Europaudvalget 2018
KOM (2018) 0296
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EUROPEAN
COMMISSION
Brussels, 17.5.2018
SWD(2018) 189 final
PART 2/3
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}
EN
EN
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ANNEXES OF THE IMPACT ASSESSMENT
ON THE REVIEW OF THE TYRE LABELLING
REGULATION (EC) No 1222/2009/EC
Table of Content
ANNEX 1: PROCEDURAL INFORMATION
..........................................................................................
3
ANNEX 2: STAKEHOLDER CONSULTATION
..................................................................................... 6
1.
2.
3.
OVERVIEW OF THE RESPONDENTS TO THE OPC
....................................................... 6
OVERALL RESULTS
.............................................................................................................. 8
DETAILED RESULTS
............................................................................................................. 9
3.1.
3.2.
4.
1.
2.
3.
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
E
VALUATION OF EXISTING TYRE LABEL
........................................................................ 9
P
OSSIBLE
I
MPROVEMENTS AND ADDITIONS
................................................................. 14
IN EXTENSO
COMMENTS FROM ALL RESPONDENTS
.............................................. 34
PRACTICAL IMPLICATIONS OF THE INITIATIVE
..................................................... 56
SUMMARY OF COSTS AND BENEFITS
........................................................................... 57
ESTIMATION OF ADMINISTRATIVE COSTS
................................................................ 58
GENERAL ASSUMPTIONS
.................................................................................................. 64
INFORMATION EFFECT
..................................................................................................... 65
STOCK MODEL ASSUMPTION
.......................................................................................... 65
BAU SCENARIO ASSUMPTIONS
....................................................................................... 66
POLICY OPTION 2 SCENARIO ASSUMPTIONS
............................................................ 70
POLICY OPTION 3 SCENARIO ASSUMPTIONS
............................................................ 70
POLICY OPTION 4 SCENARIO ASSUMPTIONS
............................................................ 72
EFFECT OF ROLLING RESISTANCE ON FUEL CONSUMPTION
............................. 72
EFFECT OF WET GRIP ON SAFETY
................................................................................ 74
SOCIETAL COSTS
................................................................................................................ 78
ECONOMY AND EMPLOYMENT
...................................................................................... 78
LABEL RE-ADJUSTMENT
.................................................................................................. 81
ANNEX 3: WHO IS AFFECTED AND HOW?
....................................................................................... 56
ANNEX 4: ANALYTICAL METHODS
................................................................................................... 64
12.1
12.2
12.3
12.4
12.5
13.
Wet Grip
....................................................................................................... 81
Rolling Resistance / Fuel Efficiency
........................................................... 82
Rolling resistance / Wet grip cross distributions
...................................... 84
Noise (dB)
..................................................................................................... 85
Noise (Classes)..............................................................................................
86
Scenario 1
...................................................................................................... 87
Scenario 2
...................................................................................................... 92
PROPOSAL TO NEW LABEL INTERVALS
...................................................................... 87
13.1
13.2
1
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ANNEX 5: EVALUATION
........................................................................................................................ 96
1.
2.
INTRODUCTION - PURPOSE AND SCOPE OF THE EVALUATION
.......................... 98
BACKGROUND TO THE INTERVENTION
...................................................................... 99
2.1.
2.2.
3.
4.
D
ESCRIPTION OF THE INTERVENTION AND ITS OBJECTIVES
......................... 99
B
ASELINE AND POINTS OF COMPARISON
(BAU)
........................................... 102
IMPLEMENTATION / STATE OF PLAY
......................................................................... 104
METHOD
............................................................................................................................... 105
4.1.
4.2.
4.3.
5.
S
HORT DESCRIPTION OF METHODOLOGY
..................................................... 105
I
NTERVIEWS AND END
-
USER SURVEY
............................................................ 107
L
IMITATIONS AND ROBUSTNESS OF FINDINGS
.............................................. 108
E
FFECTIVENESS
.............................................................................................. 108
E
FFICIENCY
..................................................................................................... 116
R
ELEVANCE
..................................................................................................... 123
C
OHERENCE
.................................................................................................... 128
EU
ADDED VALUE
........................................................................................... 132
W
HAT IS
/
IS NOT WORKING AND WHY
?
.......................................................... 134
T
HE
L
ESSONS LEARNT
.................................................................................... 135
A
CTUAL PERFORMANCE COMPARED TO EXPECTATIONS
............................. 135
A
CTIONS TO BE TAKEN
................................................................................... 136
ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS
.......................... 108
5.1.
5.2.
5.3.
5.4.
5.5.
6.
CONCLUSIONS
.................................................................................................................... 134
6.1.
6.2.
6.3.
6.4.
APPENDIX 1: STAKEHOLDER CONSULTATION
................................................................. 137
APPENDIX 2: METHODS AND ANALYTICAL MODELS
..................................................... 179
ANNEX 6: RESULTS
............................................................................................................................... 193
1.
2.
3.
4.
5.
LIST OF POLICY OPTIONS, INCLUDING MODIFIED POLICY OPTION
.............. 193
END USER EXPENDITURE
............................................................................................... 193
ECONOMY: BUSINESS TURNOVER...............................................................................
197
SAFETY AND SAFETY COSTS
......................................................................................... 200
ENERGY AND GHG EMISSIONS
..................................................................................... 204
ANNEX 7: GLOSSARY
........................................................................................................................... 206
2
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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
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.
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.
Where and how the comments have been
taken into account
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 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 A summary of the underlying assumptions of
behavioural assumptions that are neither the modelling has been added at the beginning
transparently presented nor accompanied by a of section 6 (page 29).
sensitivity analysis.
A sensitivity analysis on the key behavioural
assumptions of consumers has been added to
section 8 on the preferred option.
3
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Specific objectives are missing, as are a good The specific policy options have been added at
representation of stakeholder views on the the beginning of section 4.2 on page 12. Their
different policy options.
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)
1
2
3
http://www.labellingtyres.eu/
See Annex 2 for the results and answers of the Open Public Consultation
http://www.acea.be/statistics/article/Report-Vehicles-in-Use
4
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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
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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.
O
VERVIEW 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
C
ATEGORY
Tyre suppliers
1.
2.
3.
4.
5.
S
TAKEHOLDER
ID
Apollo Tyres
Continental Reifen Deutschland GmbH
ExxonMobil Petroleum & Chemical BVBA
Goodyear Dunlop Tires B.V.
Michelin Nordic AB
M
EMBER
S
TATE
International
Germany
International
Netherlands
Sweden
6
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6.
Retailer
Market
surveillance
authority
Member State
government
Member State
regional or local
government
authority
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
Nokian Tyres Plc
BOVAG
Swedish Energy Agency in cooperation with other agencies
Swedish Transport Agency
Federal Ministry of Environment
Ministry of Infrastructure and Water Management
City of Helsinki
DCMR EPA/EUROCITIES
Federal Office for the Environement (FOEN)
Gemeente Den Haag
The City of Oslo, Department for Urban Environment
ACP Automóvel Clube
Allgemeiner Deutscher Automobil Club e.V. (ADAC e.V.)
ANEC and BEUC
Association of Austrian Newspapers
Association of Dutch Water Companies and the Association of
Dutch Water Authorities
Austrian Journal and Trade Association (ÖZV)
Deutscher Verkehrssicherheitsrat e.V.
European Association for Accident Research and Analysis (EVU)
European
Environmental
Citizen's
Organisation
for
Standardisation
Fédération Internationale de
l’Automobile (FIA Region I)
Quercus ANCN
The European Environmental Bureau
Transport & Environment (T & E)
ZERO - Associação Sistema Terrestre Sustentável
Advertising Association
Advertising Information Group
BDEW Bundesverband der Energie- und Wasserwirtschaft
Däckbranschen Sverige AB
European association of television and radio sales houses (EGTA)
European Caravan Federation
European Magazine Media Association
and European Newspaper Publishers' Association (EMMA&
ENPA)
International
Netherlands
Sweden
Sweden
Belgium
Netherlands
Finland
Netherlands
Switzerland
Netherlands
Norway
Portugal
Germany
EU
Austria
Netherlands
Austria
Germany
Austria
EU
Luxembourg
Portugal
EU
EU
Portugal
United Kingdom
Germany
Germany
Sweden
EU
Germany
EU
EU
Germany
Norway,
Sweden
Sweden
Denmark
EU
Germany
Germany
Germany
Germany
Belgium
Netherlands
Finland
Denmark,
Non-
governmental
organisations
representing
societal interests
Industry
organisations
38. European Tyre & Rubber Manufacturers Association (ETRMA)
39. German Insurance Association (GDV)
40. Nordic Logistics Association
41. Swedish Water and Wastewater Association
42. The Danish Chamber of Commerce
43. The European Federation of National Association of Water
Services (EurEau)
44. Verband der TÜV e.V.
45. Wirtschaftsverband der deutschen Kautschukindustrie e.V.
46. Zentralverband der deutschen Werbewirtschaft ZAW e.V.
47. Commodity producer for tires
48. Solvay Silica (Manufacture of silica for the tire industry)
49. Type Approval Authority
50. Water supply plant
20 respondents identified themselves as citizens and/or private
consumers
Other
Citizens /
consumers
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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.
O
VERALL 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
4 Tyres sold on the Original Equipment Market (i.e. with a new vehicle)
8
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test results. It was widely agreed by the respondents that this would improve confidence
and should be made mandatory.
3.
D
ETAILED 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.
3.1.
E
VALUATION OF EXISTING TYRE LABEL
Question 7a: Are you aware of the EU labelling scheme for tyres?
Question 7a
70%
60%
50%
40%
30%
20%
10%
0%
No
Yes, although I have never
seen it used in practice
Yes, and I have seen the
label used as part of the
process of buying or selling
tyres
No answer
3%
16%
16%
66%
Question 7b: In your opinion, is the label a helpful piece of information when deciding
which tyres to buy?
Question 7b
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
No
Yes
Don't know or no opinion
No answer
7%
3%
13%
77%
9
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Question 7c: Do you think it is a good thing that a single EU-wide label covers tyres sold
in all EU countries?
Question 7c
90%
83%
80%
70%
60%
50%
40%
30%
20%
13%
10%
0%
Don't know or no opinion
Yes
No answer
No
4%
0%
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?
Question 8
90%
80%
70%
60%
50%
40%
30%
20%
11%
10%
0%
Wet grip
External noise
Fuel efficiency
No answer
7%
6%
79%
10
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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 9a
45%
40%
35%
30%
25%
20%
15%
10%
5%
0%
No
Yes
Don't know or can't
remember
No answer
20%
17%
20%
43%
Question 9b: Did you see the EU label?
Question 9b
40%
35%
30%
25%
20%
15%
10%
5%
0%
No
Yes
Don't know or can't
remember
No answer
24%
20%
20%
36%
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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?
Question 10
30%
25%
20%
16%
15%
10%
5%
0%
Don't know or no Its external rolling Its fuel efficiency
opinion
noise performance performance
Its wet grip
performance
Other
No answer
4%
16%
13%
29%
23%
Comments on question 10
Respondent ID
Fazilet Cinaralp
Stephan Rau
Jos de Gier
Christoffer
Greenfort
Soren Larsen
Martina Petkova
Respondent category
An organisation
representing industry
views
An organisation
representing industry
views
An organisation
representing industry
views
An organisation
representing industry
views
An organisation
representing industry
views
A business manufacturing
or involved in the trading
of tyres
A business manufacturing
or involved in the trading
of tyres
A business manufacturing
or involved in the trading
of tyres
All three performances are key for informed
decision by the consumer.
All three performances are key for informed
decision making by the consumer.
Most important Wet Grip, secondly RR and less
Noise. Overall, these key performances are a good
basis for a well-founded buy-decision.
Road safety performance.
We believe fuel efficiency, wet and winter grip and
noise are important characteristics.
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.
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).
A critical parameter is absent that affects all aspects
of tire performance: air retention. This parameter
could be accounted for without necessarily being
Susanne
Buchholz
Andrew Bassett
12
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Hans Norén
Schneuwly
Dominique
Johan Sliggers
Marina
Lukovnikova
Guido Gielen
Swedish Transport
Agency, regulatory
authority for tires (MSA)
A Member State regional
or local government
authority
A Member State
government
A Member State
government
A non-governmental
organisation representing
societal interests (for
example, environmental
or consumer interests)
Citizen/consumer (NL)
Citizen/consumer (IT)
shown as an additional label criterion.
Ice grip.
One characteristic is only valuable if the others are
visible too.
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).
We provide the answer as the authority, not as a
consumer. All parameters are important, in
different aspects.
1) Its wet grip performance; 2) wear/life and 3)
price seem to be the most important considerations
for many
All three characteristics, as well as the wear factor.
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?)”
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3.2.
3.2.1.
P
OSSIBLE
I
MPROVEMENTS AND ADDITIONS
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
Industry
Summary of answers
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.
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.
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.
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.
Governmental
organisations
Non-
governmental
organisations
Consumers
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?
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Question 11
80%
70%
60%
50%
40%
30%
20%
13%
10%
0%
Don't know or no opinion
No
Yes
No answer
7%
4%
76%
15
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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?
Question 12
35%
30%
25%
20%
15%
10%
10%
5%
0%
Encourage Member States to run awareness campaigns to increase consumer knowledge of the tyre labelling scheme
Encourage businesses to run awareness campaigns to increase consumer knowledge of the tyre labelling scheme
Extend the label's display by ensuring more types of advertisements (for example, on billboards or in magazines) for tyres
include the label
Encourage Member States to raise awareness within their central government that they are required to purchase only tyres
in the highest fuel efficiency class (Annex III of the Energy Efficiency Directive 2012/27/EU)
Don't know or no opinion
Other
No answer
3%
9%
4%
23%
18%
32%
Comments on question 12
Respondent ID
Bertrand Vallet
Soren Larsen
Ines Nitsche
Katja Heintschel
von Heinegg
Respondent category
An organisation
representing industry
views
An organisation
representing industry
views
An organisation
representing industry
views
An organisation
representing industry
Microplastics release during the use phase
Marking 3PMSF for winter tyres, tested in accordance with
UNECE R117 Annex 7. And categorise tyres in general: A,
B, C...
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.
Under no circumstances should the requirement to disclose
relevant environmental properties in media advertising be
16
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Marie De Cordier
Martina Petkova
Andrew Bassett
Johan Sliggers
Schneuwly
Dominique
Guido Gielen
Aline Maigret
Verband
Österreichischer
Zeitungen
views
An organisation
representing industry
views
A business
manufacturing or
involved in the trading
of tyres
A business
manufacturing or
involved in the trading
of tyres
A Member State
government
A Member State
regional or local
government authority
A non-governmental
organisation
representing societal
interests (for example,
environmental or
consumer interests)
An NGO representing
societal interests (for
example,
environmental or
consumer interests)
Other
extended in the course of any revision of the Regulation.
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.
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.
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
The NLs is facilitating a campaign to raise awareness of the
importance of tyres: www.kiesdebesteband.nl
Reconsider information on the tyres (is everything still
needed?), add and highlight label data ON tyre.
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
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.
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?
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Question 13
40%
35%
30%
25%
20%
15%
10%
6%
5%
0%
Online labelling
–
the label is shown on the screen when tyres are offered for sale online
Distributor must show each label
–
the tyre distributor must show the customer the label for each tyre
under consideration
Labels always on tyres
–
ensure that labels are always visible on the tyres for sale themselves rather than
just accompanying them
Don't know or no opinion
Other
No answer
3%
2%
34%
28%
27%
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.”
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3.2.2.
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
Industry
Summary of answers
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.
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.
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.
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.
Governmental
organisations
Non-
governmental
organisations
Consumers
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?
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Question 14a
60%
57%
50%
40%
30%
20%
16%
14%
13%
10%
0%
No
Yes
Don't know or no opinion
No answer
Question 14b: In your opinion, should third-party verification of tyre test results be
introduced as a requirement?
Question 14b
40%
36%
35%
30%
25%
20%
15%
10%
5%
0%
No
Yes, but for a
representative
sample of tyres
Yes, for every tyre
model
Don't know or no
opinion
No answer
14%
11%
21%
17%
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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?
Question 15
35%
30%
25%
20%
15%
10%
5%
0%
19%
20%
32%
17%
12%
Update wet grip testing
–
change the way wet grip of tyres is tested to make it more up-to-date with current
technology and understanding
Labels with each batch
–
make sure that labels are always attached to each batch of identical tyres
Better sharing of results
–
when authorities inspect tyre businesses, make sure that the results are available to
industry as a whole
Other
No answer
Comments on question 15
Respondent ID
Fazilet
Cinaralp
Respondent
category
An organisation
representing
industry views
Stephan Rau
An organisation
representing
industry views
Jos de Gier
Martina
Petkova
An organisation
representing
industry views
A business
manufacturing or
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
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.
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.
The further development of market surveillance capability and
capacity at member state level would best support to improve
21
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involved in the
trading of tyres
Susanne
Buchholz
A business
manufacturing or
involved in the
trading of tyres
Johan Sliggers
A Member State
government
Henk Wolfert
Aline Maigret
Nerea Ruiz
Stephane Arditi
Laura Carvalho
A Member State
regional or local
government
authority
A non-
governmental
organisation
representing
societal interests
(for example,
environmental or
consumer
interests)
A non-
governmental
organisation
representing
societal interests
(for example,
environmental or
consumer
interests)
A non-
governmental
organisation
representing
societal interests
(for example,
environmental or
consumer
interests)
A non-
governmental
organisation
market surveillance. The launch of the joint market
surveillance initiative MSTyr15 is an excellent tool to enhance
a high level surveillance system in Europe.
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.
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.
Maybe tests under real driving conditions could change the
order of A-G labels?
-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
Inclusion on the automotive database
For better sharing of results, go beyond industry and make
them available to all, notably by publishing on the automotive
database
Inclusion in the automotive database
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representing
societal interests
(for example,
environmental or
consumer
interests)
Citizen/consumer
(NL)
Citizen/consumer
(FI)
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)
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.
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3.2.3.
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
Industry
Governmental
organisations
Non-
governmental
organisations
Consumers
Summary of answers
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.
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.
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 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?
Question 16
45%
40%
35%
30%
25%
20%
20%
15%
10%
5%
0%
Yes
–
it should be
mandatory
Yes
–
it should be
voluntary
No
Don't know or no
opinion
No answer
3%
7%
27%
43%
General comments related to ice and snow grip
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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.”
3.2.4.
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
Industry
Governmental
organisations
Non-
governmental
organisations
Consumers
Summary of answers
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.
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.
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.
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?
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Question 17
60%
49%
50%
40%
30%
19%
20%
17%
9%
10%
7%
0%
Don't know or no
opinion
No
Yes, but only if the
accuracy (for
example, the
reliability,
repeatability, or
reproducibility) of the
measurement can be
ensured
Yes, in all
circumstances
No answer
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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?
Question 20
45%
40%
35%
30%
25%
21%
20%
15%
10%
5%
0%
Don't know or no opinion
No
Yes
No answer
39%
33%
7%
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.”
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3.2.5.
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
Industry
Summary of answers
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.
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.
Most respondents representing a non-governmental organisation suggest
including both mileage information and abrasion information on the label.
The consumers answers are very divided and there is no clear opinion on
information on mileage and abrasion on the label.
Governmental
organisations
Non-
governmental
organisations
Consumers
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 18
40%
35%
30%
25%
20%
15%
10%
5%
0%
No
Yes, but only if the
accuracy and value
for money of the
measurement can
be ensured
Yes, in all
circumstances
Don't know or no
opinion
No answer
10%
7%
27%
20%
36%
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
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abrasion, and that other legislation already exists to regulate the chemical content of tyre
materials. Should abrasion information be included in the label?
Question 19
45%
40%
35%
30%
25%
20%
15%
10%
5%
0%
No, abrasion
No, concerns Yes, but only if
should not be about abrasion the accuracy of
regulated at all
are more
the
appropriately measurement
addressed
can be ensured
through other
forms of
regulation
Yes, in all
circumstances
Don't know or
no opinion
No answer
3%
7%
7%
20%
21%
41%
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]
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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.”
3.2.6.
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
Industry
Summary of answers
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.
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.
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.
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.
Governmental
organisations
Non-
governmental
organisations
Consumers
Survey results
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Question 21a: Should a digital registration database providing information about tyres be
set up?
Question 21a
80%
70%
70%
60%
50%
40%
30%
20%
10%
0%
No
Yes
Don't know or no opinion
No answer
19%
4%
7%
Question 21b: If a digital registration database should be set up, what sort of information
should it provide?
Question 21b
70%
60%
50%
40%
30%
20%
10%
0%
It should provide It should provide
public information information about
about tyres to
tyres to make it
inform consumers
easier for
authorities to
check that labels
are correct
It should do both Don't know or no
of the above, as
opinion
long as business
confidentiality is
respected
Other (please
state):
No answer
59%
14%
6%
7%
6%
9%
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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) […]”.
3.2.7.
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.”
3.2.8.
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”
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1896113_0034.png
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 […]”
3.2.9.
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 […]”
3.2.10. 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.”
3.2.11. 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.”
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“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.
I
N 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]
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“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
35
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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
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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
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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
38
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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
39
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1896113_0041.png
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
40
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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 surveillance
Continental 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 Performance
Having 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 tyres
Prerequisite 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 Microplastics
The 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
41
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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) ≥ 1,1
6.2.2, 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 corresponding
EU 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.
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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]
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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 vehicles
TCS: 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
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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]
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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
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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
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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
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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
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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.
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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.
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(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
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1896113_0054.png
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:
terial 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.
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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.
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
54
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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]
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Annex 3: Who is affected and how?
1.
P
RACTICAL 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 CO
2
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.
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2.
S
UMMARY 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 CO
2
10 MT per year in
Society receives the benefits
emissions
2030
Increased safety
€737 million per year
Society receives the benefits, but also
(reduction of
in 2030
citizens
fatalities)
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
Manufacturers, wholesalers and
2030
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.
Options
Information
campaigns
Joint enforcement
actions
Mandate to revise
testing methods
5
Online labelling
Labelling of tyres
delivered with
vehicles at all times
6
Provision of label for
C3 tyres
8
Inclusion of snow
and ice performance
Re-adjustment of the
label
II. Overview of costs
–
Preferred option
Member
Manufacturers
Dealers
States
10
(only once)
0.02 per year
n.a.
3
(only once)
50 per year
7
6 per year
9
EU/Commission
2
(only once)
0.5-1 per year
n.a.
40
(only once)
10
30
(only once)
5
Cost for the mandate will be insignificant. But there will be costs on primarily manufacturers, the Commission, and
standardisation organisations for development of the standard(s). However, it has not been possible to estimate the
costs.
6 Including when vehicles are purchase through leasing contracts
7 Dealers of vehicles, and leasing companies providing purchase through leasing contracts
8 Both for replacement and OEM tyres. Replacement tyres include new tyres provided for fleet solutions.
9 Manufacturers of C3 tyres
10 Per rescaling. If the label is rescaled again after for instance 10 years cost for rescaling will appear again
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Tyre registration
database
Technical
documentation and
product fiche content
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
Total
0.25 per year
120 per year
11
0.1 (only once)
and 0.01 per
year
0.65 per year
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.
E
STIMATION 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
11 For provision of product information sheet
12 Commissions impact assessment Guidelines
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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
Estimated with EU-28 average labour cost of 25.4 EUR/hour. Source http://ec.europa.eu/eurostat/statistics-
explained/index.php/Wages_and_labour_costs
14
SBS is a European non-profit association that represents and defends SMEs interest in the in the standardisation
process. SBS is co-financed by the European Commission and EFTA Member States
15
ECOS receives funding from European Commission, EFTA and several public and private donors
16
ANEC is a NGO representing consumer interest and is funded by the European Commission and EFTA.
13
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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.
17 Impact assessment accompanying the document Commission Delegated Regulation amending Commission
Delegated Regulations No 1059/2010, 1060/2010, 1061/2010, 1062/2010, 626/2011, 392/2012, 874/2012, 665/2013,
811/2013 and 812/2013 with regard to labelling of energy-related products on the internet, SWD(2014) 57 final
18 Impact assessment accompanying the document Commission Delegated Regulation amending Commission
Delegated Regulations No 1059/2010, 1060/2010, 1061/2010, 1062/2010, 626/2011, 392/2012, 874/2012, 665/2013,
811/2013 and 812/2013 with regard to labelling of energy-related products on the internet, SWD(2014) 57 final
19 This measure implies that the label should be provided to end-users who buys a new vehicle including purchase
through leasing contracts)
20 Extra costs for deliverance of the label for C3 tyres (both for OEM and replacement tyres) are estimated below
21 Number of OEM tyres sold per year are 87 million. With approximate 4 tyres per vehicle the number of OEM tyres
corresponds to sale of 21,6 million vehicles. With 5 minutes spend per sale and labour costs of 25.4 EUR/hour the
costs per year will be approximately €50 million per year.
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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
.
22
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:42011X1123(03)
23 Yearly replacement sale for C1 and C2 tyres is 281.5 million tyres.
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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.
24
Estimated at 0.5 Australian dollar (exchange rate at the time approximately 0.6 €/Australian dollar) by George
Wilkenfeld and Associates pty, Regulatory Impact Statement, Energy Labelling and Minimum Energy Performance
Standards for Household Electrical Appliances in Australia, February 2009
25 New models in 2017. Based on data from TOL database
26 Labour costs for EU-28 from: http://ec.europa.eu/eurostat/statistics-explained/index.php/Wages_and_labour_costs
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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.
27
The approved laboratories are considered to correspond to independent third-party laboratories
28 Numbers of new models per year from TOL database (C1 tyres: 3150, C2 tyres: 287, C3 tyres: 593) and test costs
from ETRMA (C1 tyres: 3500-4000 EUR, C2 tyres: 4000-4500 EUR, C3 tyres: 5000-6000 EUR). The highest value
for each tyre type is used in the calculation of extra testing costs.
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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.
-
-
-
-
-
-
-
-
G
ENERAL 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/monetar
y_valuation_of_road_safety_en
and
http://heatco.ier.uni-
stuttgart.de/HEATCO_D5.pdf
-
-
-
-
29
30 http://www.acea.be/uploads/statistic_documents/ACEA_Report_Vehicles_in_use-Europe_2017_FINAL2.pdf
European automobile manufacturers’ Association
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2.
I
NFORMATION 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.
o
Find fuel efficiency “very important”: 34%
o
Find wet grip “Very important”: 62%
o
Find 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.
S
TOCK MODEL ASSUMPTION
3.
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
C1 replacement
C1 OEM
C2 replacement
C2 OEM
C3 replacement
C3 OEM
Total
2006
231.46
59.09
25.72
4.96
12.76
3.35
337.33
2008
224.30
77.61
24.92
7.51
11.42
4.74
350.50
2010
249.72
74.64
27.75
4.98
11.56
2.72
371.36
2012
226.42
71.12
25.16
4.98
9.61
3.33
340.62
2014
236.60
73.80
26.29
5.35
12.19
3.20
357.44
2016
248.10
79.47
27.57
6.68
13.97
3.65
379.44
2017
253.31
80.06
28.15
6.72
14.88
3.94
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
.
31
Dara O’Rourke and Abraham Ringer, Journal of Industrial Ecology, 2015 “The Impact of Sustainability
Information on Consumer Decision Making”, link:
http://onlinelibrary.wiley.com/doi/10.1111/jiec.12310/abstract
32 http://www.etrma.org/statistics-2
33 http://www.gfk.com/about-gfk/about-gfk/
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Table 2: Assumption on tyre lifespans and mileage
Tyre type
C1
C2
C3
Expected
life in km
56 700
71 400
200 000
Average distance
driven per year, km
13 500
21 000
57 500
Average tyre
lifespan, years
4.2
3.4
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
Share of C1 OEM
Share of C2 OEM
Share of C3 OEM
Number of tyres per vehicle in stock
–
C1 (Calculated)
Number of tyres per vehicle in stock
–
C2 (Calculated)
Number of tyres per vehicle in stock
–
C3 (Calculated)
90%
21% of C1 replacement market
25% of C2 replacement market
25% of C3 replacement market
5.7 (approx. 1/3 have two sets of tyres)
4.1 (approx. 2,5% have two sets of tyres)
12.7 (different number of wheels on
different trucks/busses)
Sources: ETRMA, Ecodesign Impact Accounting
4.
BAU S
CENARIO 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:
-
34https://ec.europa.eu/energy/sites/ener/files/documents/Ecodesign%20Impacts%20Accounting%20%20-
%20status%20January%202016%20-%20Final-20160607%20-%20N....pdf
35
http://www.mstyr15.eu/index.php/en/
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-
-
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
Class average 6.3
7.4
2012
0% 3%
2013
1% 6%
2014
0% 5%
2015
0% 5%
2016
0% 5%
2017
0% 6%
C
8.7
29%
36%
36%
38%
34%
37%
E
10
42%
39%
43%
42%
43%
42%
F
G
Market Market average with
11.5 12.4 average non-compliance
24% 1%
9.92
10.28
17% 1%
9.64
10.01
15% 1%
9.63
10.00
14% 0%
9.57
9.93
17% 1%
9.68
10.05
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
Class average
2012
2013
2014
2015
2016
2017
A
5.3
0%
0%
0%
0%
0%
0%
B
6.4
1%
4%
6%
5%
4%
4%
C
7.7
26%
20%
25%
29%
25%
28%
E
8.9
56%
44%
41%
40%
42%
41%
F
10.2
15%
28%
25%
24%
27%
25%
G
10.8
2%
3%
2%
1%
3%
2%
Market Market average with
average non-compliance
8.80
9.13
8.97
9.30
8.82
9.15
8.77
9.10
8.92
9.25
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
Class average
2012
2013
2014
2015
2016
2017
A
3.8
2%
2%
1%
1%
1%
0%
B
4.7
10%
11%
10%
7%
7%
16%
C
5.7
33%
33%
36%
29%
29%
44%
D
6.7
37%
37%
36%
38%
40%
26%
E
7.7
16%
15%
14%
20%
18%
13%
F
8.6
3%
2%
2%
5%
4%
1%
Market Market average with
average non-compliance
6.07
6.43
6.34
6.70
6.30
6.66
6.28
6.64
6.54
6.90
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
Class average
2025
2030
A
5.3
3%
3%
B
6.4
C
7.7
E
8.9
F
10.2
11% 45% 40%
14% 48% 35%
Source: estimated based on historical development
G
Market Market average with
10.8 average non-compliance
9.03
9.40
1%
0%
8.90
9.27
0%
0%
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Table 8: Forecast of fuel efficiency label distribution in the BAU scenario for C2 tyres
RRC class
Class average
2025
2030
A
5.3
0%
0%
B
6.4
C
7.7
E
8.9
F
10.2
6% 40% 54%
6% 43% 50%
Source: estimated based on historical development
G
Market Market average with
10.8 average non-compliance
8.37
8.70
1%
0%
8.25
8.58
1%
0%
Table 9: Forecast of fuel efficiency label distribution in the BAU scenario for C3 tyres
RRC class
Class average
2025
2030
A
3.8
2%
2%
B
4.7
C
5.7
D
6.7
E
7.7
F
8.6
8% 33% 54%
3%
9% 34% 54%
1%
Source: estimated based on historical development
Market Market average with
average non-compliance
0%
6.18
6.54
0%
6.13
6.49
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
Class average
2012
2013
2014
2015
2016
2017
A
1.6
9%
15%
17%
19%
18%
20%
B
1.47
24%
31%
31%
33%
31%
32%
C
1.32
55%
44%
43%
41%
41%
38%
E
1.17
8%
7%
7%
7%
9%
7%
F
1.04
3%
3%
2%
1%
2%
2%
Market Market average with
average non-compliance
1.36
1.32
1.39
1.35
1.40
1.35
1.41
1.36
1.40
1.35
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
Class average
2012
2013
2014
2015
2016
2017
A
1.45
2%
3%
5%
6%
6%
8%
B
1.32
29%
27%
31%
32%
30%
34%
C
1.17
61%
56%
49%
45%
43%
38%
E
1.02
8%
13%
15%
17%
20%
18%
F
0.9
1%
1%
1%
0%
1%
1%
Market Market average with
average non-compliance
1.21
1.16
1.20
1.15
1.21
1.16
1.21
1.16
1.20
1.16
1.22
1.17
Source: Data from TOL (Tyres On-Line, Germany).
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Table 12: Current label Wet grip market shares for C3 tyres
Wet grip class
Class average
2012
2013
2014
2015
2016
2017
A
1.3
11%
4%
5%
6%
2%
3%
B
1.14
65%
46%
47%
53%
39%
42%
C
1
21%
47%
45%
38%
54%
51%
D
0.85
3%
2%
3%
3%
4%
4%
E
0.7
0%
0%
0%
0%
0%
0%
Market Market average with
average non-compliance
1.12
1.07
1.07
1.03
1.08
1.03
1.09
1.04
1.06
1.01
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
Class average
2025
2030
A
B
C
E
F
1.6
1.44 1.3
1.14 1
35% 30% 30%
4%
1%
1.44
40% 31% 25%
3%
1%
1.46
Source: estimated based on historical development
Market
average
Market average with
non-compliance
1.39
1.41
Table 14: Forecast of wet grip label distribution in the BAU scenario for C2 tyres
Wet grip class
Class average
2025
2030
A
B
C
1.45 1.3
1.14
10% 45% 37%
8%
0%
1.23
12% 47% 34%
7%
0%
1.24
Source: estimated based on historical development
E
1.0
F
0.9
Market
average
Market average with
non-compliance
1.19
1.20
Table 15: Forecast of wet grip label distribution in the BAU scenario for C3 tyres
Wet grip class
Class average
2025
2030
A
B
C
D
E
F
1.3
1.14 1
0.85 0.7
0.6
5% 47% 44%
4%
0%
0%
1.07
5% 49% 42%
4%
0%
0%
1.08
Source: estimated based on historical development
Market Market average with
average non-compliance
1.03
1.04
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
70.81
71.93
71.78
2012
70.67
71.98
72.19
2013
70.86
72.07
72.05
2014
70.80
72.03
71.71
2015
70.84
72.15
71.71
2016
70.73
71.97
71.69
2017
Source: Data from TOL (Tyres On-Line, Germany).
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Table 17: Forecast of average market noise levels in BAU scenario
Year C1
C2
C3
70.59
72.02
71.55
2025
70.50
72.05
71.46
2030
Source: estimated based on historical development
5.
-
-
-
P
OLICY
O
PTION
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:
o
Not 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.
P
OLICY
O
PTION
3 S
CENARIO 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.
o
By 2025 they will follow the same development as replacement tyres.
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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:
o
Share that would use the database to search for information: 51%
36
.
o
Expecting to purchase online: 21%.
-
Average of 21% and 51% = 36%.
Re-adjustment of the label for wet grip and rolling resistance:
o
Adding 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:
o
The 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
Class average 5.1
6.3 7.4
8.7
10
11.5 average
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
Class average
2025
2030
New A
4.1
5.3
B
6.4
C
7.7
D
8.9
E
Market
10.2 average
8.28
8.21
0%
1%
5%
39% 54% 1%
0%
2%
5%
42% 50% 1%
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
36
Question: “If a public database were to be established with information
on tyre performance areas shown on the
label, would you use the database to search for information when purchasing new tyres in the future?” (share of those
who answered “yes”).
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Class average 2.8
2025
0%
2030
1%
3.8
4.7
5.7
6.7
7.7
average
6.25
6.17
1%
8%
30% 57% 4%
1%
8%
32% 56% 2%
Source: estimated based on historical development
Table 21: Forecast of wet grip label distribution in the PO3scenario for C1 tyres
Wet grip class
Class average
2025
2030
New A
A
B
C
D
E
1.71
1.6 1.44
1.3 1.14
5% 34% 28% 29% 3% 1%
10% 38% 29% 20% 2% 1%
Source: estimated based on historical development
Market
1.0
average
1.45
1.49
Table 22: Forecast of wet grip label distribution in the PO3 scenario for C2 tyres
Wet grip class
Class average
2025
2030
New A A
B
C
D
1.56 1.45
1.3 1.14
3% 10% 44% 36% 7% 0%
6% 11% 45% 32% 6% 0%
Source: estimated based on historical development
Market
1.0 0.85
average
1.24
1.26
E
Table 23: Forecast of wet grip label distribution in the PO3 scenario for C3 tyres
Wet grip class
A+
E
Market
A
B
C
D
1.41
1.3 1.14
1.0 0.85
0.7
average
Class average
2%
5% 46% 45%
2%
0%
2025
1.08
4%
3% 51% 40%
2%
0%
2030
1.09
Source: estimated based on historical development
7.
P
OLICY
O
PTION
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.
-
-
E
FFECT OF
R
OLLING 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
.
37 https://ec.europa.eu/energy/en/topics/energy-efficiency/energy-efficient-products/tyres
38 http://www.applusidiada.com/en/aboutUs/inbrief
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-
In the calculations a share of 50% urban driving and 50% non-urban driving was
assumed.
���� ���� ����
����
����ℎ���� �������� % = ���� ∗
������������
− ������������
������������
����
∗
%
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 RRC
old
in this case refers to BAU1 (actual data), RRC
new
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
Increase in RRC
Decrease in RRC
Road type
Urban
Non-urban
Urban
Non-urban
C1
0.104
0.158
0.145
0.183
C2
0.098
0.118
0.109
0.125
C3
0.095
0.112
0.106
0.118
Source: IDIADA background report on the fuel savings calculator
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9.
E
FFECT OF
W
ET 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:
o
Passenger cars (C1 tyres)
o
Lorries <3.5 tons (C2 tyres)
o
Heavy goods vehicles >3.5 tons (C3 tyres)
o
Buses (C3 tyres)
o
Pedestrians 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
:
o
10% Severely injured
-
39
TNO, Memorandum To Ministry of Infrastructure and Environment, “Potential benefits of Triple-A
tyres in the
EU” Link:
http://www.unece.org/fileadmin/DAM/trans/doc/2014/wp29grb/GRB-60-13e.pdf
40
TNO, Memorandum To Ministry of Infrastructure and Environment, “Potential benefits of Triple-A
tyres in the
EU” Link:
http://www.unece.org/fileadmin/DAM/trans/doc/2014/wp29grb/GRB-60-13e.pdf
41 https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/statistics/dacota/asr2017.pdf
42 https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/observatory/historical_evol.pdf
43
https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/vademecum_2016.pdf
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o
90% slightly injured
The distribution of accidents by road type is divided into the following based on
2015 numbers
44
:
o
Urban
–
37,3%
o
Rural
–
55,0%
o
Motorway
–
7,8%
o
The 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/s
2
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
G
1,55 ≤ G
1,40 ≤G ≤ 1,54
1,25 ≤ G ≤ 1,39
Empty
1,10 ≤ G ≤ 1,24
G ≤ 1,09
Wet grip
class
A
B
C
D
E
F
G
C2 tyres
Wet grip
class
A
B
C
D
E
F
G
C3 tyres
Wet grip
class
A
B
C
D
E
F
1,40 ≤ G
1,25 ≤ G ≤ 1,39
1,10 ≤ G ≤ 1,24
Empty
0,95 ≤ G ≤ 1,09
G ≤ 0,94
1,25 ≤ G
1,10 ≤ G ≤ 1,24
0,95 ≤ G ≤ 1,09
0,8 ≤ G ≤ 0,94
0,65 ≤ G ≤ 0,79
G ≤ 0,64
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.
44 https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/statistics/dacota/asr2017.pdf
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Table 26: Braking distance for different wet grip levels compared to rating A. Assumed
equal for C1, C2 and C3 tyres.
Tyre label
A
B
C
D
E
F
Impact speed
Increased braking
distance (index A=100)
100
111
124
132
141
155
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
Initial speed (km/h)
Impact speed (km/h)
Urban road
car to car
50
30
Rural road car
to car
80
46
Motorway car
to car
120
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.
76
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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 Fatalities Serious
Slight
No injury
(km/h)
injuries
injuries
30
1.6%
7.1%
63.4%
27.9%
Urban
46
1.8%
22.7%
62.8%
12.7%
Rural
91
23.7%
61.2%
13.8%
1.4%
Motorway
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.
45
TNO, Memorandum To Ministry of Infrastructure and Environment, “Potential benefits of Triple-A
tyres in the
EU” Link:
http://www.unece.org/fileadmin/DAM/trans/doc/2014/wp29grb/GRB-60-13e.pdf
46 https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/statistics/dacota/asr2017.pdf
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10.
S
OCIETAL 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.
E
CONOMY 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.
47 Developing Harmonised European Approaches for Transport Costing and Project Assessment - http://heatco.ier.uni-
stuttgart.de/HEATCO_D5.pdf
48 Converted to 2017 price level - Developing Harmonised European Approaches for Transport Costing and Project
Assessment - http://heatco.ier.uni-stuttgart.de/HEATCO_D5.pdf
49 Sold production, exports and imports (NACE Rev. 2)
–
Product codes 22111100, 22111355, 22111357
50http://www.etrma.org/uploads/20170912%20-%20Statistics%20booklet%202017%20-
%20alternative%20rubber%20section%20FINAL%20web1.pdf and personal correspondence with ETRMA.
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Table 30 Turnover and employees - tyre manufacturers
Year
2012
2013
2014
2015
2016
Avg.
Turnover
million
EUR
17,634
16,800
16,813
16,801
16,836
16,977
Employees Turnover/
employee
EUR
257,434
68,501
258,440
65,007
260,124
64,635
272,018
61,764
281,839
59,738
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.
51 http://www.eurocommerce.eu/retail-and-wholesale-in-europe/facts-and-figures.aspx
52 Germany, France, UK, Spain, Italy
53 GfK data
54 http://www.daekonline.dk Based on 180 tyre models.
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RRC
–
WG
A
B
C
E
F
G
Table 31 Unit price matrix - 2017 EUR
–
GfK data
–
C1 tyres. *Identified as an outlier and
adjusted
A
121.8
94.6
101.4
124.5
115.0
80.7
B
92.2
91.0
89.9
96.6
107.8
103.3
C
86.2
86.4
76.0
63.0
80.0
E
F
78.1
73.7
70.7
61.8
66.3
73.7*
70.7*
Table 32 Unit price matrix - 2017 EUR
–
GfK data
–
C2 tyres. *Identified as an outlier and
adjusted
RRC - WG
A
B
C
E
F
G
A
140.6
119.7
112.1
116.9
77.1
B
126.8
124.4
121.5
114.5
77.4
C
125.4*
106.0
94.8
95.1
81.4*
E
124.6*
104.5
100.4
100.5
85.3
F
123.9
117.1
70.3
100.5*
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*
520,50*
505,24
491,38*
B
555,25*
535,81
532,66
477,60
C
503,72
519,41
535,44
529,07
546,86
D
E
382,93
410,08
368,68
506,99
360,48
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
A
B
C
E
F
G
RRC
<6.6 (6.3)
6.6
–
7.7 (7.2)
7.8
–
9.0 (8.4)
9.1
–
10.5 (9.8)
10.6
–
12.0 (11.3)
>12 (12.4)
WG
>1.54 (1.6)
1.54
–
1.40 (1.47)
1.39
–
1.25 (1.32)
1.24
–
1.10 (1.17)
<1.10 (1.04)
55 http://www.daekonline.dk Based on 180 tyre models.
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Table 35 Relation between label class, rolling resistance and wet grip
–
C2 tyres
Label Class
A
B
C
E
F
G
Label Class
A
B
C
D
E
F
RRC
<5.5 (5.3)
5.6
–
6.7 (6.2)
6.8
–
8.0 (7.4)
8.1
–
9.2 (8.7)
9.3
–
10.5 (9.9)
>10.5 (10.8)
RRC
<4.1 (3.8)
4.1
–
5.0 (4.6)
5.1
–
6.0 (5.6)
6.1
–
7.0 (6.6)
7.1
–
8.0 (7.6)
>8.0 (8.5)
WG
>1.39 (1.45)
1.39
–
1.25 (1.32)
1.24
–
1.1 (1.17)
1.09
–
0.95 (1.02)
<0.95 (0.89)
Table 36 Relation between label class, rolling resistance and wet grip
–
C3 tyres
WG
>1.24 (1.3)
1.24
–
1.1 (1.17)
1.09
–
0.95 (1.02)
0.94
–
0.8 (0.87)
<0.8 (0.72)
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
Wholesale
Manufacturer
25,511
59,241
63,929
2
1.25
1
12.
L
ABEL 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.
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Figure 3a/b: Wet grip label distribution for all sold tyres 2015-2017, for C1(a) and C2(b)
tyres.
Source: GfK
Wet grip label distribution (C1)
100%
90% 19%
80%
70%
60%
50%
40%
30% 41%
20%
10%
0%
2015
8%
41%
38%
33%
31%
32%
18%
20%
Label A
Label B
Label C
Label D-
F
Wet grip label distribution (C2)
100%
90%
80% 32%
70%
60%
50%
40% 45%
30%
20%
10% 17%
0%
2015
21%
2016
19%
2017
43%
38%
Label C
Label D-
F
6%
6%
30%
8%
Label A
34%
Label B
11%
2016
9%
2017
Figure 4: Wet grip label distribution for all sold C3 tyres 2015-2017.
Source: TOL
Wet grip label distribution (C3)
100%
90%
80%
70% 53%
60%
50%
40%
30%
20% 38%
10%
0% 3%
2015
4%
2016
4%
2017
54%
51%
Label D-F
6%
2%
39%
3%
42%
Label A
Label B
Label C
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.
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Figure 5a/b: Rolling resistance label distribution for all sold tyres 2015-2017, for C1(a) and
C2(b) tyres.
Source: TOL
RR label distribution (C1)
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
14%
18%
2016
16%
2017
0%
2015
42%
43%
41%
38%
34%
37%
Label A;
0,44%
Label A;
0,34%
RR label distribution (C2)
100% 5%
90%
70%
Label C
Label E
Label
F+G
Label A;
0,00%
Label A;
0,00%
5%
5%
6%
Label A;
0,47%
4%
4%
Label A;
0,00%
Label A
Label B
Label A
80% 29%
60%
50%
40%
30%
20%
10% 26%
0%
2015
40%
25%
28%
Label B
Label C
42%
41%
Label E
Label
F+G
30%
27%
2017
2016
Figure 6: Rolling resistance label distribution for all sold C3 tyres 2015-2017.
Source: TOL
Rolling resistance label distribution (C3)
100%
1%
90%
10%
80%
70%
36%
60%
50%
40%
30%
20%
10%
16%
0%
2015
Label C
1%
7%
29%
1%
7%
29%
Label A
Label B
38%
36%
40%
Label D
Label E+F
25%
2016
23%
2017
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.
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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
C1
A
B
C
D
E
F
G
sum
A
0,2%
2%
11%
0%
6,5%
1,0%
0%
20%
B
0,2%
3%
13%
0%
13%
4%
0,1%
32%
C
0%
1,1%
11%
0%
18%
7%
0,3%
38%
Wet Grip
D
E
0%
0,0%
0%
0,1%
0%
1%
0%
0%
0%
4%
0%
2%
0%
0,2%
0%
7%
F
0,0%
0,1%
0,6%
0%
0,8%
0,8%
0,1%
2%
G
0%
0%
0%
0%
0%
0%
0%
0%
sum
0%
6%
37%
0%
41%
15%
1%
Table 39: Current distribution of Rolling Resistance (RR) and Wet Grip (WG) labels for
C2 tyres sold in 2017.
Source: TOL
Rolling resistance
C2
A
B
C
D
E
F
G
sum
A
0,0%
1%
6%
0%
1,2%
0,3%
0%
8%
B
0,0%
2%
14%
0%
11%
7%
0,5%
34%
Wet Grip
C
D
0%
0%
0,2%
0%
6%
0%
0%
0%
24%
0%
7%
0%
1,1%
0%
38%
0%
E
0,0%
0,3%
2%
0%
5%
9%
0,6%
18%
F
0,0%
0,1%
0,1%
0%
0,2%
0,5%
0,0%
1%
G
0%
0%
0%
0%
0%
0%
0%
0%
sum
0%
4%
28%
0%
41%
25%
2%
Table 40: Current distribution of Rolling Resistance (RR) and Wet Grip (WG) labels for
C3 tyres sold in 2017.
Source: TOL
Rolling resistance
C3
A
B
C
D
E
F
G
sum
12.4
A
0,1%
1%
2%
1%
0,4%
0,1%
0%
3%
B
0,3%
5%
17%
14%
5%
1%
0,0%
42%
C
0%
2,2%
11%
23%
12%
2%
0,0%
51%
Wet Grip
D
E
0%
0,0%
0%
0,0%
0%
0%
1%
0%
1%
0%
1%
0%
0%
0,0%
4%
0%
F
0,0%
0,0%
0,0%
0%
0,0%
0,0%
0,0%
0%
G
0%
0%
0%
0%
0%
0%
0%
0%
sum
1%
7%
29%
40%
18%
4%
0%
Rolling resistance
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
84
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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
Noise level distribution (C1) [dB]
100% 3,2%
90% 12,0%
80%
70%
60%
50%
40%
30%
20%
10% 13,5%
0%
3,4%
2015
14,4%
3,3%
2016
15,0%
3,0%
2017
22,1%
22,0%
22,9%
17,1%
16,6%
17,0%
15,4%
16,3%
17,7%
≤67
68
69
70
71
72
≥73
3,7%
12,7%
3,6%
11,8%
100%
90%
80%
70%
Noise level distribution (C2)
[dB]
21,4%
22,3%
23,6%
≤70
13,7%
60%
50%
40% 27,6%
30%
20%
10%
15,7%
14,9%
15,1%
71
72
73
28,0%
30,4%
≥74
15,5%
4,2%
2016
14,3%
3,6%
2017
0% 4,6%
2015
Figure 8: Noise level distribution for all available C3 tyres 2015-2017.
Source: TOL
Noise level distribution (C3) [dB]
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
16%
14%
10%
15%
14%
18%
18%
17%
13%
13%
17%
9%
13%
2016
17%
17%
14%
14%
18%
9%
12%
2017
≤69
70
71
72
73
74
≥75
12%
0%
2015
Table 41: Average noise levels for C1-C3 tyres from 2015-2017.
Source: GfK/TOL
Avg. Noise level
C1
C2
C3
12.5
2015
70,13
71,64
71,71
Noise (Classes)
2016
70,09
71,59
71,71
2017
70,11
71,51
71,69
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
85
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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
Noise class distribution (C1)
78%
79%
16%
6%
18%
3%
2016
2017
Figure 10: Noise class distributions for available C2 tyres in 2016-2017.
Source: TOL
82%
Noise class distribution (C2)
86%
6%
12%
5%
9%
2016
2017
Figure 11: Noise class distributions for available C3 tyres in 2016-2017.
Source: TOL
Noise class distribution (C3)
45%
46%
48%
48%
8%
4%
2016
2017
86
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13.
P
ROPOSAL 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
a.
Scenario 1
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
A
B
1,39–
1,25
C
Empty
D
E
1,24–
1,10
1,24–
1,10
E
F
Empty
≤1,09
F
Empty
G
New
A
B
C
D
≥1,68
1,67-1,55 1,54-1,40 1,39–
1,25
G
Empty
C1 WG
87
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Table 43: Current and new label class intervals for wet grip in C2 tyres
Current
≥1,40
A
1,39–
1,25
B
1,24–
1,10
C
D
1,24–
1,10
Empty
D
E
1,09–
0,95
1,09–
0,95
E
F
Empty
≤0,94
F
Empty
G
New
A
B
C
≥1,53
1,52-1,40 1,39–
1,25
G
Empty
C2 WG
T
able 44: Current and new label class intervals for wet grip in C3 tyres
Current
≥1,25
A
A
≥1,38
B
1,37–
1,25
1,24–
1,10
B
C
1,24–
1,10
1,09–
0,95
C
D
1,09–
0,95
0,94–
0,80
D
E
0,94–
0,80
0,79–
0,65
E
F
0,79–
0,65
≤0,64
F
Empty
G
New
G
Empty
C3 WG
Table 45: Current Wet grip class intervals
C1 tyres
(Current)
C2 tyres
(Current)
C3 tyres
(Current)
Wet grip
Wet grip
Wet grip
G
G
G
class
class
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)
Wet grip
Wet grip
Wet grip
G
G
G
class
class
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
88
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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
≤6,5
6,6–7,7 7,8–9,0
Empty 9,1–10,5 10,6–12,0
Current
A
B
C
D
E
F
≥12,1
G
C1 RR
New
A
≤5,4
B
5,5–6,5
C
6,6–7,7
D
7,8–9,0
E
9,1–10,5
F
Empty
G
Empty
Table 48: Current and new label class intervals for rolling resistance in C2 tyres
Current
≤5,5
A
A
≤4,4
B
4,5–5,5
5,6–6,7
B
C
5,6–6,7
6,8–8,0
C
D
6,8–8,0
Empty
D
E
8,1–9,0
8,1–9,0
E
F
Empty
9,3–10,5
F
G
Empty
≥10,6
G
New
C2 RR
Table 49: Current and new label class intervals for rolling resistance in C3 tyres
Current
≤4,0
A
A
≤3,1
B
3,2–4,0
4,1–5,0
B
C
4,1–5,0
5,1–6,0
C
D
5,1–6,0
6,1–7,0
D
E
6,1–6,5
56
7,1–8,0
E
F
Empty
≥8,1
F
G
Empty
Empty
G
New
C3 RR
C1 tyres (current)
RRC in kg/t
RRC ≤ 6,5
6,6 ≤RRC ≤ 7,7
7,8 ≤RRC ≤ 9,0
Empty
9,1 ≤RRC ≤ 10,5
10,6 ≤RRC ≤ 12,0
RRC ≥ 12,1
Table 50: Current rolling resistance class intervals
C2 tyres (current)
C3 tyres (current)
Energy
Energy
efficiency
RRC in kg/t
efficiency RRC in kg/t
class
class
A
RRC ≤ 5,5
A
RRC ≤ 4,0
B
5,6 ≤RRC ≤ 6,7
B
4,1 ≤RRC ≤ 5,0
C
6,8 ≤RRC ≤ 8,0
C
5,1 ≤RRC ≤ 6,0
D
Empty
D
6,1 ≤RRC ≤ 7,0
E
8,1 ≤RRC ≤ 9,2
E
7,1 ≤RRC ≤ 8,0
F
9,3 ≤RRC ≤ 10,5
F
RRC ≥ 8,1
G
RRC ≥ 10,6
G
Empty
Energy
efficiency
class
A
B
C
D
E
F
G
56 A new upper limit is set as defined in the tyre-approval regulation No. 661/2009.
89
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Table 51: Proposed rolling resistance class intervals
C1 tyres (proposed)
C2 tyres (proposed)
C3 tyres (proposed)
Energy
Energy
Energy
RRC in kg/t
efficiency RRC in kg/t
efficiency
RRC in kg/t
efficiency
class
class
class
RRC ≤ 5,4
A
RRC ≤ 4,4
A
RRC ≤ 3,1
A
5,5 ≤RRC ≤ 6,5
B
4,5 ≤RRC ≤ 5,5
B
3,2 ≤RRC ≤ 4,0
B
6,6 ≤RRC ≤ 7,7
C
5,6 ≤RRC ≤ 6,7
C
4,1 ≤RRC ≤ 5,0
C
7,8 ≤RRC ≤ 9,0
D
6,8 ≤RRC ≤ 8,0
D
5,1 ≤RRC ≤ 6,0
D
9,1 ≤RRC ≤ 10,5
E
8,1 ≤RRC ≤ 9,0
E
6,1 ≤RRC ≤ 6,5
E
Empty
F
Empty
F
Empty
F
Empty
G
Empty
G
Empty
G
Table 52: Current and 'Scenario 1' - proposed distribution of wet grip and rolling
resistance of C1/C2/C3 tyres.
Source: GfK and TOL
For C1:
Current
RR/WG
A
B
C
D
E
F
G
sum
Proposed
(S1)
RR/WG
A
B
C
D
E
F
G
sum
A
0,2%
2%
11%
0%
6,5%
1,0%
0%
20%
B
0,2%
3%
13%
0%
13%
4%
0,1%
32%
C
0%
1,1%
11%
0%
18%
7%
0,3%
38%
Wet Grip
D
E
0%
0,0%
0%
0,1%
0%
1%
0%
0%
0%
4%
0%
2%
0%
0,2%
0%
7%
Wet Grip
A
0%
0%
0%
0%
0%
0%
0%
0%
B
0,2%
2%
11%
0%
6%
1%
0,0%
20%
C
0%
2,7%
13%
0%
13%
4%
0,1%
32%
D
0%
1%
11%
0%
18%
7%
0%
38%
E
0,0%
0,1%
1%
0%
4%
2%
0,2%
7%
F
0,0%
0,0%
0,0%
0%
0,0%
0,0%
0,0%
0%
G
0%
0%
0%
0%
0%
0%
0%
0%
sum
0%
6%
36%
0%
41%
14%
1%
F
0,0%
0,1%
0,6%
0%
0,8%
0,8%
0,1%
2%
G
0%
0%
0%
0%
0%
0%
0%
0%
sum
0%
6%
37%
0%
41%
15%
1%
Rolling resistance
Rolling resistance
90
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For C2:
Current
RR / WG
A
B
C
D
E
F
G
sum
Proposed
(S1)
RR / WG
A
B
C
D
E
F
G
sum
For C3:
Current
Rolling Resistance
Rolling Resistance
RR / WG
A
B
C
D
E
F
G
sum
Rolling resistance
A
0,0%
1%
6%
0%
1,2%
0,3%
0%
8%
A
0%
0%
0%
0%
0%
0%
0%
0%
B
0,0%
2%
14%
0%
11%
7%
0,5%
34%
B
0,0%
1%
6%
0%
1%
0%
0,0%
9%
Wet Grip
C
D
0%
0%
0,2%
0%
6%
0%
0%
0%
24%
0%
7%
0%
1,1%
0%
38%
0%
Wet Grip
C
0%
1,8%
14%
0%
11%
7%
0,5%
35%
D
0%
0%
6%
0%
24%
7%
1%
39%
Wet Grip
D
E
0,0%
0,3%
2%
0%
5%
9%
0,6%
18%
E
0,0%
0,3%
2%
0%
5%
10%
0,6%
18%
F
0,0%
0,1%
0,1%
0%
0,2%
0,5%
0,0%
1%
F
0,0%
0,0%
0,0%
0%
0,0%
0,0%
0,0%
0%
G
0%
0%
0%
0%
0%
0%
0%
0%
G
0%
0%
0%
0%
0%
0%
0%
0%
sum
0%
4%
28%
0%
41%
25%
2%
sum
0%
4%
29%
0%
41%
24%
2%
A
B
C
E
F
G
sum
0,1%
1%
2%
1%
0,4%
0,1%
0%
3%
0,3%
5%
17%
14%
5%
1%
0,0%
42%
0%
2,2%
11%
23%
12%
2%
0,0%
51%
0%
0%
0%
1%
1%
1%
0%
4%
Wet Grip
0,0%
0,0%
0%
0%
0%
0%
0,0%
0%
0,0%
0,0%
0,0%
0%
0,0%
0,0%
0,0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
1%
7%
29%
40%
18%
4%
0%
Proposed
(S1)
RR / WG
A
B
C
D
E
F
G
sum
A
B
C
D
E
F
G
sum
Rolling resistance
0,0%
0%
0%
0%
0,0%
0,0%
0%
0%
0,1%
1%
2%
1%
0%
0%
0,0%
3%
0%
4,7%
17%
15%
5%
0%
0,0%
43%
1%
2%
11%
24%
12%
0%
0%
51%
0,0%
0,2%
0%
1%
1%
0%
0,0%
3%
0,0%
0,0%
0,0%
0%
0,2%
0,0%
0,0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
1%
8%
31%
41%
19%
0%
0%
91
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c.
Proposal to new Noise level label intervals (Scenario 1 and 2)
The noise class intervals are based on the limit value (LV) set out in Part C of Annex II
of Regulation (EC) No 661/2009, and the actual external rolling noise measured value
(N). The proposed redistribution shown in Table removes all tyres surpassing the rolling
noise limit value. Furthermore, it introduces a new top class.
Table 53: Current and new label class intervals for noise for all tyre types
Class
Current
New
13.2
a.
N
≤ LV –
3
N
≤ LV –
6
Scenario 2
LV
–
3 <
N
≤ LV
LV
–
6 <
N
< LV
–
3
N
> LV
LV
–
3 <
N
≤ LV
Proposal to new Wet Grip index label intervals (Scenario 2)
For C1/C2 tyres, the empty D class is removed. Classes E and F are combined into a new
D class. For C3 tyres, the classes are combined based on the current market distributions
(See Table 58). This will combine classes A and B into a new A class, and classes E and
F into a new D class, visualized in Table . The current and proposed wet grip classes can
be seen in Table 54 and Table 55.
Table 54: Current and new label class intervals for wet grip in C3 tyres. Scenario 2
≥1,25
1,24–1,10 1,09–0,95 0,94–0,80 0,79–0,65
≤0,64
Empty
Current
A
B
C
D
E
F
G
New
A
B
C
D
≥1,10
1,09–0,95 0,94–0,80
≤0,79
E
Empty
F
Empty
G
Empty
C3 WG
S2
Table 55: Current Wet grip class intervals
C1 tyres
(Current)
C2 tyres
(Current)
C3 tyres
(Current)
Wet grip
Wet grip
Wet grip
G
G
G
class
class
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
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Table 56: Proposed Wet grip class intervals. Scenario 2
C1 tyres
(Proposed)
C2 tyres
(Proposed)
C3 tyres
(Proposed)
Wet grip
Wet grip
Wet grip
G
G
G
class
class
class
1,55 ≤ G
A
1,40 ≤ G
A
1,10 ≤ G
A
1,40 ≤ G ≤ 1,54
B
1,25 ≤ G ≤ 1,39
B
0,95 ≤ G ≤ 1,09
B
1,25 ≤ G ≤ 1,39
C
1,10 ≤ G ≤ 1,24
C
0,8 ≤ G ≤ 0,94
C
G ≤ 1,24
D
G ≤ 1,09
D
G ≤ 0,79
D
Empty
E
Empty
E
Empty
E
Empty
F
Empty
F
Empty
F
Empty
G
Empty
G
Empty
G
b.
Proposal to new Rolling Resistance index label intervals (Scenario 2)
For C1/C2 tyres, the empty D class is removed. Regulation No. 661/2009 naturally
removes classes F and G. The current E class is thus renamed to the new D class.
For C3 tyres, the regulation removes classes E and F, which results in 4 total classes. The
current and proposed rolling resistance classes can be seen in Table and 57.
Table 57: Current rolling resistance class intervals
C1 tyres (current)
C2 tyres (current)
C3 tyres (current)
Energy
Energy
Energy
efficiency
efficiency
efficiency
RRC in kg/t
RRC in kg/t
RRC in kg/t
class
class
class
RRC ≤ 6,5
A
RRC ≤ 5,5
A
RRC ≤ 4,0
A
6,6 ≤RRC ≤ 7,7
B
5,6 ≤RRC ≤ 6,7
B
4,1 ≤RRC ≤ 5,0
B
7,8 ≤RRC ≤ 9,0
C
6,8 ≤RRC ≤ 8,0
C
5,1 ≤RRC ≤ 6,0
C
Empty
D
Empty
D
6,1 ≤RRC ≤ 7,0
D
9,1 ≤RRC ≤ 10,5
E
8,1 ≤RRC ≤ 9,2
E
7,1 ≤RRC ≤ 8,0
E
10,6 ≤RRC ≤
F
9,3 ≤RRC ≤
F
RRC ≥ 8,1
F
12,0
10,5
RRC ≥ 12,1
G
RRC ≥ 10,6
G
Empty
G
Table 58: Proposed rolling resistance class intervals. Scenario 2
C1 tyres (proposed)
Energy
RRC in kg/t
efficiency
class
RRC ≤ 6,5
A
6,6 ≤RRC ≤ 7,7
B
7,8 ≤RRC ≤ 9,0
C
RRC ≥ 9,1
D
Empty
E
Empty
F
Empty
G
C2 tyres (proposed)
Energy
RRC in kg/t
efficiency
class
RRC ≤ 5,5
A
5,6 ≤RRC ≤
6,7
B
6,8 ≤RRC ≤ 8,0
C
RRC ≥ 8,1
D
Empty
E
Empty
F
Empty
G
C3 tyres (proposed)
Energy
RRC in kg/t
efficiency
class
RRC ≤ 4,0
A
4,1 ≤RRC ≤ 5,0
B
5,1 ≤RRC ≤ 6,0
C
RRC ≥ 6,1
D
Empty
E
Empty
F
Empty
G
93
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Table 59: Current and 'Scenario 2' - proposed distribution of wet grip and rolling
resistance of C1/C2/C3 tyres.
Source: GfK and TOL
For C1:
Current
RR/WG
A
B
C
D
E
F
G
sum
Proposed
(S2)
RR/WG
A
B
C
D
E
F
G
sum
For C2:
Rolling resistance
Rolling resistance
Current
RR / WG
A
B
C
D
E
F
G
sum
Proposed
(S2)
RR / WG
A
B
C
D
E
F
G
sum
A
0,2%
2%
11%
0%
6,5%
1,0%
0%
20%
B
0,2%
3%
13%
0%
13%
4%
0,1%
32%
C
0%
1,1%
11%
0%
18%
7%
0,3%
38%
Wet Grip
D
E
0%
0,0%
0%
0,1%
0%
1%
0%
0%
0%
4%
0%
2%
0%
0,2%
0%
7%
Wet Grip
A
0,2%
1,8%
10,9%
7,5%
0,0%
0,0%
0%
20%
B
0,2%
2,7%
12,9%
16,5%
0%
0%
0,0%
32%
C
0,1%
1,1%
11,3%
25,4%
0%
0%
0,0%
38%
D
0,0%
0,2%
1,8%
7,4%
0%
0%
0%
9%
E
0,0%
0,0%
0%
0%
0%
0%
0,0%
0%
F
0,0%
0,0%
0,0%
0%
0,0%
0,0%
0,0%
0%
G
0%
0%
0%
0%
0%
0%
0%
0%
sum
0%
6%
37%
57%
0%
0%
0%
F
0,0%
0,1%
0,6%
0%
0,8%
0,8%
0,1%
2%
G
0%
0%
0%
0%
0%
0%
0%
0%
sum
0%
6%
37%
0%
41%
15%
1%
A
0,0%
1%
6%
0%
1,2%
0,3%
0%
8%
A
0,0%
1,5%
5,5%
1,5%
0,0%
0,0%
0%
8%
B
0,0%
2%
14%
0%
11%
7%
0,5%
34%
B
0,0%
1,8%
14,3%
18,3%
0%
0%
0,0%
34%
Wet Grip
C
D
0%
0%
0,2%
0%
6%
0%
0%
0%
24%
0%
7%
0%
1,1%
0%
38%
0%
Wet Grip
C
0,0%
0,2%
6,1%
32,0%
0%
0%
0,0%
38%
94
D
0,0%
0,3%
2,4%
16,1%
0%
0%
0%
19%
E
0,0%
0,3%
2%
0%
5%
9%
0,6%
18%
E
0,0%
0,0%
0%
0%
0%
0%
0,0%
0%
F
0,0%
0,1%
0,1%
0%
0,2%
0,5%
0,0%
1%
F
0,0%
0,0%
0,0%
0%
0,0%
0,0%
0,0%
0%
G
0%
0%
0%
0%
0%
0%
0%
0%
G
0%
0%
0%
0%
0%
0%
0%
0%
sum
0%
4%
28%
0%
41%
25%
2%
Rolling Resistance
sum
0%
4%
28%
68%
0%
0%
0%
Rolling Resistance
 kom (2018) 0296 - Ingen titel
1896113_0096.png
For C3:
Current
RR / WG
A
B
C
D
E
F
G
sum
Proposed
(S2)
RR / WG
A
B
C
D
E
F
G
sum
A
0,1%
1%
2%
1%
0,4%
0,1%
0%
3%
B
0,3%
5%
17%
14%
5%
1%
0,0%
42%
C
0%
2,2%
11%
23%
12%
2%
0,0%
51%
Wet Grip
D
0%
0%
0%
1%
1%
1%
0%
4%
Wet Grip
A
0,4%
5,1%
18,2%
21,4%
0,0%
0,0%
0%
45%
B
0,5%
2,2%
10,7%
37,5%
0%
0%
0,0%
51%
C
0,0%
0,1%
0,4%
3,0%
0%
0%
0,0%
4%
D
0,0%
0,0%
0,0%
0,4%
0%
0%
0%
0%
E
0,0%
0,0%
0%
0%
0%
0%
0,0%
0%
F
0,0%
0,0%
0,0%
0%
0,0%
0,0%
0,0%
0%
G
0%
0%
0%
0%
0%
0%
0%
0%
sum
1%
7%
29%
62%
0%
0%
0%
E
0,0%
0,0%
0%
0%
0%
0%
0,0%
0%
F
0,0%
0,0%
0,0%
0%
0,0%
0,0%
0,0%
0%
G
0%
0%
0%
0%
0%
0%
0%
0%
sum
1%
7%
29%
40%
18%
4%
0%
Rolling resistance
Rolling resistance
95