenario. When the relative change has been calculated it can be coupled with the absolute number of fatalities, seriously injured and slightly injured in the baseline.

Table 28 Baseline distribution of injury types based on average accident impact speeds for different road types.

Road type

Impact speed (km/h)

Fatalities

Serious injuries

Slight injuries

No injury

Urban

30

1.6%

7.1%

63.4%

27.9%

Rural

46

1.8%

22.7%

62.8%

12.7%

Motorway

91

23.7%

61.2%

13.8%

1.4%

Ice and snow label 

It has not been possible to acquire data on the effect of ice and snow tyres compared to regular tyres on accidents. Unlike wet grip, the ice and snow labels do not include a scale, meaning there is either a constant effect or no effect with and without the labels. As for wet grip it is assumed that improved snow and ice grip only affects accident on snowy and icy roads. The share of accidents on snowy roads were in 2015 1% 46 . There are no data for accidents on icy roads, but it has been assumed to be of the same extent as for snowy roads, being 1%. There are no data on injury type distribution (fatal, severe, slight), impact speed or braking distance from accidents on snowy and icy roads. In the baseline these are assumed equal to those used for wet road accidents. For scenarios including the ice and snow labels the effect on fatal, severe and slight accidents are assumed equal to that of wet road accidents.

10.Societal costs

Estimations of societal costs of accidents are based on values from the 2006 HEATCO report 47 recommended by the Commission for monetary valuation of road safety. It includes estimates for three different injury types – fatal, severe and slight – for individual countries in the EU-25. The values vary greatly between Member States and correlates to the GDP of the Member State. The valuation of the three remaining MSs has therefore been estimated based on GDP. The modelling approach uses a weighted average cost value for each injury type covering the whole of EU-28. The number of fatalities and injuries for each MS has been used as weighting factors.

Values given in the HEATCO report are 2002 prices and have therefore been converted to the current price level based on the inflation rate (see Table 29 ).

Table 29 Societal costs based on injury types 48

Injury type

Societal costs thousand EUR (2017)

Fatal

1,673

Severe

251

Slight

19

11.Economy and employment

The industry turnover has been used as a measure of economic impact and used to quantify employment changes within the industry.

Turnover and employment have been divided into three sectors:

·Manufacturer

·Wholesale

·Retail

Manufacturer

Data for manufacturer turnover has been acquired from EUROSTAT 49 for 2012-2016 (see Table 30). Data for number of employees are from ETRMA 50 , which has been up scaled to EU-28 based on ETRMA’s market share.


Table 30 Turnover and employees - tyre manufacturers

Year

Turnover million EUR

Employees

Turnover/ employee EUR

2012

17,634

257,434

68,501

2013

16,800

258,440

65,007

2014

16,813

260,124

64,635

2015

16,801

272,018

61,764

2016

16,836

281,839

59,738

Avg.

16,977

265,971

63,929

The average turnover of 63,929 EUR/employee was fixed throughout the whole modelling period and therefore assumed to be constant. Similarly the mark-up factor relative to the retail turnover, calculated to an average of 2, is assumed to be constant through the whole modelling period.

Wholesale

It was not possible to acquire data for either turnover or employment for the tyre wholesale sector. Instead estimates on turnover are based on a suggested mark-up factor of 1.25 relative to manufacturer turnover. Number of employees is calculated based on a labour productivity of 59,241 EUR/employee 51 , which is an average for all industries. It is unknown if the tyre wholesale industry deviates from this.

Retail

The yearly retail turnover was estimated based on tyre prices and total sales numbers. The price of a tyre is determined by its combination of rolling resistance and wet grip category. The general trend is the higher the category the higher the price. Prices for C1, C2 and C3 tyres are seen in the following three tables. C1 and C2 prices are based on total sales numbers and total turnover for five major EU markets 52 giving an accurate estimate of the individual unit prices. 53 Some label class combinations have limited sales which were considered too small to give a representative estimate of the unit price. These have been adjusted based on linear interpolation and marked with a (*) in the tables below.

Similar data were not available for C3 tyres, which were therefore collected through an online web shop 54 , giving a relatively low sample size. Results should therefore be considered with caution.



Table 31 Unit price matrix - 2017 EUR – GfK data – C1 tyres. *Identified as an outlier and adjusted

RRC – WG

A

B

C

E

F

A

121.8

92.2

B

94.6

91.0

86.2

C

101.4

89.9

86.4

78.1

66.3

E

124.5

96.6

76.0

73.7

73.7*

F

115.0

107.8

63.0

70.7

70.7*

G

80.7

103.3

80.0

61.8

 

Table 32 Unit price matrix - 2017 EUR – GfK data – C2 tyres. *Identified as an outlier and adjusted

RRC - WG

A

B

C

E

F

A

B

140.6

126.8

125.4*

124.6*

123.9

C

119.7

124.4

106.0

104.5

117.1

E

112.1

121.5

94.8

100.4

70.3

F

116.9

114.5

95.1

100.5

100.5*

G

77.1

77.4

81.4*

85.3

Table 33 Unit price matrix - 2018 EUR – C3 tyres. *Identified as an outlier and adjusted 55

RRC - WG

A

B

C

D

E

A

581,00*

555,25*

503,72

 

 

B

520,50*

535,81

519,41

 

382,93

C

505,24

532,66

535,44

506,99

410,08

D

491,38*

477,60

529,07

360,48

368,68

E

 

 

546,86

 

 

The division of each label class is too broad to track yearly developments. Therefore, the modelling is based on the exact rolling resistance coefficient (RRC) and wet grip index for each year. Consequently, unit prices must be subdivided as well, making it possible to identify a certain unit price based on a specific combination of RRC and wet grip index. The relation between label class and RRC/WG can be seen in the tables below. It is assumed that the unit price of a specific label class corresponds to the middle of the interval (given in brackets below). To calculate a specific unit price in between label classes a linear interpolation has been applied.

Table 34 Relation between label class, rolling resistance and wet grip – C1 tyres.

Label Class

RRC

WG

A

<6.6 (6.3)

>1.54 (1.6)

B

6.6 – 7.7 (7.2)

1.54 – 1.40 (1.47)

C

7.8 – 9.0 (8.4)

1.39 – 1.25 (1.32)

E

9.1 – 10.5 (9.8)

1.24 – 1.10 (1.17)

F

10.6 – 12.0 (11.3)

<1.10 (1.04)

G

>12 (12.4)

Table 35 Relation between label class, rolling resistance and wet grip – C2 tyres

Label Class

RRC

WG

A

<5.5 (5.3)

>1.39 (1.45)

B

5.6 – 6.7 (6.2)

1.39 – 1.25 (1.32)

C

6.8 – 8.0 (7.4)

1.24 – 1.1 (1.17)

E

8.1 – 9.2 (8.7)

1.09 – 0.95 (1.02)

F

9.3 – 10.5 (9.9)

<0.95 (0.89)

G

>10.5 (10.8)

Table 36 Relation between label class, rolling resistance and wet grip – C3 tyres

Label Class

RRC

WG

A

<4.1 (3.8)

>1.24 (1.3)

B

4.1 – 5.0 (4.6)

1.24 – 1.1 (1.17)

C

5.1 – 6.0 (5.6)

1.09 – 0.95 (1.02)

D

6.1 – 7.0 (6.6)

0.94 – 0.8 (0.87)

E

7.1 – 8.0 (7.6)

<0.8 (0.72)

F

>8.0 (8.5)

The average tyre unit price for a specific year is coupled with annual sales data acquired from ETRMA giving an estimate of the turnover in the retail sector. This is done for all three tyre types C1, C2 and C3. Subsequently, it is possible to calculate market turnovers for the manufacturer and wholesale sector based on estimated mark-up factors seen in the table below. Coupled with productivity data (turnover/employee) seen in the same table, the number of employees is calculated.

Table 37 Labour productivity and mark-up factors used in the modelling

Sector

Turnover/employee EUR

Mark-up factors

Retail

25,511

2

Wholesale

59,241

1.25

Manufacturer

63,929

1

12.Label re-adjustment

12.1    Wet Grip

The current distribution of tyres in wet grip class A is 20% of all C1 tyres and 8% of all C2 tyres sold in 2017, cf. Figure 3 . The ongoing trend from 2015-2017 is that more tyres are placed in the top 3 classes. For C3 tyres, the trend has been opposite for class A and B. The distribution of C3 tyres in class A and B has lowered from 2012-2017, while tyres in class C-F have increased.

Figure 3a/b: Wet grip label distribution for all sold tyres 2015-2017, for C1(a) and C2(b) tyres. Source: GfK

Figure 4: Wet grip label distribution for all sold C3 tyres 2015-2017. Source: TOL

12.2    Rolling Resistance / Fuel Efficiency

For C1/C2 tyres, the trend is similar to the wet grip performance development, as more products are placed in the top 3 categories. The A class is however currently almost empty.

For C3 tyres, the trend is again opposite. From 2012-2017, the market share of tyres in class D-F have increased from 39% in 2012, to 63% in 2017.

Figure 5a/b: Rolling resistance label distribution for all sold tyres 2015-2017, for C1(a) and C2(b) tyres. Source: TOL

Figure 6: Rolling resistance label distribution for all sold C3 tyres 2015-2017. Source: TOL

The wet grip and rolling resistance / Fuel efficiency are to some extent negatively correlated. This means that very few products are in class A in both categories. Table 39 / Table 40 shows the current distribution of the tyres with both wet grip and fuel efficiency class for C1, C2, and C3 tyres respectively. While the wet grip classes are heavily distributed in classes A-C (for C1 and C2 tyres), the fuel efficiency is more evenly spaced out.


12.3    Rolling resistance / Wet grip cross distributions

Table 38: Current distribution of Rolling Resistance (RR) and Wet Grip (WG) labels for C1 tyres sold in 2017. Source: TOL

 

 

Wet Grip

 

 C1

A

B

C

D

E

F

G

sum

Rolling resistance

A

0,2%

0,2%

0%

0%

0,0%

0,0%

0%

0%

B

2%

3%

1,1%

0%

0,1%

0,1%

0%

6%

C

11%

13%

11%

0%

1%

0,6%

0%

37%

D

0%

0%

0%

0%

0%

0%

0%

0%

E

6,5%

13%

18%

0%

4%

0,8%

0%

41%

F

1,0%

4%

7%

0%

2%

0,8%

0%

15%

G

0%

0,1%

0,3%

0%

0,2%

0,1%

0%

1%

sum

20%

32%

38%

0%

7%

2%

0%

 

Table 39: Current distribution of Rolling Resistance (RR) and Wet Grip (WG) labels for C2 tyres sold in 2017. Source: TOL 

 

 

Wet Grip

 

C2

A

B

C

D

E

F

G

sum

Rolling resistance

A

0,0%

0,0%

0%

0%

0,0%

0,0%

0%

0%

B

1%

2%

0,2%

0%

0,3%

0,1%

0%

4%

C

6%

14%

6%

0%

2%

0,1%

0%

28%

D

0%

0%

0%

0%

0%

0%

0%

0%

E

1,2%

11%

24%

0%

5%

0,2%

0%

41%

F

0,3%

7%

7%

0%

9%

0,5%

0%

25%

G

0%

0,5%

1,1%

0%

0,6%

0,0%

0%

2%

sum

8%

34%

38%

0%

18%

1%

0%

 

Table 40: Current distribution of Rolling Resistance (RR) and Wet Grip (WG) labels for C3 tyres sold in 2017. Source: TOL

 

 

Wet Grip

C3

A

B

C

D

E

F

G

sum

Rolling resistance

A

0,1%

0,3%

0%

0%

0,0%

0,0%

0%

1%

B

1%

5%

2,2%

0%

0,0%

0,0%

0%

7%

C

2%

17%

11%

0%

0%

0,0%

0%

29%

D

1%

14%

23%

1%

0%

0%

0%

40%

E

0,4%

5%

12%

1%

0%

0,0%

0%

18%

F

0,1%

1%

2%

1%

0%

0,0%

0%

4%

G

0%

0,0%

0,0%

0%

0,0%

0,0%

0%

0%

sum

3%

42%

51%

4%

0%

0%

0%

 

12.4    Noise (dB)

The noise level distributions are generally more stable than the WG/RR developments. A minor overall decrease in average noise levels at 0.03%, 0.18%, and 0.03% for C1/C2/C3 tyres respectively is seen from 2015-2017. The raw dB distributions are shown in Figure 7 and Figure 8 . The average values are shown in Table 41 .

Figure 7a/b: Noise level distribution for all sold tyres 2015-2017, for C1(a) and C2(b) tyres. Source: GfK

Figure 8: Noise level distribution for all available C3 tyres 2015-2017. Source: TOL

Table 41: Average noise levels for C1-C3 tyres from 2015-2017. Source: GfK/TOL

Avg. Noise level

2015

2016

2017

C1

70,13

70,09

70,11

C2

71,64

71,59

71,51

C3

71,71

71,71

71,69

12.5    Noise (Classes)

Besides the raw noise in dB, 3 noise classes are available on the Ecolabel. The vast majority of C1+C2 tyres are in the middle category. For C3 tyres, an almost equal distribution between categories 1 and 2 exists. All tyre types have generally progressed towards lower noise emissions, which is consistent with the findings in Table 41 . The noise level class (1-3) distribution is shown in

Figure 9 - Figure 11 for C1, C2, and C3 tyres respectively.

Figure 9: Noise class distributions for available C1 tyres in 2016-2017. Source: TOL

Figure 10: Noise class distributions for available C2 tyres in 2016-2017. Source: TOL

Figure 11: Noise class distributions for available C3 tyres in 2016-2017. Source: TOL



13.Proposal to new label intervals

In order to ensure future relevancy, and to remove the worst performing tyres on the market, new label class intervals are proposed. New top classes are introduced for each parameter, and the worst performing class is removed entirely. All stated stage 2 requirements as per the tyre-approval regulation No. 661/2009 are used as lower boundaries if available.

As current performance testing procedures have many naturally occurring uncertainties, the class interval sizes should remain constant.

Two different scenarios are proposed; Scenario 1 will introduce a new A class and readjust the remaining classes. The interval sizes will remain as they are now. The empty D class is removed. For wet grip and rolling resistance, the new A class will follow the tendency of having a mean value with +/- ~5% as upper- and lower bounds, and with top classes having narrower bands than the lower classes. The new upper boundary is hence based on a linear extrapolation on the differences (in percentages) between the other classes

Scenario 2 will restructure the intervals to 4 classes (A-D). For C1 and C2 tyres, the current intervals are kept without introducing a new A class. The empty D class is removed, and current E and F classes are restructured to fit the tier 2 requirement in the Type Approval Regulation (TAR). For C3 tyres, the classes are redistributed dependent on the current market distribution, shown in Table 59).

13.1    Scenario 1

a.    Proposal to new Wet Grip index label intervals (Scenario 1)

For C1 and C2 tyres, the currently empty D class is removed, leaving both F and G classes empty. For C3 tyres, the current intervals are shifted one class down.

Table 42 , 43 and 44 shows the label interval shifts for C1-C3 tyres respectively, and Table 45 and Table 46 shows the summarized current and new WG label class intervals.

Table 42: Current and new label class intervals for wet grip in C1 tyres.

Current

≥1,55

1,54-1,40

1,39–1,25

Empty

1,24–1,10

≤1,09

Empty

A

B

C

D

E

F

G

New

A

B

C

D

E

F

G

C1 WG

≥1,68

1,67-1,55

1,54-1,40

1,39–1,25

1,24–1,10

Empty

Empty

Table 43: Current and new label class intervals for wet grip in C2 tyres

Current

≥1,40

1,39–1,25

1,24–1,10

Empty

1,09–0,95

≤0,94

Empty

A

B

C

D

E

F

G

New

A

B

C

D

E

F

G

C2 WG

≥1,53

1,52-1,40

1,39–1,25

1,24–1,10

1,09–0,95

Empty

Empty

Table 44: Current and new label class intervals for wet grip in C3 tyres

Current

≥1,25

1,24–1,10

1,09–0,95

0,94–0,80

0,79–0,65

≤0,64

Empty

A

B

C

D

E

F

G

New

A

B

C

D

E

F

G

C3 WG

≥1,38

1,37–1,25

1,24–1,10

1,09–0,95

0,94–0,80

0,79–0,65

Empty

Table 45: Current Wet grip class intervals

C1 tyres (Current)

C2 tyres (Current)

C3 tyres (Current)

G

Wet grip class

G

Wet grip class

G

Wet grip class

1,55 ≤ G

A

1,40 ≤ G

A

1,25 ≤ G

A

1,40 ≤ G ≤ 1,54

B

1,25 ≤ G ≤ 1,39

B

1,10 ≤ G ≤ 1,24

B

1,25 ≤ G ≤ 1,39

C

1,10 ≤ G ≤ 1,24

C

0,95 ≤ G ≤ 1,09

C

Empty

D

Empty

D

0,8 ≤ G ≤ 0,94

D

1,10 ≤ G ≤ 1,24

E

0,95 ≤ G ≤ 1,09

E

0,65 ≤ G ≤ 0,79

E

G ≤ 1,09

F

G ≤ 0,94

F

G ≤ 0,64

F

Empty

G

Empty

G

Empty

G

Table 46: Proposed Wet grip class intervals

C1 tyres (Proposed)

C2 tyres (Proposed)

C3 tyres (Proposed)

G

Wet grip class

G

Wet grip class

G

Wet grip class

1,68 ≤ G

A

1,53 ≤ G

A

1,38 ≤ G

A

1,55 ≤ G ≤ 1,67

B

1,40 ≤ G ≤ 1,52

B

1,25 ≤ G ≤ 1,37

B

1,40 ≤ G ≤ 1,54

C

1,25 ≤ G ≤ 1,39

C

1,10 ≤ G ≤ 1,24

C

1,25 ≤ G ≤ 1,39

D

1,10 ≤ G ≤ 1,24

D

0,95 ≤ G ≤ 1,09

D

1,10 ≤ G ≤ 1,24

E

0,95 ≤ G ≤ 1,09

E

0,80 ≤ G ≤ 0,94

E

Empty

F

Empty

F

0,65 ≤ G ≤ 0,79

F

Empty

G

Empty

G

Empty

G



b.    Proposal to new Rolling Resistance index label intervals (scenario 1)

Even though the current A classes are almost empty, redistribution is nonetheless proposed so as to ensure future relevancy. The rolling resistance redistributions follow the same trend as the wet grip classes, with the currently empty D class being removed C1 and C2 tyres and shifting the C3 tyres intervals up one class.

Table 47 to Table 49 shows the label interval shifts for C1-C3 tyres respectively, and Table 50 and Table 51 shows the summarized current and new label RR class intervals.

Table 47: Current and new label class intervals for rolling resistance in C1 tyres

Current

≤6,5

6,6–7,7

7,8–9,0

Empty

9,1–10,5

10,6–12,0

≥12,1