Europaudvalget 2018
KOM (2018) 0296
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EUROPEAN
COMMISSION
Brussels, 17.5.2018
SWD(2018) 189 final
PART 3/3
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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Annex 5: Evaluation
Table of Contents
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
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Glossary for the evaluation report
Term or acronym
Meaning or definition
RRC
WG
BAU
OPC
SRTT
MSA
C1 Tyres
C2 Tyres
C3 Tyres
LCV
HCV
TCO
LCC
GHG emissions
OEM tyres
Rolling Resistance Coefficient
Wet Grip
Business as Usual
–
no label (Before regulation)
Open Public Consultation
Standard Reference Test Tyre
Market Surveillance Authority
Passenger car tyres
Light commercial vehicle tyres
Medium and Heavy commercial vehicle tyres
Light Commercial Vehicle
Heavy Commercial Vehicle
Total Cost of Ownership
Life Cycle Cost
Greenhouse Gas emissions
Original Manufacturer Equipment tyres, sold with
new vehicles
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1. Introduction - Purpose and scope of the evaluation
The Tyre Labelling Regulation 1222/2009
1
(hereafter called ‘TLR’) was
one of the
initiatives set out in the Commission Communication of 8 July 2008 entitled Greening
Transport
2
that aimed at increasing the sustainability of the transport sector and
contributing to achieve the EU 2020 Strategy on climate change and energy targets
3
.
Car tyres were identified as an important factor that impacts the fuel consumption and
pollution from road traffic, as 5% to 10% of fuel consumption is caused by the tyre
rolling resistance
4
. Furthermore, the grip of the tyres on wet road and the external rolling
noise are important parameters for increasing road safety and decreasing noise pollution
from road traffic, respectively.
The TLR was implemented to improve the performance of tyres sold in the EU with
respect to the fuel efficiency, wet grip and external rolling noise.
Pursuant to article 14
5
of the TLR, it should be reviewed by March 2016, in regard of
which a review study was carried out
6
. Based on the results from this 2016 Review
Study, the Commission decided to carry out an evaluation.
The purpose of the evaluation is to
quantify the effect of introducing the TLR
separately from the effect of the GSR. The intention is to determine the effect the label
has had on the tyre market, after five years of application of the tyre labelling scheme in
the European Union, in terms of increased performance in fuel efficiency, safety and
environmental noise by assessing the three performance parameters of the label; rolling
resistance, wet grip and external rolling noise.
Furthermore, the purpose of the evaluation is to
determine whether the TLR has been
effective and efficient in achieving its objectives, whether it is still relevant,
and
whether it is coherent with other EU regulations
and
brings added value to the EU
tyre market.
By answering these questions, the evaluation helps ultimately to
identify
the potential for improving the regulation
to better achieve its objectives, thus
supporting the Impact Assessment's policy options.
The evaluation looks at the development of tyre performance in all EU Member States
from 2005 to 2017, thus including the progress that took place in the years before the
Regulation started to apply in November 2012.
1 Regulation (EC) No 1222/2009 of the European Parliament and of the Council of 25 November 2009 on the labelling
of tyres with respect to fuel efficiency and other essential parameters, OJ L 342 of 22.12.2009, p.46
2
https://ec.europa.eu/transport/themes/strategies/2008_greening_transport_en
3
https://ec.europa.eu/info/business-economy-euro/economic-and-fiscal-policy-coordination/eu-economic-governance-
monitoring-prevention-correction/european-semester/framework/europe-2020-strategy_en
4
http://www.npc.org/reports/FTF-report-080112/Chapter_10-HD_Engines-Vehicles.pdf
and
https://www.fueleconomy.gov/feg/atv.shtml
5
The Commission shall assess the need to review this Regulation, presenting the result of this assessmentto the
European Parliament and the Council no later than 1 March2016, and, if appropriate, submit proposals to the European
Parliament and to the Council
6
https://ec.europa.eu/energy/sites/ener/files/documents/Study%20in%20support%20of%20the%20Review%20of%20th
e%20Tyre%20Labelling%20Regulation_final.pdf
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2. Background to the intervention
2.1.
D
ESCRIPTION OF THE INTERVENTION AND ITS OBJECTIVES
The TLR was designed to promote sustainable mobility in the light of the climate change
challenges and the need to support European competitiveness.
The TLR was introduced simultaneously with the Regulation on type approval of
“general safety of motor vehicles, their trailers and systems, components and separate
technical units intended therefore”
7
(hereafter the "General
Safety Regulation"
or
"GSR"). The GSR sets minimum requirements for tyre performance in terms of rolling
resistance and external rolling noise as well as wet grip for certain tyre types.
The two Regulations are intended to work in synergy; the GSR pushing the tyre market
towards higher performance by removing the lowest performing tyres from the Union
market, and the label introduced by the TLR pulling the market towards even higher
performance by providing end-users with the necessary information to identify and
purchase the best performing tyres on the market.
Before the implementation of the TLR, end-users did not have access to any harmonized
and reliable information about the fuel efficiency of tyres. Therefore, they were not able
to incorporate the possible fuel savings in their purchase decision.
The TLR was set up to encourage:
tyre manufacturers to optimise all three interrelated label parameters (rolling
resistance, external rolling noise and wet grip for certain tyre types) beyond the
minimum requirements in the GSR.
end-users to purchase more fuel-efficient tyres to reduce the environmental
impact of road transport.
end-users to purchase tyres with low external rolling noise to reduce traffic noise.
end-users to purchase tyres with high wet grip performance to improve road
safety.
The TLR sets out harmonised requirements on tyre parameter information to be provided
to end-users allow them to make informed purchasing choices. Three tyre performance
parameters are included: fuel efficiency, wet grip, and external rolling noise class and
measured value (in dB). An element of complexity is that improving one parameter such
as rolling resistance may have an adverse impact on other parameters such as wet grip,
while improving wet grip may have an adverse impact on external rolling noise.
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Figure 12: Example of the tyre label
a. Scope of the intervention
The TLR applies to C1, C2 and C3 tyres, as defined in article 8 of the GSR (C1 tyres can
generally be said to be tyres for passenger cars, C2 tyres for light commercial vehicles
(LCVs) and C3 tyres for heavy commercial vehicles (HCV’s). The definition of the tyre
types is based on the vehicles they are primarily designed for, including the weight and
passenger capacity, and on the tyre load and speed indexes of the tyres, as seen in Table
1. In general, C1 tyres can be said to be tyres for passenger cars, C2 tyres for light
commercial vehicles (LCVs) and C3 tyres for heavy commercial vehicles (HCV’s)
8
.
Table 59: Definition of tyre types included in the TLR, based on Regulation (EC) 661/2009
Seats in addition Vehicle weight
Designed
Load
Speed
Tyre
to driver’s seat
(based on
primarily for
capacity
category
(based on vehicle vehicle
type
vehicle categories
index
symbol
category)
category)
C1
tyres
C2
tyres
C3
tyres
M
1
, N
1
, O
1
and O
2
M
2
, M
3
, N, O
3
and O
4
M
2
, M
3
, N, O
3
and O
4
≤8
≥8
≥8
≤3.5 t
≥3.5 t
≥3.5 t
Not
Not
applicable applicable
≤121
≤121
≥122
≥N
≤M
none
The TLR does not apply to the following tyre types:
- re-treaded tyres;
8
European Commission (2014), “Frequently Asked Questions (Version 25/11/2014) for Regulation (EC) No
1222/2009 of the European Parliament and of the Council. Link:
http://ec.europa.eu/energy/sites/ener/files/documents/faq_-_tyre_labelling.pdf
100
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-
-
-
-
-
-
-
off-road professional tyres;
tyres designed to be fitted only to vehicles registered for the first time before 1
October 1990;
T-type temporary-use spare tyres;
tyres whose speed rating is less than 80 km/h;
tyres whose nominal rim diameter does not exceed 254 mm or is 635 mm or
more;
tyres designed only to be fitted on vehicles intended exclusively for racing.
tyres fitted with additional devices to improve traction properties, such as studded
tyres.
The TRL requires C1 and C2 tyres to bear the label. For C3 tyres the label is not required
but the information on rolling resistance, wet grip and rolling noise needs to be included
in the promotional documentation.
b.
The intervention logic
Objectives of the TLR.
The tyre label was introduced to provide end-users with
information on tyre parameters so that they can make an informed choice, and to
influence their purchase decisions in favour of more fuel efficient, safer, and quieter
tyres. Furthermore, it incentivises manufacturers to optimise those tyre parameters,
paving the way for more sustainable consumption and production.
Problems the TLR aimed to solve.
The tyre label was designed based on the experience
from the effect of the EU energy labelling scheme for household appliances (under
Directive 1992/75/EC), which had shown that energy labelling can have a significant
influence on consumer choice and market transformation towards more energy-efficient
products.
Before introducing the TLR, the absence of information gave rise to a market failure
preventing tyre end-users to consider fuel efficiency and related impacts in their
purchasing decisions. More concretely, the market failure identified by the Commission's
impact assessment
9
prior to proposing Regulation (EC) No 1222/2009 consisted of:
lack of information on the rolling resistance of tyres
–
the criteria for buying tyres
was influenced by price, size, appearance, alignment, etc. End-users had no
information on tyre rolling resistance;
lack of information on the relative energy efficiency of tyres
–
no tangible or
transparent way for an end-user
to understand a tyre’s capability to increase a
vehicle’s fuel economy and to secure fuel cost savings;
lack of information on the range of tyre attributes
–
end-users need to understand
better the interplay between the different tyre attributes (fuel efficiency, tyre
9 Impact Assessment COM(2008)779, SEC(2008)2861,
Link:
http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1458040597506&uri=CELEX:52008SC2860
Study EPEC 2008; “Impact Assessment Study on Possible Energy Labelling of Tyres”.
Link:
https://circabc.europa.eu/sd/a/99ffc67c-4422-4a38-9995-
e41e3a40c333/Technical%20Study%20on%20Possible%20Energy%20Labelling%20of%20Tyres.pdf
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safety and noise) to make rational choices between tyres with different properties
depending on end-user preferences.
The consequence of the market failure was an unexploited potential for lowering the
rolling resistance and rolling noise while increasing the wet grip performance.
The mechanisms set in place by the TLR.
The tyre labelling Regulation introduced a
label for tyres as seen above that includes three interrelated performance parameters:
-
Fuel efficiency:
The fuel efficiency of tyres is defined in terms of the
Rolling
Resistance Coefficient
(RRC), given as kg resistance per ton of vehicle (kg/t).
The lower the value for RRC, the better the fuel efficiency of the tyre.
-
Wet grip:
Wet grip refers to the safety performance of tyres, i.e. it reflects the
capacity of a tyre to brake on a wet road. Wet grip is determined based on the wet
grip index (G), calculated based on either the average deceleration in m/s
2
or the
peak brake force coefficient, which is unit-less, and compared to a Standard
Reference Test Tyre (SRTT). The better the wet grip, the safer the tyre.
-
External rolling noise:
The external rolling noise refers to the noise of the tyres
experienced outside the car (i.e. not by the driver or passengers). The external
rolling noise (N) is measured in decibel (dB).
The interrelation of the three parameters means that improving one may have an adverse
effect on another, due to the physical and chemical characteristics of the tyres. While the
best performing tyres, especially those with high performance in all parameters, generally
have a higher purchase price, the total cost of ownership (TCO), also called life cycle
cost (LCC) for the consumer is often lower for tyres with low rolling resistance due to
the increased fuel efficiency and the accompanying fuel cost savings over the whole life
of the tyre. To help end-users make an informed decision the label therefore shows the
rolling resistance converted to an A-G fuel efficiency scale. To avoid trade-offs in safety
and noise pollution while improving the rolling resistance, the wet grip scale is shown
next to the fuel efficiency scale on the label and the external rolling noise is added as a
three-step
scale (1 to 3 “sound waves”) below. This is intended to increase the demand
for tyres that have high performance in all three parameters in spite of the additional
purchase cost, which in turn is intended to encourage manufacturers to increase
innovation rate and optimise all three label parameters beyond the standard performance.
The synergy between the three parameters is therefore important, and end-users need
information on all three to make an informed purchasing decision.
2.2.
B
ASELINE AND POINTS OF COMPARISON
(BAU)
The base line of this evaluation will be the market without the implementation of the
TLR but including the effect of the type-approval process of the GSR. This baseline is
also referred to as Business as Usual (BAU).
The development in the BAU scenario is based on the future market estimates made in
the 2008 Impact Assessment under the no-label scenario for the years 2004-2017 for C1
and C2 tyres. However, for C3 tyres the future market estimates for the no-label scenario
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resulted in better tyre performance than can be observed from real-life data in the market
with
the label. The C3 BAU scenario was therefore adjusted to a more realistic level,
taking into consideration the available market data from a German tyre model database
10
.
The assumed distribution can be seen in Appendix 2.
In the 2008 Impact Assessment only the rolling resistance was included as a performance
parameter in the scenarios, while noise was not included at all and the wet grip was only
mentioned superficially and only for C1. The wet grip and noise market levels therefore
had to be estimated in the development of another Business as Usual scenario BAU0
using market data from 2008 until 2017. The data and estimates are shown in Appendix
2. .
The figures and table below show the BAU development for each label parameter
(rolling resistance, wet grip and noise) for C1, C2 and C3 tyres. The change occurring
around 2012 is induced by the GSR that sets minimum requirements for rolling
resistance and noise for all three tyres types (C1, C2, C3) as well as for wet grip on C1
tyres. Further limitations on maximum rolling resistance were introduced from 2014 for
C1 and C2 tyres and from 2016 for C3 tyres.
Figure 13: Development of average wet grip (WG) for each tyre type in BAU0
Wet Grip development in BAU0
1,30
1,20
Wet grip index
1,10
1,00
0,90
0,80
0,70
0,60
2008
2010
2012
2014
2016
C1 replacement
C2 Replacement
C3 replacement
Year
Source: Based on market distribution of WG adopted form the IA 2008 (Appendix 2)
10
http://www.tol-energy.de/
. The TOL database provides the most comprehensive and representative data on tyres
sold in the EU, as many importers and manufacturers transport their tyres through Germany, which are then
registered in this database. The data therefore provides an indication of the general European tyre market.
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Figure 14: Development of average rolling resistance (RRC) for each tyre types in BAU0
RRC development in BAU0
Rolling Resistance Coefficient,
RRC
14,00
12,00
10,00
8,00
6,00
4,00
2,00
-
2008
2010
2012
2014
2016
C1 replacement
C2 replacement
C3 replacement
Year
Source: Based on market distribution of RRC adopted form the IA 2008 (Appendix 2)
Table 60: External rolling noise levels for all tyre types in BAU0
Tyre type
External rolling
External rolling
noise, dB, 2008
noise, dB, 2017
71.20
71.05
C1
72.51
72.35
C2
72.00
71.85
C3
Based on the very low rate of development for external rolling noise seen from actual
data (i.e. the “Current label scenario” as described in chapter 3) from 2012 to 2017, it is
assumed that almost no development would have occurred without the TLR, as the
average levels were already below the noise limit values in the GSR. The average
external rolling noise levels in the BAU scenario are therefore assumed to change only
very little from 2008 to 2017 as seen in Table 60.
3. Implementation / state of Play
The TLR was adopted by the Council and the European Parliament in November 2009
and entered into force on 1 November 2012. Member States had thus three years to
implement the necessary market surveillance and enforcement processes.
The TLR provides a framework for the provision of harmonised information on tyre
performance and is directly applicable in all Member States. Enforcement is carried out
by national market surveillance authorities (MSAs) appointed in each Member State in
accordance with Regulation (EC) No 765/2008
11
. Interviews conducted with MSAs in
various Member States
12
in 2015 showed that the market surveillance effort varies
greatly throughout the EU, and in general, the only widespread activity is shop
inspections. Technical documentation is rarely requested for market surveillance
11 Regulation (EC) No 765/2008 of the European Parliament and of the Council of 9 July 2008 setting out the
requirements for accreditation and market surveillance relating to the marketing of products and repealing Regulation
(EEC) No 339/93, OJ L 218, 13.8.2008, p. 30.
12 Belgium, Finland, Germany (3 Länder), Estonia, Malta, Netherlands, Sweden, United Kingdom, Hungary, Poland
and Slovakia
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purposes and there is a severe lack of market surveillance testing due to a lack of
resources and limited number of testing facilities. Furthermore, the few Member States
which have conducted tests found that the repeatability and reproducibility of the test
results was very low.
The low market surveillance activity decreases end-user confidence in the tyre label.
Similarly, tyre dealers reported that due to lack of market surveillance inspections, they
decreased their efforts to train their employees in informing end-users of the labelling
scheme.
In response to the acknowledged lack of market surveillance and enforcement, the
Horizon 2020 funded the MSTyr15 project
13
was launched in April 2016 for a two-year
duration. Based on coordinated market surveillance actions by 15 countries
14
, the project
aims to perform 15,000 tyre inspections (shop inspections), 1,500 document inspections
and 150 tyre tests of rolling resistance and wet grip for C1 tyres by May 2018. The
results of the efforts are still to be published.
Aside from the enforcement issues, a general low awareness among C1 users was
identified in the 2016 consumer survey performed in the context of the 2016 Review
Study
15
. Only 41% of the respondents were aware of the tyre label before they responded
to the survey, and while more than 70% found the information on fuel efficiency and wet
grip easy to understand, less than 60% found the noise information easy to understand.
This indicates that for the full potential of the label to be realised both the general
awareness of the label’s existence and the specific knowledge of the label content would
need to be improved.
Despite the issues related to enforcement and awareness of the label, the rolling
resistance and wet grip have both improved since the label was first implemented, while
the pattern is less consistent for the external rolling noise parameter. The evolution of the
three label parameters can be seen in
Figure 16
to
Figure 18
in chapter 5.
4. Method
4.1.
S
HORT DESCRIPTION OF METHODOLOGY
This evaluation is partially based on the findings from the Review Study carried out in
2016
16
and the subsequent Open Public Consultation (OPC)
17
, but with market data
updated to 2017.
The evaluation calculations are based on a stock model, determining the number of tyres
of each type (C1, C2, C3) in the EU, which is shown in the table below. The stock model
is built on annual sales provided by the European Tyre and Rubber Manufacturers
13
http://www.mstyr15.eu/index.php/en/
14 Belgium, Bulgaria, Croatia, Estonia, Finland, Germany, Ireland, Latvia, Lithuania, Luxembourg, Poland, Romania,
Spain, Sweden and Turkey
15https://ec.europa.eu/energy/sites/ener/files/documents/Study%20in%20support%20of%20the%20Review%20of%20
the%20Tyre%20Labelling%20Regulation_final.pdf
16
http://www.labellingtyres.eu/
17 See Annex 2 of the 2018 Impact Assessment for the results and answers of the Open Public Consultation
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Association (ETRMA), combined with European Automobile Manufacturers
Association (ACEA) annual numbers on vehicles in use in EU
18
. The specific data and
assumptions are shown in Appendix 2
Table 61: Derived tyre stock in EU-28, from 2008 to 2017
Stock in millions
C1
C2
C3
Total
2008
2010
2012
2014
2016
1 461
126
62
1 650
2017
1 499
130
67
1 696
1 351
1 415
1 398
1 406
121
122
123
122
65
59
57
56
1 537
1 596
1 578
1 584
Source: Stock model, Viegand Maagøe 2018.
The calculated tyre stock gives an average of 5.5 tyres/C1vehicle, 4.1 tyres/C2 vehicle
and 12.2 tyres/C3 vehicle. The higher average number of tyres per vehicle for C1 than C2
is assumed to be due to the larger number of users having two sets of tyres for their car
(e.g. winter tyres in addition to summer tyres).
The development in rolling resistance, wet grip and external rolling noise with and
without the label regulation (i.e. the BAU and the current label scenarios) is used to
calculate the effect on fuel efficiency, safety and environmental noise. The specific
calculation methods are detailed in Appendix 2.
The fuel efficiency is correlated with the tyre rolling resistance based on the following
equation, derived by IDIADA
19
and used in the official “Fuel savings calculator” on the
Commission website on tyres
20
(K is a correlation factor determined by testing of tyres):
���� ���� ����
����
����ℎ���� �������� % = ���� ∗
������������
− ������������
����
������������
����
����
����
The correlation between wet grip and safety in terms of severity of accidents is much
more complex than that of rolling resistance and fuel efficiency. The wet grip is directly
correlated to the braking length, which is in turn related to the impact speed in accidents.
The correlation is based on data form a study undertaken by TNO in 2014
21
on the
potential benefits of Triple-A tyres in the EU. The probability distribution of fatality,
severe injury and minor injury varies with impact speed. Hence, a change in wet grip will
cause a change in accident severity or even in some avoided accidents. The methodology
and underlying calculations are explained in more detail in Appendix 2.
The external rolling noise is important for the environmental noise pollution from road
traffic, and the health effects experienced by those exposed to it. The exact correlation
between tyre noise and the health effects of environmental noise has not been thoroughly
identified. The World Health Organisation (WHO) is developing environmental noise
∗
%
18
http://www.acea.be/statistics/article/Report-Vehicles-in-Use
19
http://www.applusidiada.com/en/
20
https://ec.europa.eu/energy/en/topics/energy-efficiency/energy-efficient-products/tyres
21
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
106
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guidelines for the EU
22
and reports regarding the noise effects. Studies are ongoing (to be
finalised in 2018) and it is possible that a calculation model for quantitatively correlating
traffic noise with its health effects will also be developed. At the moment, only a
preliminary model is available, which has been used for estimating the health effects.
4.2.
I
NTERVIEWS AND END
-
USER SURVEY
As part of the 2016 Review Study
23
, an extensive stakeholder consultation was
performed, to assess the efficiency and effectiveness of the label scheme. Stakeholders
from across the supply chain (see Figure 15), 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.
Figure 15: Overview of the stakeholder groups directly and indirectly involved in the tyre
supply chain of both OEM (Original Equipment Market) and replacement tyre market
EU Member
States
Market
Surveillance
Authorities
Car
suppliers
C1 tyre
dealers
LCV
suppliers
Tyre
suppliers
Tyre wholesalers
(B2 B)
C2 tyre
dealers
Heavy truck
suppliers
C3 tyre
dealers
Heavy truck
distributors
C3 end-users
LCV
distributors
C2 end-users
Car
distributors
C1 end-users
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)
22http://www.euro.who.int/en/health-topics/environment-and-health/noise/activities/development-of-who-
environmental-noise-guidelines-for-the-european-region
23https://ec.europa.eu/energy/sites/ener/files/documents/Study%20in%20support%20of%20the%20Review%20of%20
the%20Tyre%20Labelling%20Regulation_final.pdf
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England (~29 million cars)
France (~32 million cars)
Italy (~37 million cars)
Sweden (~4.5 million cars)
Finland (~3 million cars)
The consumer survey was supplemented with answers from the OPC. More details about
the stakeholder consultation are presented in Appendix 1.
4.3.
L
IMITATIONS AND ROBUSTNESS OF FINDINGS
The major limitation of the findings is the
inability to directly correlate the external
rolling noise reported on the label to societal consequences in terms of human
health.
It is reasonable to expect that decreasing tyre rolling noise will result in a
decreasing number of people exposed to excessive traffic noise. However, the effect in
terms of hospitalisations and fatalities cannot be quantified.
Also, the correlation between wet grip and safety (in terms of number of accidents,
fatalities and injured in the traffic) relies on several crucial assumptions, such as the
likelihood of sustaining various degrees of injury in a traffic accident based on the impact
speed (as explained in Appendix 2).
Another important limitation is the lack of available data on non-compliance with the
label values; i.e. the number of tyres that do not live up to the declared label values, and
how much the actual performance varies from the reported performance for these
products. This might result in a larger estimated saving than actually achieved, because
the modelling is based on reported label values.
5. Analysis and answers to the evaluation questions
5.1.
E
FFECTIVENESS
a. Evaluation question 1: what have been the effects of the intervention?
The Review study from 2016 and the results from the OPC show that the objectives of
the TLR have been achieved to some extent, but that the effect is reduced due to
relatively low consumer awareness, lack of visibility of the label in the purchase situation
and weak enforcement resulting in low confidence in the label.
The consumer awareness affects effectiveness of the TLR because it is reliant on
affecting consumers’ choice when purchasing tyres and with low awareness and
confidence, users will be less likely to take the label into account in a purchase situation.
The lack of visibility of the label before a purchase decision is taken, is contributing to
the low awareness and thus decrease the overall effectiveness of the TLR.
The rolling resistance and wet grip performance of tyres have improved since
implementation of the TLR in 2009, as seen from the data in
Figure 16
and
Figure 17
,
whereas the effectiveness on noise is questionable (
Figure 18
). As seen in the graphs
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below, the rolling resistance and wet grip improvements of all three tyre types (C1, C2,
C3) subside after 2013. For C3 tyres (trucks and busses) there is even an increase in
average rolling resistance from 2015 to 2017 and a simultaneous decrease in wet grip.
Figure 16: Development of average rolling resistance for all tyre types in BAU1
Development of RRC in BAU1
14,00
12,00
RRC
10,00
8,00
6,00
4,00
2005
2007
2009
2011
Year
2013
2015
2017
C1 Replacement
C2 Replacement
C3 replacement
Source: Based on data on market distribution from TOL/GfK (Appendix 2)
Figure 17: Development of average wet grip for each tyre type with the current label
Wet grip development, BAU1
1,60
Wet grip index
1,40
1,20
1,00
0,80
0,60
2005
2007
2009
2011
2013
2015
2017
C1 replacement
C2 replacement
C3 replacement
Year
Source: Based on data on market distribution from TOL/GfK (Appendix 2)
Figure 18: Development of average external rolling noise for all tyre types in BAU1
External rolling noise development, BAU1
External rolling noise, dB
73,00
72,50
72,00
71,50
71,00
70,50
70,00
2005
2007
2009
2011
2013
2015
2017
C1 replacement
C2 Replacement
C3 replacement
Year
Source: Based on data on market distribution from TOL/GfK
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The reverse development for C3 tyres could be due to a variety of reasons, but one is that
C3 tyres are often purchased by procurement departments in professional fleets, and that
the focus is on purchase price rather than total cost of ownership. Also, the label is not
shown for C3 tyres, but only the values are given in the technical promotional material,
which could result in lower awareness of the label criteria and their significance.
Furthermore, other parameters such as mileage might play a bigger role for C3 fleet
operators than for private consumers and C2 users, since the yearly distances driven with
C3 vehicles are often much higher.
In general, the C3 tyre market fluctuates more for all three label parameters than the C1
and C2 markets. This variation is most pronounced for the external rolling noise
parameter, which does not show the same smooth development as the rolling resistance
and the wet grip, but overall still shows a declining tendency for all tyre types.
The decrease in rolling resistance has resulted in cumulative fuel savings of
approximately 1200 PJ from 2010 to 2017, corresponding to 170 PJ per year in saved
fuel consumption
24
. According to official EU statistics the energy consumption of the
road transport sector was around 12,300 PJ in 2015
25
. The annual savings are thus around
1% of road transport fuel consumption.
The difference in total fuel consumption of all vehicle types (C1, C2, C3) in the EU-28 in
the BAU and the Current Label Scenario is shown in Figure 19. The saved fuel
consumption is directly linked to corresponding avoided greenhouse gas (GHG)
emissions of around 88 MT CO
2
-eq
26
as well as other pollutant emissions related to road
transport.
Figure 19:
Development of fuel consumption for all tyre types (C1, C2, C3) in EU-28 from
2005 to 2017 for the BAU and Current Label Scenario
Fuel consumption for all types PJ/a
13 600
13 400
Energy consumption, PJ
13 200
13 000
12 800
12 600
12 400
12 200
12 000
2005
2007
2009
2011
Year
2013
2015
2017
Current
Label
BAU
Source: Calculation by external consultants Viegand Maagøe
24
Based on calculations models developed by consultants from Viegand Maagoe
25 EU statistical pocketbook, European Commission, 2017
https://ec.europa.eu/transport/sites/transport/files/pocketbook2017.pdf
26
Based on calculations models developed by consultants from Viegand Maagoe
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Regarding safety, the observed improvement in wet grip performance is estimated to
have led to 1,825 avoided fatalities in traffic accidents and 29,640 less people severely
injured from 2010 to 2017
27
. At the same time, however, an additional 43,122 people
suffered minor injuries because the accidents became less severe (i.e. the accidents with
avoided severe injuries instead resulted in minor injuries)
28
. The total societal costs
savings of the avoided fatalities and accidents amount to approximately EUR 9,600
million in the entire period the Regulation has been in place, or EUR 1,200 million per
year. The development of safety health costs for the BAU and the Current Label Scenario
is shown in Figure 20 for the years 2006 to 2017.
Figure 20: Development of safety health costs for all tyre types
15.000
14.500
14.000
13.500
Current
Label
Safety Health costs
BAU
Mln. EUR
13.000
12.500
12.000
11.500
11.000
10.500
10.000
2006
2008
2010
2012
Year
2014
2016
Source: Calculation by external consultants Viegand Maagøe
The external rolling noise of tyres is the parameter for which the TLR has been least
effective in changing the market. Even though noise levels have decreased slightly for all
three tyre types, the decrease is rather tenuous with fluctuating noise levels from year to
year, and overall less than 0.5 dB decrease is observed from 2005 to 2017 (See Figure
18). The small effect on external rolling noise compared to the other label parameters, is
thought to be because both industry and end-users give noise a lower importance than
other parameters
29
. Furthermore, the rolling noise pictogram is the label parameter that
end-users find most difficult to understand according to both the consumer survey from
the 2016 Review Study and the OPC responses.
Nevertheless, overall external rolling noise has decreased slightly, which might have led
to an unquantifiable number of people experiencing less severe noise nuisance from road
traffic. Road and traffic noise is causing health effects such as sleep deprivation,
27 Based on calculations models developed by consultants from Viegand Maagoe
28 Based on calculations models developed by consultants from Viegand Maagoe
29 According to the consumer survey made in relation to the 2016 review study, 34% found fuel efficiency very
important, 62% found wet grip very important and only 21% found external rolling noise very important. Industry
declared during the review study that the focus was first on developing tyres with good wet grip and rolling resistance,
and noise had lower priority.
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increased stress and ultimately hospitalisation or death due to coronary heart disease and
cerebrovascular disease. A report from 2014
30
estimated that traffic noise above 55 dB
caused around 8,900 deaths and 38,150 hospitalisations per year.
Since the external rolling noise remains above 70 dB on average, and the actual noise
nuisance experienced depends on several factors not affected by the tyre itself (e.g.
distance to the road, noise barriers, pavement type and speed limits), it is not possible to
quantify the actual change in number of people affected by road noise due to the TLR.
Even though the TLR has resulted in savings of about 1% annual fuel consumption, more
than 90% of tyres sold are still in fuel efficiency class C to F, and only 6-8% are in class
A or B. A potential thus exists for further energy savings, which can be obtained without
compromising road safety (wet grip), since tyres with fuel efficiency and wet grip
performance class combinations “AA” or “AB/BA” are already on the market. However,
the energy savings obtained through the labelling scheme is being somewhat
counteracted by a trend towards larger tyres (due to deliberate consumer choice), which
tends to increase absolute fuel consumption, even though these tyres are more fuel
efficient than earlier models of that size
31
.
The effectiveness of the scheme is reduced by the low degree of enforcement and market
surveillance, which prevents the full savings potential to be realised. This has been
assumed to cause relatively high non-compliance rates
32
of the recorded label values for
tyres sold in the EU. One of the barriers for market surveillance reported by some
MSAs
33
and by the PROSAFE MSTyr15 project is the problems experienced when
trying to obtain technical documentation. According to these sources it is sometimes
difficult and time consuming to identify the party responsible for providing the
information, and then to receive the complete information. Furthermore, the uncertainty
of the test methods leads to low reproducibility of test results, making it difficult for
MSAs to prove non-compliance in the cases when they find it by testing. An MSA
interviewed for the 2016 Review Study stated that the same tyre tested on two different
tracks could vary up to 3 label classes on the wet grip scale in some cases.
b. Evaluation question 2: To what extent do the observed effects link to the
intervention?
The observed market change in especially RRC and WG is likely to be largely linked to
the TLR. It is possible that the effects are in part due to other factors such as general
innovation and market trends towards more fuel efficient tyres, independent of the TLR.
However, as seen from the graphs (Figures 5 to 8), there was only very minor
development in the label parameters before the regulation was adopted in 2009.
30
http://www.rivm.nl/en/Documents_and_publications/Scientific/Reports/2014/december/Health_implication_of_road_
railway_and_aircraft_noise_in_the_European_Union_Provisional_results_based_on_the_2nd_round_of_noise_mapp
ing
31
According to industry members consulted during the Review Study, 2016
32
In the Current Label value, a 15% non-compliance rate is assumed with the average non-compliance magnitude of 2
classes lower than recorded on the label, based on preliminary results from the PROSAFE MSTyr15 project..
33
In interviews conducted in relation to the 2016 Review Study
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A report in
the TLR’s impact on innovation from 2014
34
found that the label had a
positive impact on the innovation activities in the tyre supply chain. Not only tyre
manufacturers, but also rubber and plant manufacturers were affected positively, since
the improvement of the label parameters are heavily reliant on rubber compounds and
new compounds require the development and adaption of machinery. According to the
innovation study, manufacturers stated that innovation activities started around four years
before the legislation came into place, which is also seen by the development in the label
parameters (Figure 16 to Figure 18).
According to the innovation study, the work towards more efficient tyres was initiated
before the TLR was implemented, but the label provided a “strong additional impulse” in
innovation
35
. Furthermore, the “background” improvement is also included in the BAU
scenario of this evaluation, thus taking into account the expected performance
development without any intervention. The first tyre with class A for rolling resistance
and for wet grip (so-called AA tyre) was presented in the spring 2012, but due to changes
in production lines, it was not marketed before January 2015, which was the first year
AA tyres became available on the market
36
.
Another intervention influencing the tyre performance parameters on the label is the
GSR, setting minimum efficiency requirements for the performance parameters on the
label. However, the effect of the GSR is taken into account in the BAU scenario and
therefore the difference between the BAU and the current label scenario can be assumed
to be very closely linked to the TLR. Furthermore, the GSR does not set minimum
requirements on wet grip for C2 and C3 tyres, and the development of WG for these tyre
types can therefore not be linked to the GSR.
c. Evaluation question 3: To what extent can these changes/effects be credited
to the intervention?
Some of the observed effects already took place in the years before the regulation was
adopted. However, the observed effect (difference between BAU and Current Label
Scenario) is still linked to the TLR because the manufacturers adapted to the foreseen
Regulation (from 2009) even before it entered into force (in 2012), as mentioned earlier.
It should be noted that the average label values before 2012 are not based on actual data,
but on estimates from the 2008 Impact Assessment (which were based on expert
statements)
37
. The development before 2012 is thus more uncertain than the effect seen
after 2012. However, it is expected that most of these changes were a response to the
34
Ecofys, Impact of Ecodesign and Energy/Tyre Labelling on R&D and technological innovation,
https://www.ecofys.com/files/files/fraunhofer-ecofys-2014-impact-of-ecodesign-energy-labelling-on-innovation.pdf
35
Ecofys, Impact of Ecodesign and Energy/Tyre Labelling on R&D and technological innovation,
https://www.ecofys.com/files/files/fraunhofer-ecofys-2014-impact-of-ecodesign-energy-labelling-on-innovation.pdf
Page 25
36
http://news.cision.com/goodyear-dunlop-uk-newsroom/r/goodyear-achieves-top-ratings-in-tyre-labelling-with-
introduction-of-eight-aa-tyre-sizes,c9716749
37
https://circabc.europa.eu/sd/a/99ffc67c-4422-4a38-9995-
e41e3a40c333/Technical%20Study%20on%20Possible%20Energy%20Labelling%20of%20Tyres.pdf
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GSR, whereas the effects of the TLR are more pronounced after 2012, when consumers
were first presented with the label in purchase situations.
d. Evaluation question 4: To what extent can factors influencing the observed
achievements be linked to the EU intervention?
Even though the TLR as a whole has been effective in increasing fuel efficiency level, it
has been less effective for C3 tyres than for C1 and C2 tyres, primarily due to the way C3
are purchased compared to C1 and C2 tyres. This is not related to the intervention itself
but rather to the market structure of the C3 market.
For larger fleets, procurement departments are often responsible for the purchases, and
they are typically less focused on fuel efficiency than on purchase price and mileage
(which influences the frequency with which new tyres have to be purchased).
Furthermore, some C3 tyres are sold through service schemes, which resemble a leasing
solution, where the tyre supplier does not bear the fuel costs and therefore does not attach
a high importance to fuel efficiency. Combined with purchase cost focused procurement
departments, the label information might thus receive little attention in purchase
decisions.
Several other factors have reduced the achievements of the TLR, including low consumer
awareness, lack of visibility of the label in purchase situations, weak enforcement and
inaccurate test procedures.
Some of these factors are linked to the intervention itself while other factors are linked to
the national implementation or non-compliance of market actors.
Factors linked to the TLR itself include the lack of a requirement to show the label when
tyres are offered for sale on the internet and that labelling is not always required for
OEM tyres, which influences the visibility of the label and thus consumer awareness.
Furthermore, the TLR itself affects the enforcement based on the facts that:
-
-
-
the label values are based on self-declaration by the manufactures;
the defined calculation methods for establishment of the wet grip performance
cause uncertainties;
no detailed explanation of the content of technical documentation is required.
These factors are all linked to the TLR itself and can thus be improved by changing the
regulation. Regarding visibility of the label during internet sales, 12% of C1 end-users
purchased their last set of tyres online, with 56% planning to buy tyres on the internet in
the future
38
. According to input to the OPC from Deutsche Umwelthilfe e.V. it is
important that consumers who buy tyres from on-line shops are provided with complete
information and that this requires in particular an image of the label, which due to its
recognition value, enables comparisons.
38 Review study on the Regulation (EC) No 1222/2009 on the labelling of tyres. March 2016. Consumer survey
among 6000 car owners in Germany, England, France, Italy, Sweden and Finland (1000 per country)
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In the OPC nearly 60% of the 70 respondents answered that they would be more
confident in the label’s information if third party
verification were mandatory and nearly
the same percentage is of the opinion that third party verification should be a
requirement
39
.
In addition, several stakeholders mentioned independent testing as a means to guarantee
the credibility of the label (FOEN
40
) and to make a positive contribution to the
confidence in the label (Verband der TÜV e.v.). However, industry (ETRMA and
Goodyear) does not support the introduction of third party testing because they see no
benefits compared to improving market surveillance efforts and that it might be
disproportionate to the available infrastructure of testing institutes/type approval authorities’
laboratories.
e. Conclusion on effectiveness of the TLR
So far, the tyre labelling scheme has shown its effectiveness by being able to
transform
the market in a positive direction from 2012 to 2017 for the rolling resistance and
wet grip
parameters.
For external rolling noise the label cannot be said to have been
effective
as it is not possible to unambiguously relate the effect solely to the TLR.
Since only one other intervention (the GSR) affects the tyre performance parameters
included in the label, and the effect of this intervention is taken into account in the BAU
scenario,
the effects on rolling resistance and wet grip can be attributed directly to
the TLR.
However, due to the low label awareness among consumers, the effect is not as
great as it would have been with higher awareness. In the consumer survey from the 2016
Review Study, 90% of respondents found the label information
“useful” or “very useful”,
but only 41% stated that they knew the label before the questionnaire. This indicates that
the label would be more effective if the awareness was higher.
The effectiveness of the scheme is reduced due to relatively low consumer awareness,
consumer preferences, weak enforcement and inaccurate test procedures, especially for
the wet grip tests which can give 3-4 classes of difference when tested at different tracks.
This was highlighted by MSAs interviewed for the 2016 Review Study
41
as a problem for
enforcement and a potential for improvement.
Consumer awareness and confidence in the label is particularly important since the TLR
does not require manufacturers to produce tyres with higher performance, but this is
rather a result of increased end-user demand for such tyres. Hence, if user
awareness or
confidence in the label is low, tyres with high performance according to the label
parameters will not have a market advantage,
but rather the opposite since they are
often sold at higher prices. Visibility of the label is therefore important especially in the
case of tyres sold online and for OEM tyres.
39 36% support third-party verification for every tyre model, 22% for representative sample of tyres
40 Federal Office for the Environment,
https://www.bafu.admin.ch/bafu/en/home.html
41https://ec.europa.eu/energy/sites/ener/files/documents/Study%20in%20support%20of%20the%20Review%20of%20
the%20Tyre%20Labelling%20Regulation_final.pdf
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5.2.
E
FFICIENCY
a. Evaluation question 1: To what extent has the intervention been cost-
effective?
While the costs of labelling will fall on manufacturers in the first place, they will pass on
any extra costs to end-users who will benefit from cost savings linked to the performance
of the products that outweigh the upfront costs
42
.
Increased tyre performance has resulted in increased purchase prices for end-users, but
this is offset by lower fuel consumption, which results in greater cost savings over the
tyre lifetime. The total costs of ownership (TCO)
43
over the life time of tyres are lower
with the implementation of the label than without, for both C1/C2 and C3 tyres. On
average, tyre labelling is estimated to have saved C1 end-users an average of 60
Euro/year, C2 end-users an average of 118 Euro/year and C3 end-users an average of 673
Euro/year
44
from 2010 to 2017.
However, for C3 tyres the TOC improvements seen in the Current Label Scenario went
down in 2016 and 2017, as seen in
Figure 21
below. The reduction in benefits occurs
because of the second stage of rolling resistance requirements in the GSR, which causes
the rolling resistance levels to decrease in the BAU scenario, which thus “catches up”
with the development otherwise experienced in the current label scenario. This indicates
that even though the TLR was cost efficient for end-users in the years 2010-2015, it gives
no further savings in 2016 and 2017, when the market is pushed by the GSR towards
higher fuel efficiency.
The reasons why the TLR is less efficient for C3 tyres than C1 and C2 tyres are linked to
the way C3 tyres are purchased as explained in section 5.1.4. As a result, for C3 tyres the
TLR does not achieve better rolling resistance levels than the BAU scenario (after the
second stage of the GSR), and thus it is not more cost efficient.
It is however important to note that even though the TOC for C3 end-users does not
improve compared to the BAU scenario in the years 2016 and 2017, improvement
was
seen in the years 2010 to 2015. Furthermore, although the effect of the improved wet grip
performance for C3 tyres is not included in the TOC calculation (as there isn’t a directly
derived cost effect), end-users still benefit in terms of less severe and fewer accidents.
42 Evaluation of the Energy Labelling and Ecodesign Directives SWD(2015) 143 final
43 The total costs of ownership include the purchase price of the tyre and the costs for fuel in the life time of the tyre.
44 Based on calculation models developed by consultants at Viegand Maagøe. The figures are in total direct savings
(fuel savings minus purchase price), in TCO (Total Cost of Ownership) of a full set of tyres (4 for C1 and C2, 10
for C3).
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Figure 21: Total Cost of Ownership for end-users of C3 tyres in BAU and with the label
End user Total Cost of Ownership, TCO
85 000
80 000
75 000
EUR
70 000
65 000
60 000
55 000
50 000
2005
2007
2009
2011
Year
2013
2015
2017
BAU - C3
Current
Label - C3
Source: based on unit prices from GfK and sales for ETRMA
Since the introduction of the TLR both tyre performance and purchase prices of tyres
have increased. According to ETRMA
45
the TLR has encouraged manufactures to
upgrade their products in the context of increased competition on the European market.
However, no data is available to make a conclusive connection between increased sale
prices and increased costs for development and production of improved tyres.
Based on product prices from GfK the annual retailer turnover has been calculated and
mark-up factors have been used to estimate the corresponding turnover for wholesalers
and manufacturers (see Appendix 2), which is seen in
Figure 22
below.
Figure 22: Turnover for tyre manufacturers, wholesalers and retailers in EU-28 for the
tyres included in scope of the Regulation
Source: unit sales prices from GfK combined with sales data
45 ETRMA input to Inception Impact Assessment
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It is important to bear in mind that although the label is mandatory there is no obligation
for manufacturers to improve the performance of the product. Experiences from the EU
energy labelling of energy-related products show strong evidence that manufacturers
have reacted positively to the EU energy labelling scheme and consider the label as an
important instrument to differentiate their products. This also suggests that the extra
investments needed to achieve higher efficiency levels have generally been outweighed
by the benefits
46
.
As the labelling is based on self-declaration, no excessive testing costs are put on the
manufacturers. The current test costs depend on the tyre type, but can be estimated for all
three label parameters
47
:
-
-
-
3,500-4,000 Euro for C1 tyres
4,000-4,500 Euro for C2 tyres
5,000-6,000 Euro for C3 tyres
For each model family with up to 10 different tyre sizes, at least one test needs to be
performed. It is not possible to estimate the total testing costs for manufacturers because
no data of the actual number of tyres sold of each model are available. However, as
mentioned above manufacturers have so far been able to pass most of the additional costs
for testing in relation to the tyre labelling on to end-users. According to a 2014 study
48
manufacturers stated that the TLR provided a tool for differentiating their products,
making it easier to achieve a return on investment in innovation, because it provided
information on an otherwise low-interest product.
In the 2008 Impact Assessment
49
, test costs of around 2,300 Euro were estimated for wet
grip grading alone, with a need for 1,100 tests per year. No data estimates were given for
the other label parameters. Since the TLR includes not only wet grip, but also rolling
resistance and external rolling noise, the actual test costs mentioned above are higher
than estimated in 2008. The number of tests depends on the number of different tyre
models placed on the market each year, and with around 4,000 new models per year
50
around 1,000 individual tests seems reasonable. It can therefore be assumed that the wet
grip testing costs estimated in the 2008 Impact Assessment have been materialised, with
the addition of the cost for rolling resistance and external rolling noise.
Distributors and dealers must ensure that C1 and C2 tyres bear the label at the point of
sale and they will have to cover the administrative costs for this activity. Although no
quantitative data is available, costs for dealers to show the label on displayed products is
widely accepted within the framework of the EU energy labelling scheme for energy-
related products. In addition, the dealers will benefit from higher turnover due to
46 Ecofys, Evaluation of the Energy Labelling Directive and specific aspects of the Ecodesign Directive, June 2014.
47 Source: Information from ETRMA
48
https://www.ecofys.com/files/files/fraunhofer-ecofys-2014-impact-of-ecodesign-energy-labelling-on-innovation.pdf
page 25
49
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52008SC2860&from=EN
–table
16 on page 51.
50
Based on estimates from data purchased from TOL
https://www.bloomberg.com/research/stocks/private/snapshot.asp?privcapId=257341008
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increased sales of better performing and more expensive tyres
51
. In the 2008 Impact
Assessment
52
it was estimated that it would cost 0.04 Euro/tyre to print and add a label as
a sticker on the tyre tread, amounting to around 10 million Euro per year in total (for C1
and C2 tyres). In more recent studies, e.g. the Impact Assessment on Energy Label
Framework Regulation
53
, a price 0.3 Euro/sticker was estimated.
Member States need to bear the costs for market surveillance, but they will also benefit
from the reduction of accidents and health problems resulting from tyre labelling. In
addition, EU wide legislation will be more cost effective from a Member State
perspective compared to national legislation, because the costs of developing the
regulation, test methods and conducting pre-regulatory studies are shared instead of
conducted for each country separately.
The costs for market surveillance vary between Member States. Some carrying out
almost no activities while others undertake both shop inspections and testing. No data
regarding Member States costs for market surveillance is available.
Via the MSTyr15
54
project, the Commission supportscoordination and improvement of
tyre market surveillance on the European market. The overall objective of the project is
to help deliver the intended economic and environment benefits of the labelling of class
C1 (passenger car) tyres. This will be achieved by improving the effectiveness of the
MSAs through training and the adoption of good practice guidelines. The budget for the
project is EUR 1.85 million
55
.
b. Evaluation question 2: To what extent are the costs of the intervention
justified, given the changes/effects it has achieved?
The TLR has resulted in substantial savings for end-users and society, without excessive
costs for manufacturers, other market actors or Member States. In total 1,200 PJ,
corresponding to 88 MT CO
2
emissions, have been avoided from 2010 to 2017,
benefiting the society as a whole. Furthermore, in the same period an estimated 1,825
fatalities and 29,640 severe injuries were avoided in traffic due to higher performing
tyres.
Manufacturers have been able to pass on the extra cost for development of better
performing tyres to end-uses, and distributors and dealers benefitted from increased
turnover.
Member States need to bear costs for market surveillance, but they will also benefit from
the reduction of accidents and health problems achieved due to the tyre labelling. In
addition, an EU wide legislation will be more cost effective from a Member State
perspective compared to national legislation.
51
52
Stoock model numbers presented in Appendix 3 indicate a continuous increase in overall sales
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52008SC2860&from=EN
–
Table 17 on page 52
53
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52015SC0139&from=EN
- Annex 9, page 114
54
http://www.prosafe.org/horizon-2020-projects/mstyr15/72-joint-actions/mstyr15
55
https://cordis.europa.eu/project/rcn/200156_en.html
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Therefore, the intervention costs seem justified given the improved performance of tyres
and the associated benefits.
c. Evaluation question 3: To what extent are the costs associated with the
intervention proportionate to the benefits it has generated? What factors are
influencing any particular discrepancies? How do these factors link to the
intervention?
Due to the benefits illustrated above and the low costs for implementation of labelling
compared to other actions, the intervention is considered proportionate. The fact that the
same tests can be used to prove compliance with the GSR to document the label values
makes both regulations more cost efficient for manufacturers.
One important factor influencing the discrepancy observed for C3 tyres is their purchase
pattern, which often involves procurement departments primarily focused on purchase
costs or leasing solutions in which different actors carry the burden for the purchase cost
(the tyre supplier) and the fuel cost (the end-user). This is a market factor (i.e. a split
incentive) that cannot be linked to the intervention itself but to the supply chain.
d. Evaluation question 4: To what extent do the factors linked to the
intervention influence the efficiency with which the observed achievements
were attained? what other factors influence the costs and benefits?
Since the efficiency to some extent depends on the effectiveness of the scheme, some of
the same factors influence the efficiency. This is especially true for consumer awareness,
since the label does not require manufacturers to produce tyres with higher performance,
but this is rather a result of end-user demand for such tyres. Hence, if end-user awareness
or confidence in the label is low, tyres with high performance according to the label
parameters will not have a market advantage, but rather the opposite since they are often
also sold at higher prices.
Consumer awareness and label confidence are in turn linked to the enforcement and
market surveillance actions of the Member States, and to improve awareness and
confidence, market surveillance activities should also be strengthened.
Other factors affecting the costs and benefits of the Tyre Label Scheme is the general
tendency towards more fuel-efficient cars. Since the tyre rolling resistance accounts for a
certain percentage of the car fuel consumption, cars with higher fuel efficiency
subsequently also give the end-user lower absolute savings from the tyres. This should
however not be seen as a negative effect, since the reduced fuel consumption of the car
itself is a means to the same end of mitigating GHG emissions.
e. Evaluation Question 5: How proportionate were the costs of the intervention
borne by different stakeholder groups taking into account the distribution of
the associated costs?
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Tyre manufacturers bear the largest share of the costs, but they have so far been able to
pass the extra costs on to the end-users, without increasing the total costs for end-users
over the life time of the tyres.
The end-users bear the costs for more expensive tyres, but they will be compensated by
saved fuels costs over the lifetime of the tyres.
Member States bear the costs for market surveillance in general and tyres only form one
small part of that. Moreover, the Commission has supported market surveillance through
the MSTyr15 project.
For this intervention it is important to bear in mind that it is voluntary for manufacturers
to improve the performance of tyres and for the end-users to buy better performing tyres.
The mandatory part for the manufacturer is the provision of the label information and the
label itself (for C1 and C2 tyres).
f. Evaluation question 6: Are there opportunities to simplify the legislation or
reduce unnecessary regulatory costs without undermining the intended
objectives of the intervention?
The one opportunity for simplification and reduction of regulatory costs that has been
identified is the establishment of a product registration database in line with database
introduced in the energy labelling framework regulation (EU) 2017/1369. According to
MSAs interviewed in correlation with the 2016 Review Study and the PROSAFE
MSTyr15 project, obtaining technical documentation is difficult and a database would
help them in their work, making market surveillance easier.
The idea is that the tyre supplier will be obliged to register all new models and enter pre-
defined information in the database before placing the tyre on the market. The
information will include details about the supplier and the product, for instance suppliers
name and trademark, model identifier, performance classes and other parameters on the
label, the label in electronic format and the technical documentation.
As tyre suppliers are already obliged to assemble all the required documents and
information (including providing the label) and make the information available to
authorities on request, the additional costs for uploading the documentation in a database
is limited. The additional costs could be compensated by the fact that manufacturers do
not need to handle requests from authorities because these already have easy access to
the information in the database.
The burden for Member States’ MSAs to obtain the documentation is significantly
reduced. Also, the burden for suppliers and dealers will be reduced because they have
easier access to the label and the label information.
As the Commission is already obliged to set up the database for energy-related products,
the extra costs for inclusion of tyres will be marginal. Establishment of a product
registration database is supported by end-users, manufacturers and Member States.
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g. Evaluation question 7: if there are significant differences in costs (or
benefits) between Member States, what is causing them? How do these
differences link to the intervention?
Member State costs associated with the tyre labelling Regulation are primarily related to
market surveillance.
Even though all Member States have the same the obligation to perform market
surveillance according to the Regulation, the actual level of market surveillance varies
greatly between Member States - from zero to several hundred shop inspections per year.
The prevailing type of market surveillance is ‘point of sales’ inspections. Some
authorities performed inspections of technical documentation, but only very few
performed laboratory tests to verify the label values. According to MSAs, high cost and
too few accredited test facilities are the greatest barriers for laboratory testing of tyres.
56
The relatively low level of market surveillance affects consumer confidence negatively,
and many stakeholders
57
state in both the Review Study and the OPC that to increase
confidence more market surveillance (including testing) and sanctioning of non-
compliance is needed. Furthermore, retailers claim in the Review Study and the OPC that
they ‘not often’ or ‘never’ experience that their shops are inspected, which has given
them the impression that tyre labelling is of low priority for the authorities.
Based on this, some tyre dealer organisations have decreased their effort to educate their
employees in advising consumers about the label parameters. The involvement of dealers
is considered of great importance for consumer awareness and the actual use of the label.
h. Evaluation question 8: How timely and efficient
is the intervention’s process
for reporting and monitoring?
Pursuant to the TLR, the Commission must assess the need to review the Regulation and
present the result of this assessment to the European Parliament and the Council no later
than 1 March 2016.
The TLR was adopted in November 2009 and entered into force in November 2012.
Pursuant to Article 14 of the TLR, the assessment should consider,
inter alia:
(a) the effectiveness of the label in terms of end-user awareness, in particular
whether the provisions of Article 4(1)(b) are as effective as those of Article
4(1)(a) in contributing to the objectives of this Regulation;
(b) whether the labelling scheme should be extended to include retreaded tyres;
(c) whether new tyre parameters, such as mileage, should be introduced;
56 Review study on the Regulation (EC) No 1222/2009 on the labelling of tyres. March 2016
57 Both the industry and end users have expressed the need for more market surveillance in the context of the 2016
Review Study and in the OPC.
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(d) the information on tyre parameters provided by vehicle suppliers and
distributors to end-users.
Monitoring the effect of the regulation 6 years after its adoption and around 3 years after
it entered into force seems to be appropriate. The Regulation needs to have been in place
for some time before it is possible to evaluate its functioning and effectiveness. The list
of issues that should be considered has been expanded to include also essential aspects
regarding cost effectiveness and the possibility of the label to be able to pull the tyre
market towards better performing tyres.
There is no collective data collection or monitoring procedure to evaluate the level of
compliance and enforcement/market surveillance activities. This means that progress in
the market can only be estimated by purchasing data from market research companies or
the like, and not through data collected directly form Members States or suppliers.
i. Conclusions on efficiency of the TLR
The evaluation assessment has shown that
the benefits from the TLR seem to outweigh
its costs, both for business and for society as a whole.
This is true both for
manufacturers’ costs for testing and for end-users.
The fact that manufacturers have
worked to improve their products shows that the TLR has been used as a product-
differentiating factor, which suggests that the extra investment needed to achieve higher
efficiency levels has generally been outweighed by the benefits
58
.
The increased performance has resulted in increased purchase prices for end-users, but this is
offset by the fuel savings, which results in larger savings over the tyre lifetime. All in all,
the
total cost of ownership
for end-users is lower with implementation of the TLR than
without
for C1, C2 and C3 tyres. However, for C3 tyres the TOC improvements seen in
the Current Label Scenario subsided in 2016 and 2017.
Member State costs associated with the TLR are primarily related to market surveillance.
These costs should be reduced, to incentivise market surveillance in all Member States at
a sufficient level. The cost could be reduced by establishing a product registration
database in line with the database introduced in the energy labelling framework
regulation (EU) 2017/1369 and by specifying better the content of the technical
documentation.
5.3.
R
ELEVANCE
a. Evaluation question 1: To what extent is the intervention still relevant?
The objective of the TLR is to provide end-users with information on tyre performance
parameters thereby allowing them to make an informed choice, and to influence their
purchase decisions in favour of more fuel efficient, safer, and quieter tyres. Furthermore,
it incentivises manufacturers to optimise those tyre parameters, paving the way for more
sustainable consumption and production.
58 Ecofys, Evaluation of the Energy Labelling Directive and specific aspects of the Ecodesign Directive, June 2014.
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These objectives are still relevant since increasing fuel efficiency continues to be
important with the EU facing a dependence on energy imports and with the need to limit
climate change. Decarbonising the transport sector is a major challenge and it is the only
large EU sector where emissions today are above their 1990 levels. Tyres account for 5-
10% of vehicle fuel consumption due to their rolling resistance
59
. Decreasing rolling
resistance of tyres is therefore important to increase fuel efficiency and cut greenhouse
gas emissions.
Ensuring that consumers are informed about the rolling resistance (and thus the impact
on fuel consumption) of different types of tyres is a crucial element in driving changes in
behaviour and moving the market towards greater fuel efficiency. At the same time, the
label helps end-users choose safer tyres through the wet grip performance indicator and
quieter tyres through the external rolling noise indicator. The more effective the label, the
greater the contribution to achieving clean, safe and quiet vehicles.
Increasing road safety is highly relevant with approximately 24,500 road accident
fatalities in the EU in 2017
60
. The Commission has adopted a road safety programme
61
to
decrease road deaths between 2011 and 2020. Tyres are an important part of road safety
as they are the only contact between the vehicle and the road. Providing end-users with
information on tyre safety parameters is highly relevant as well, with the tyre safety
parameter wet grip being a top-level concern for end-users along with price when
purchasing tyres. furthermore the 2016 Review Study indicated that considering
including additional safety performance parameters such as tyre grip on snow and ice in
addition to the wet grip parameter may contribute to increasing relevance. Snow and ice
performance were also rated as relevant by end-users in the consumer survey conducted
in relation to the 2016 Review Study.
Regulating external rolling noise levels also continues to be highly relevant. The
Environmental Noise Directive (END) 2002/49/EC entered into force in 2002 and
obliges Member States to report noise levels. The data collected shows that in 2013 70
million people in Europe suffered from unacceptable noise levels in so-called Black
Areas, exceeding 65 dB noise levels, and even more in Grey Areas with noise levels
between 55 and 65 dB. The WHO recommends night noise levels below 40 dB to protect
public health. Regulating external rolling noise of tyres thus remains important to
mitigate this problem.
According to the results of the OPC, a clear majority of the respondents (nearly 80%)
find the tyre label helpful when deciding which tyres to buy. The respondents that find
the label useful include manufacturers (ETRMA), national authorities and NGOs. In the
consumer survey carried out as part of the 2016 Review Study, 90% of the interviewed
car owners (cars with C1 tyres) rated the label as useful (including 38% as very useful).
59
Numbers are for highway driving,
https://www.fueleconomy.gov/feg/atv.shtml.
City driving results in 3-5% rolling
resistance loss.
60
https://ec.europa.eu/transport/road_safety/specialist/statistics_en#
61
http://europa.eu/rapid/press-release_MEMO-10-343_en.htm
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b. Evaluation question 2: To what extent have the (original) objectives proven
to have been appropriate for the intervention in question?
The original objectives of decreasing fuel consumption and increasing safety have been
appropriate and as a result better performing tyres have been placed on the market.
However, the original 2008 Impact Assessment did not include considerations on wet
grip (safety) for C2 and C3 tyres or on external rolling noise for any of the tyre types.
These factors, however, continue to be relevant for the TLR, and manufacturers consider
that information about the interaction of all three parameters is crucial for end-users to
make an informed choice
62
.
c. Evaluation question 3: How well do the (original) objectives of the
intervention (still) correspond to the needs within the EU?
There is still a need in the EU to promote cleaner, safer and quieter vehicles. In this
context tyre labelling is still very relevant. However, some additional needs have
appeared within the EU since the adoption of the current tyre labelling scheme.
The current tyre labelling scheme does not cover re-treaded tyres or studded tyres. In
addition, there is no information on the performance of tyres in snow and ice conditions.
Tyre re-treading is a process used to extend the life of used tyres, in particular for C3
tyres. The market share of re-treaded C3 tyres is around 30% in Europe, which
corresponds to around 4.3 million tyres
63
.
Studded tyres
64
are primarily used in Finland, Sweden and Norway, where the market
share is 25% on average of the C1 tyre market. More than 50% of car owners in Sweden
and Finland have studded tyres for their cars
65
. In the rest of the EU, the market share can
be estimated at around 0.50% of the annual sales according to the 2016 Review Study
66
.
Wet grip is generally perceived as a safety rating of the tyre, but this is only true for wet
conditions, not for the snow and ice conditions seen in the Nordic countries or in
mountainous areas. Tyres with very good level of performance under ice conditions tend
to have in general low wet grip rates. The market share of these tyres at EU level is
around 30% of the annual C1 tyres sales for snow tyres and around 1% for ice tyres
according to the 2016 Review Study.
The fact that these types of tyres are not in the scope of the current TLR means that there
is no EU system of information to end-users about such tyres, and they could therefore be
misled regarding the safety information because of confusion between the wet grip
parameter and performance on snow/ice.
62 According to ETRMA answers to the OPC
63
http://www.etrma.org/uploads/20170912%20-%20Statistics%20booklet%202017%20-
%20alternative%20rubber%20section%20FINAL%20web1.pdf
64 Tyres with a
number of small metal studs embedded in the tyre tread to improve traction on snowy or icy roads
65
According to C1 end users participating in the consumer survey perfoirmed in relation to the 2016 Review Study
66 For the overall EU, the market share of the studded tyres is around 2%
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In general, stakeholders are in favour of including information regarding snow and ice
performances on the label (70% according to the OPC). This is also supported by
industry (ETRMA).
Respondents to the OPC are also in favour of extension of the scope of the tyre labelling
regulation to include retreated tyres (about 65% answer yes). However, only 22% are
supporting inclusion of studded tyres. The majority of the respondents’ answered “don’t
know” or “no” to that question.
Some stakeholders, in particular BIPAVER
67
in cooperation with ETRMA
68
and
ETRTO
69
, are working proactively to find an adequate system for the integration of
retreated tyres in the tyre labelling scheme. However, ETRMA also stress that before
inclusion of retreated tyres in the tyre labelling scheme it is essential to identify a
technically and economically feasible tool or system for establishing the label
performance parameters. This is particularly important because of the high number of
SME tyre retreaders who will be impacted if retreated tyres are included in the scope.
d. Evaluation question 4: How well adapted is the intervention to subsequent
technological or scientific advances?
Since the adoption of the TLR manufacturers have placed better performing tyres on the
market especially regarding wet grip. Nevertheless, very few tyres are able to have at the
same a high performance (i.e. corresponding to class A) with respect to both fuel
efficiency and wet grip.
As more products are now in the highest performing classes of the label (especially with
regard to wet grip and noise) re-adjustment of the label classes could be a solution
ensuring that the label also in the future will able to pull the market for all the included
performance parameters. Also the removal of the bottom classes (through the GSR),
means that several of the label classes are no longer utilised, and a re-adjustment of the
classes could possibly make it more relevant for future technology.
According to ETRMA, the tyre industry has taken a proactive approach in reducing CO
2
emissions through advanced technology while promoting road safety and other key
performance parameters at the same time. In addition, ETRMA argues that because tyres
are technologically complex products, tyre development faces a multiple set of customer-
oriented performance requirements which often conflict with each other. Therefore, the
performances rated on the tyre label are the results of complex engineering development.
Against this background, ETRMA finds that the current scaling system of the three
performance parameters on the label is already challenging and will remain so in the
foreseeable future
70
.
67 European retread industry trade association, representing National retreading associations and suppliers to the
retreading industry from 11 Member States
https://bipaver.org/
68 European Tyre & Rubber Manufacturer Association,
http://www.etrma.org/
69 European Tyre and Rim Technical Organisation,
https://www.etrto.org/Home
70 ETRMA contribution to Evaluation Roadmap/Inception Impact assessment. EU tyre labelling scheme
–
1222/2009/EC. July 20, 2017.
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e. Evaluation question 5: How relevant is the EU intervention to EU citizens?
As the TLR is an intervention that is specifically targeting end-users of tyres, and there
are more than 250 million C1 vehicles plus C2 (30 million) and C3 (6 million) vehicles,
it is by nature very relevant for EU citizens.
According to respondents to both the OPC and the consumer survey made in relation to
the 2016 Review Study, the TLR is indeed relevant; 82% of respondents in the OPC
found an EU label on tyres helpful when making a purchasing decision. In both the OPC
and the consumer survey, fuel efficiency and wet grip were rated as important
parameters, even when comparing to non-label parameters as seen in the figure below.
Figure 23: Percentage of C1 end-users
rating different tyre parameters “very important”
Mileage
Snow and ice grip
Tyre brand
Tyre price
External rolling noise
Wet grip
Fuel efficiency
0%
10%
20%
30%
40%
50%
60%
70%
Label parameters
non-label parameters
Source: consumer survey made in relation to the 2016 Review Study
The
external rolling noise, on the other hand, is rated as “very important” by only 21% of
end-users (see figure above) and according to ANEC/BEUC
71
“external rolling noise
performance does not deliver useful consumer information”
72
.
One reason for the low relevance rating of external rolling noise is that it is not the noise
experienced by the driver that is measured, but the noise experienced by a bystander
when the vehicle drives past. This is important because of environmental noise effects,
but users purchasing a new tyre typically find parameters that affect them directly more
relevant (e.g. the wet grip and the fuel efficiency).
Another reason might be the lower understanding of the noise pictogram on the label,
which according to both the consumer survey and the OPC is the label parameter users
find most difficult to understand. Swiss FOEN
73
suggested in the OPC to reconsider the
noise pictogram and exchange it with for example a “smiley” scale
74
.
71
http://www.beuc.eu/about-beuc/who-we-are
72 Comment from the OPC answer
73
https://www.bafu.admin.ch/bafu/en/home.html
74
“Reconsider noise pictogram (smileys? :-)
/ :-I / :-(
, add color?)”
[FOEN]
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Even though the external rolling noise might not be important for the end-user in a
purchase situation
75
, some still use it in their decision making, and it is still relevant for
the EU citizens who are affected by traffic noise.
f. Conclusions on relevance of the TLR
The TLR continues to be highly relevant for promoting fuel efficient and safe tyres with
low external rolling noise
76
. The end-users that participated in the survey found the label
information relevant when purchasing tyres.
Increasing the fuel efficiency continues to be highly relevant with the EU facing a
dependence on energy imports and with the need to limit climate change. With the
transport sector constituting one third
77
of European energy consumption, increasing fuel
efficiency of road transport plays an important role in addressing these challenges.
Increasing road safety is highly relevant with approximately 24,500 road accident
fatalities in the EU in 2017
78
. The Commission has adopted a road safety programme
79
to
decrease road deaths between 2011 and 2020
80
. Tyres are an important part of road
safety, as they are the only contact between the vehicle and the road. Providing
consumers with information on tyre safety parameters is highly relevant as well, with the
tyre safety parameter wet grip being a top-level concern for consumers along with price
when purchasing tyres
81
.
.
Regulating external rolling noise levels also continues to be highly relevant.
The
Environmental Noise Directive (END) 2002/49/EC
82
entered into force in 2002 and
obliges Member States to report noise levels. The
data collected shows that in 2013 70
million people in Europe suffered from unacceptable noise levels in so-called Black
Areas, exceeding 65 dB noise levels, and even more in Grey Areas with noise levels
between 55 and 65 dB
83
.
The WHO recommends night noise levels not higher than 40
dB to protect public health. Regulating external rolling noise thus remains important to
mitigate this problem.
5.4.
C
OHERENCE
a. Evaluation question 1: To what extent is this intervention coherent with
other interventions which have similar objectives?
75
Based on C1 consumer survey made in correlation to the 2016 Review Study.
76 Regulation 1222/2009 of the European Parliament and of the Council
77
European Commission (2014), “EU Energy in Figures statistical pocketbook 2014”, European Union, 2014.
ISBN
978-92-79-29317-7. Link:
http://ec.europa.eu/energy/sites/ener/files/documents/2014_pocketbook.pdf
78
https://ec.europa.eu/transport/road_safety/specialist/statistics_en#
79
European Commission (2010), “Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions - Towards a European road safety
area: policy orientations on road safety 2011-2020”.
Brussels, July 2010. COM (2010) 389 final. Link:
http://ec.europa.eu/transport/road_safety/pdf/com_20072010_en.pdf
80
European Commission (2016), “Mobility and Transport Road Safety; Statistics – accidents data”. Website last
updated 04.03.2016. Link:
http://ec.europa.eu/transport/road_safety/specialist/statistics/index_en.htm
81 Consumer survey with C1 end-users in selected European Countries, Viegand Maagøe, fall 2015. See Appendix 2.
82 Directive 2002/49/EC of the European Parliament and of the Council
83
European Environment Agency (2014), ”Exposure to and annoyance by traffic noise”, December 2014, Link:
http://www.eea.europa.eu/data-and-maps/indicators/exposure-to-and-annoyance-by-1/assessment
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Description of the GSR
The TLR was adopted at the same time as the GSR that puts in place harmonised
technical requirements that tyres must satisfy to be placed on the EU market.
The GSR removes the worst performing tyres from the market by putting in place
minimum requirements for (i) the rolling resistance, (ii) external rolling noise and (iii)
wet grip performance of tyres. All three minimum requirements applied from 1
November 2012 for new models of tyres, with a second more stringent set of
requirements applied for the rolling resistance of new models of tyres from 1 November
2016.
Effects of the interaction of both Regulations
As a result of the current minimum requirements of the GSR, classes set up by the TLR
are outdated: classes G and F (and E for C3 tyres) for rolling resistance, class F for wet
grip and the three soundwaves class for noise are now empty. By contrast, the top classes
are increasingly populated, in particular for wet grip
84
.
The elimination of the bottom classes through the type approval legislation and the
migration towards top classes due to technological progress makes a re adjustment of the
the label necessary in order to maintain the incentive effect of the labelling scheme.
The TLR is coherent with the GSR. The same measuring methods and performance
parameters are applied in both Regulations, and often industry uses the results from the
type approval tests to establish the labelling values. The two Regulations are closely
related and complement each other. While the GSR sets minimum efficiency
requirements to remove the worst performing tyres from the market, the tyre labelling
regulation inform end-users of the tyre performance so that they can make informed
purchasing decisions (so call combined "push" and "pull" effect).
The TLR and the GSR should be seen as a "parallel" to the EU's Energy Labelling and
Ecodesign framework for energy-related products (which is not applicable to means of
transport). Similar to the GSR, ecodesign regulations set minimum energy efficiency
requirements that products must satisfy before they can be placed on the Union market,
while energy labelling regulations (similar to the TLR) provide information to consumer
so that they can make better informed choices when purchasing.
This same "push and pull" effect can be seen in the EU mobility framework, where the
car labelling Directive helps consumers buy or lease cars which use less fuel and thereby
emit less CO
2
and encourages manufacturers to reduce the fuel consumption of new cars,
while the Regulation on emission performance standards and reducing CO
2
emissions for
new passenger cars sets the minimum requirements for the Union market.
84 2016 Review study on the Tyre Labelling Regulation,
https://ec.europa.eu/energy/sites/ener/files/documents/Study%20in%20support%20of%20the%20Review%20of%20t
he%20Tyre%20Labelling%20Regulation_final.pdf
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The TLR is coherent with the framework Energy Labelling Regulation
85
and the
implementing measures (Commission Delegated Regulations) adopted under that
framework. The design of the label itself as well as the structure of the implementing
measures are very similar, although further alignment would be possible.
The efforts by the European Commission to decrease the fuel consumption of passenger
cars, LCVs (HCVs interrelate with the TLR on achieving the same goal: higher overall
energy savings and emission reductions from road transport within the EU. However,
since the tyre rolling resistance causes a certain share of the vehicle fuel consumption,
the general decrease in fuel consumption of vehicles, also decreases the absolute value of
the saving potential of improving the tyres.
Tyres sold on the OEM (i.e. with a new vehicle) constitute around 25% of the tyre sales
in Europe
86
. Even though it is smaller than the replacement market it is still considered
important in terms of which tyres are used on European roads. According to the TLR,
OEM tyres should only bear the label when end-users are offered a choice between
different tyres when they buy a new car (which in most cases they are not
87
). Passenger
cars are covered by European fuel efficiency labelling88 with the aim to help consumers
buy or lease cars which use less fuel and thereby emit less CO
2
. However, the fuel
efficiency label for cars does not take the fuel efficiency of tyres into account because
cars are tested with standard tyres when establishing the efficiency rating for the fuel
label.
b. Evaluation question 2: To what extent is the intervention coherent
internally?
Tyres are characterised by several interrelated parameters, and improving one parameter,
such as rolling resistance, can have an adverse impact on other parameters, such as wet
grip, thereby decreasing road safety. Furthermore, the improvement of wet grip might
have an adverse impact on external rolling noise, increasing noise pollution.
It is important for the internal coherence that all three interrelated performance
parameters are included in the label. If the wet grip was not included in the label the fuel
efficiency could be improved at the expense of the wet grip, which could result in less
safe tyres and more accidents.
The implementation of the TLR has especially resulted in improvement of the wet grip
performance, while less progress has been achieved for fuel efficiency and only very
minor improvements for external rolling noise. This corresponds to the fact that most
85
Regulation (EU) 2017/1369 of the European Parliament and of the Council setting a framework for energy labelling
and repealing Directive 2010/30/EU
86
Based on statement from ETRMA and calculation methods used in the 2016 Ecodesign Impact Accounting
https://ec.europa.eu/energy/sites/ener/files/documents/Ecodesign%20Impacts%20Accounting%20%20-
%20status%20January%202016%20-%20Final-20160607%20-%20N....pdf
87
According to answers in the consumer survey made in relation to the 2016 Review Study
88
DIRECTIVE 1999/94/EC of the European Parliament and of the Council relating to the availability of consumer
information on fuel economy and CO
2
emissions in respect of the marketing of new passenger cars
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end-users find the wet grip performance the most important parameter on the label
89
.
This is also confirmed by the results of the OPC.
c. Evaluation question 3: To what extent is the intervention coherent with
wider EU policy?
The intervention is coherent with wider EU policies for increasing energy efficiency and
reducing CO
2
emissions and the TLR contributes positively to achieving the objectives of
these policies.
Lowering the demand for energy and 'putting energy efficiency first' is one of the five
main objectives of the Energy Union strategy. In 2015, Member States confirmed the
imperative need to reach the 20% energy efficiency target for 2020. In November 2016,
the Commission proposed to further strengthen this beyond 2020 with a 30% EU energy
efficiency target for 2030. That target is currently under examination in the ordinary
legislative procedure: there is no sign that final agreement will be on a level of ambition
lower than that proposed by the Commission.
The proposed 2030 EU Climate and Energy policy framework sets out binding targets for
the non-Emissions Trading System (ETS) sectors (primarily agriculture and
transportation) to cut emissions by 30% by 2030 compared to 2005. Legislation is in
place to reduce emissions from new cars by 40% in 2021 compared to 2005 and by 19%
for new vans in 2020 compared to 2012.
With the transport sector accounting for one third of European energy consumption,
increasing the fuel efficiency of vehicles is a key element in decreasing transport
emissions and also contributes to reducing the EU’s dependence on energy imports.
Therefore, there are major efforts at EU level to reduce CO
2
emissions and air pollution
caused by transport. For instance, in its Communication "A European Strategy for Low-
Emission Mobility” the Commission announced that by 2050 greenhouse gas emissions
from transport need to be 60% lower than in 1990. Similarly, the "Third Mobility
Package" will include initiatives to reduce emissions by cars and lorries, to increase
safety of road transport and to reduce pollution. The Commission's Communication "A
European Strategy for Plastics in a Circular Economy" specifically mentions the need to
study how to reduce unintentional release of microplastics from tyres, possibly through
tyre design, minimum requirements for abrasion and information requirements.
d. Evaluation question 4: To what extent is the intervention coherent with
international obligations?
International UNECE
90
test methods form the basis of the tests in both the tyre energy
labelling Regulation and the GSR. The use of globally recognised measurement
standards ensures coherence with international approaches and avoids that industry has to
test according to different testing methodologies.
89 Review study on the Regulation (EC) No 1222/2009 on the labelling of tyres. March 2016.
90 United Nations Economic Commission for Europe (UNECE), https://www.unece.org/mission.html
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No international obligations have been identified for tyres specifically, but in a wider
perspective, the TLR is coherent with any obligations related to mitigating climate
change.
e. Conclusions to coherence of the TLR
The TLR is coherent with the GSR. The same measuring methods and performance
parameters are applied in both Regulations and the two Regulations are closely related
and complement each other by acting as push and pull factors on the market,
respectively.
The inclusion of all three interrelated performance parameters (wet grip, noise and fuel
efficiency) in the label ensured internal coherence.
The intervention is coherent with wider EU policies in place to increase energy efficiency
and reduce the CO
2
emissions and the tyre labelling regulation contributes positively to
achieve the objectives of these policies. This includes for example the energy efficiency
targets in the Energy Union Strategy for 2020 and 2030 and the European Strategy for
Low-Emission Mobility (Commission Communication).
With the transport sector accounting for one third of European energy consumption,
increasing the fuel efficiency of vehicles is a key element in decreasing transport
emissions and contributes to reducing the EU’s dependence on energy imports.
Finally, international UNECE test methods form the basis of the tests in both
Regulations. The use of globally recognized measurement standards also ensures
coherence with international approaches and saves the industry the effort to test
according to different testing schemes.
5.5.
EU
ADDED VALUE
a. Evaluation question 1: What is the additional value resulting from the EU
intervention compared to what could reasonable have been expected from
Member States acting at national and/or regional levels?
The general stakeholder view as expressed in the OPC and consumer survey related to
the 2016 Review study is that an EU-wide label covering all EU countries is preferable
over national or regional regulation. 83% of the respondents (including industry
respondents) to the OPC found an EU-wide label the best solution. During the OPC and
the 2016 Review Study no stakeholder expressed opposition against having the tyre label
at EU level.
Furthermore, several stakeholders indirectly support the EU-wide action by expressing in
the OPC that they want to expand the reach of the label in terms of for example
consolidated market surveillance actions and an EU tyre registration database.
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An EU harmonised regulatory framework rather than having rules at Member State level
brings down costs for manufacturers and ensures promotion of high-performing tyres.
Moreover, given that the TLR is closely linked to the GSR, which operates at EU level,
having both regulations operate at different levels would lower their added value.
If instead of the TLR, national or regional regulations would be in place, there would be
considerable regulatory barriers to trading tyres because of different rules and
requirements. This would make it difficult for businesses to enter the EU market as each
Member State would have to be treated as a separate market, imposing considerable
regulatory compliance costs.
For tyres the EU legislation preceded any national legislation that could have led to
market fragmentation and created obstacles to the free movement of products and to
higher costs for both producers and member states.
Furthermore, a Regulation at EU level provides end-users with the same, harmonised
information, no matter which Member State they choose to purchase their tyres in, which
is increasingly relevant as the online trade increases. With the tyre labelling scheme at
EU level, energy efficient and safe tyres reducing noise pollution, are promoted in all
Member States, creating a larger market for such tyres and hence larger incentives for the
tyre industry to develop them. All Member States will also benefit from the optimised
performance of the tyres in terms of lower fuel/energy consumption, lower CO
2
emissions, fewer accidents and fewer people exposed to increased noise levels.
The added value of having an EU-wide regulation compared to what could reasonably be
expected from Member States acting at national and/or regional levels is the consistent
labelling requirements for all manufacturers throughout the EU, the
reduced cost of
market entry
and operation for businesses and the
availability of high performing
tyres for all EU citizens
at reasonable costs due to the increased competition on the
internal market.
b. Evaluation question 2: What would be the most likely consequences of
stopping or withdrawing the existing EU intervention?
Since tyres are a relatively complicated product to test compared to other energy labelled
products and no Member States or regions had any performance regulations in place
before the EU TLR, it is unlikely that national or regional legislation would be adopted in
case the EU label is withdrawn.
If no national regulations were in place, end-users would not be able to find harmonised
information on tyre performance regarding fuel efficiency, wet grip or external rolling
noise.
If Member States were to adopt national legislation, the most likely effect would be:
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-
Fewer models on the smaller national markets in particular (low purchasing
power or low number of end-users) caused by the increased regulatory and
monetary burden of introducing new tyres on the market
More expensive tyres (to pay for the increased market entry costs faced by
producers)
Less competition and more fragmentation of the market
-
-
Without the TLR CO
2
emissions, the number of road accidents and road noise would
likely be higher, resulting in increased societal costs from both the effect of climate
change, road accidents and noise nuisance.
Most likely, if the EU TLR was withdrawn,
no national or regional legislation would
be put in its place.
This would mean that the market would over time approach the
performance seen in the BAU (no-label) scenario with
higher rolling resistance, lower
wet grip and higher noise levels.
c. Conclusions to EU added value of the TLR
A harmonised regulatory framework at EU level provides added value to the EU
compared to having regulations at Member State level, because it enables businesses to
enter a larger market for their products while ensuring high levels of environmental
protection.
This strengthens competitiveness EU-wide and facilitates easier inter-European trade of
tyres, which also benefits consumers in terms of lower prices and wider range of
products.
The objective of reducing the negative environmental impacts of tyres cannot be
sufficiently achieved only by the Member States, because this would lead to divergent
national provisions and procedures that would result in undue costs for industry (and
eventually consumers) and constitute obstacles to the free movement of goods within the
EU internal market. Only through harmonised EU rules on tyre labelling, and underlying
measurements and testing, can it be ensured that the same model of a tyre has the same
published energy class throughout the EU. This is the only way to ensure end-users can
compare tyres across the EU.
6. Conclusions
6.1.
W
HAT IS
/
IS NOT WORKING AND WHY
?
The TLR is working only partly as intended towards the objective of providing end-users
with information allowing them to choose more fuel efficient, safer and quieter tyres,
since only around half of end-users know of the label. The label parameters continue to
be relevant both from an end-user and societal perspective.
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The overall fuel consumption for all vehicle types (C1, C2 and C3) has decreased
compared to the No-label scenario through decreasing rolling resistance. However, the
effect of the TLR on rolling resistance of C3 tyres is reducing after the latest minimum
requirements of the GSR were introduced. This limited effect is most likely due to the
differing supply chain for C3 tyres and not directly linked to the TLR itself.
The severity of accidents has been brought down through improving the tyre wet grip,
which is the parameter rated as most important by both end-users and industry, and
therefore also the parameter which has improved the most. However, the relevance of the
label could be improved regarding safety, by implementing label parameters for tyre grip
on snow and ice.
The external rolling noise is the parameter that has been affected the least by the TLR,
and also the parameter rated as least important by end-users. The label is thus not
effective in reducing the external rolling noise due to the lower focus on this parameter
by end-users
and possibly the difficulty to understand the label “scale” for noise.
The end-user awareness and confidence in the label are low according to the consumer
survey conducted in correlation with the 2016 Review Study, presumably due to many
end-users not seeing the label before purchase, which is partly a consequence of low
market surveillance activity and inadequate enforcement in Member States. The
awareness and market surveillance efforts can and should be improved by amending the
Regulation.
6.2.
T
HE
L
ESSONS LEARNT
The effect of the TLR is strongly correlated with end-user preferences
91
, which is for
example shown by the achieved market change for rolling resistance and wet grip. The
wet grip, which is most important to end-users, has improved the most, followed by
rolling resistance (fuel efficiency). External rolling noise has hardly improved at all and
is seen by most end-users as least important.
The end-user awareness of the label and knowledge of the parameters and their
implications on fuel efficiency, safety and noise pollution is therefore crucial for the
continued effectiveness of the label, which is in any case diminishing in comparison to
the BAU scenario due to the new limit values implemented through the GSR in 2016.
Market surveillance actions are generally limited and coordination between Member Sate
MSAs is necessary to achieve more efficient enforcement. The test costs are considered
high, and MSAs experience problems when trying to obtain technical documentation.
6.3.
A
CTUAL PERFORMANCE COMPARED TO EXPECTATIONS
The original 2008 Impact Assessment for tyre labelling did not consider the label in the
form that was eventually decided upon. For C1 tyres only wet grip and rolling resistance
was assessed, and for C2 and C3 tyres only fuel efficiency labelling was assessed. Noise
91
According to consumer survey performed in connection to the 2016Review study
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was not considered in any of the options. It is therefore not possible to compare directly
the expected savings from the 2008 Impact Assessment and the actual observed savings.
However, in terms total cumulated fuel savings from 2012 to 2020, the 2008 Impact
Assessment expected 879 PJ cumulated savings for all tyre types (C1, C2, C3), whereas
the actual data from 2012 to 2017 shows fuel savings of 1200 PJ.
6.4.
A
CTIONS TO BE TAKEN
The objectives of the TLR were (i) to provide end-users with information on tyre
parameters so that they can make an informed choice, (ii) to influence end-users purchase
decisions in favour of more fuel efficient, safer, and quieter tyres, and (iii) to incentivise
manufacturers to optimise those tyre parameters, paving the way for more sustainable
consumption and production.
The present evaluation shows that effectiveness and efficiency of the TLR can be further
improved notably by (i) increasing consumer awareness and confidence in the label
(which will make them more likely to use the label information when purchasing tyres),
and (ii) improving market surveillance to ultimately fully reach the three objectives of the
TLR.
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Appendix 1: Stakeholder consultation
Involvement of stakeholders has happened across the 2016 Review Study and the Evaluation /
Impact Assessment studies and the same sources have been used in all of them.
I.
S
TAKEHOLDER MEETING
One stakeholder meeting was held in November 2015 connection to the 2016 Review Study, where
37 stakeholders participated form various industry organisations, manufacturers and NGOs. The
participants are shown in the table below.
Family Name
Ahlen
Anadón
Bardini
Bottesini Campos
Brahy
Brito
Burfien
Cinaralp
Collins
De Mahieu
Eaton
Falcioni
Gallegos
Gaube
Goyeneche
Guven Sumer
Gydesen
Hansen
Herges
Kemna
Lim
López Benítez
Loponen
Maya-Drysdale
Moreno Acedo
Netsch
Noirhomme
O'Connell
Ott
Perrot
Poliscanova
Rames
First Name
Nils
Ricard
Perla
Alessandro
Olivier
Henrique
Joerg
Fazilet
Desmond
Nicolas
Adrian
Simone
David
Marie
Fabienne
Ayse
Annette
Arne
Benedikt
Rene
Ho Taek
Casto
Mika
Larisa
Juan
Lars
Jean-Claude
Richard
Guy
Jean-Dominique
Julia
Mette
Organisation
Swedish Energy Agency
IDIADA
Pirelli
Vipal Europe SL
Ministry of Environment
VIPAL RUBBER
Continental Reifen Deutschland GmbH
ETRMA
Continental
ETRTO
UK Department for Transport
ETRTO
IDIADA
SOLVAY
Michelin
ANEC
Viegand Maagøe
Tyre Business Denmark
LANXESS
VHK
HANKOOK Tire Europe GmbH
EC - DG MOVE
Finnish Transport Safety Agency
Viegand Maagøe
EC - DG ENER
TUEV SUED Product Service GmbH
ETRTO
Bandvulc Tyres Ltd
MICHELIN
Michelin
Transport & Environment
Viegand Maagøe
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Rieken
Scorianz
Shchuryk
Spuybroek
Sunnari
Taylor
Tosatti
van der Rijken
van Gelderen
-
Robert
Marc-Antoine
Martina
Ruud
Jarmo
Peter
Gianluca
Tim
Alex
ITMA Europe
UTAC
Goodyear
BIPAVER
Nokian Tyres Plc
ITMA Europe
Bridgestone Europe
VACO
NVR
T
YRE SUPPLIERS
(
MANUFACTURERS AND IMPORTERS
)
On the
manufacturer side, the European Tyre and Rubber Manufacturers’ Association (ETRMA)
was identified as the key representative accounting for 76% of the European C1 and C2 tyre
markets and 83% of the C3 tyre market
92
. ETRMA has 12 corporate members consisting of large
tyre manufacturers, who were reached though online surveys. ETRMA provided sales numbers and
inputs throughout the process of both the 2016 Review Study and the evaluation/Impact Assessment
study.
On the importer side, the International Tyre Manufacturers’
Association (ITMA) was identified as
the key representative for non-ETRMA tyre manufactures importing tyres to Europe
93
. By targeting
ETRMA and ITMA, 90% of the European tyre market is represented. Interviews were conducted
with contacts from key tyre importers provided by ITMA.
-
T
YRE DEALERS
A large number of tyre dealers exist in the European market and in order to get as large a
representation of the market as possible they were reached through tyre dealer organisations listed
in Table 4. Dealers are in this study defined as those having direct contact with end- users with
exception of the ‘fleet solution services’ used primarily for C3 tyres, where tyre suppliers manage
contracts directly with fleet operators
94.
Table 62: European tyre dealer organisations interviewed
NTDA
VACO
FEDERTYRE
BRV
DRF
National Tyre Dealers Association (UK)
Industry association for the tire and wheel
industry (NL)
Association of tyre specialists of Belgium (BE)
Federal Association of tyre trade and
vulcanisation craft (DE)
Trade organisation for Swedish tyre, rim and
service (SE)
200 member companies representing
over 2000 retailers
350 member companies representing
over 730 retailers
representing companies buying, selling
and servicing tyres, rims & wheels
800 member companies representing
over 3,400 retailers
860 member companies
92
European Tyre and Rubber Manufacturers’ Association, ETRMA (2016), “European Tyre & Rubber Industry; Statistics Edition
2015”. Link:
http://www.etrma.org/uploads/documents/Statistics%20booklet%20-%20edition%202015.pdf
93
International Tyre Manufacturers’ Association (2014), “Europe’s Importers show the way”, November 18th 2014. Link:
http://www.itma-europe.com/2014/11/europes-importers-show-the-way/
94
Information provided by ETRMA. ‘Solution services’ are services provided by the tyre suppliers where
tyres are leased directly to
fleet owners/operators charging a price per km driven.
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-
V
EHICLE SUPPLIERS AND DISTRIBUTORS
Tyres sold on the OEM constitute approximately 25% of the tyre production in Europe
95
. This part
of the tyre market is small compared to the replacement market, but still considered important in
terms of which tyres are used on European roads. Interviews were therefore conducted with key
representatives of the vehicle suppliers and distributors, which were identified as the European
Automobile Manufacturers Association (ACEA) and the European Council for Motor Trades and
Repairs (CECRA). ACEA represents the 15 Europe-based car, van, truck and bus makers and has
close relations with the 29 national automobile manufacturers’ associations
in Europe
96
. CECRA
brings together 24 national professional associations representing the interests of motor trade and
repair business, and 12 European Dealer Councils representing vehicle dealers
97
.
Tyres bought on the OEM are not the key product that is purchased, but only a minor part of the
vehicle, which is the main product. However, the vehicle distributors are still in direct contact with
the end-users, and therefore important for the general label awareness and understanding.
-
C1
END
-
USERS
The C1 tyre market is by far the largest in terms of tyre sales, constituting 77% of the tyre sales in
2013
98
. C1 end-users include consumers defined as private persons buying tyres for their own
private cars, as well as leasing companies buying tyres for their lease cars.
The main difference between the two segments is that private consumers hold all costs for both tyre
purchase and tyre usage, and hence are affected by both the purchase price and the fuel efficiency.
The leasing companies on the other hand, hold only the purchase costs, whereas the lessee holds all
costs for fuel.
-
C
ONSUMER SURVEY
The C1 consumer survey was carried out as an online questionnaire with user-panels of 1000
respondents in six European countries. All respondents were owners of passenger cars who were
responsible for the purchase of tyres. The six countries were selected based on the number of
registered cars
99
, the access to user panels, and the presence of large tyre suppliers in the country.
Furthermore, it was based on the geographical coverage, to have answers from both southern and
central Europe and from Nordic countries, where the use of snow tyres is more predominant than in
the rest of Europe
100
. Based on these considerations, the following countries were chosen:
Germany (~42 million cars)
England (~29 million cars)
France (~32 million cars)
Italy (~37 million cars)
95
Braungardt et al. (2014), “Impact of Ecodesign and Energy/Tyre Labelling on R&D and Technology Innovation”, Link:
http://www.ecofys.com/files/files/fraunhofer-ecofys-2014-impact-of-ecodesign-energy-labelling-on-innovation.pdf
96
ACEA, European Automobile Manufacturers Association, (2016), “Who we are” general website. Link:
http://www.acea.be/about-acea/who-we-are
97 CECRA, The European Council for Motor Trades and Repairs (2016),
“About CECRA”, General website. Link:
http://www.cecra.eu/page/about
98 Van Holsteijn en Kemna B.V. -
VHK (2014), “Ecodesign impact accounting – Part 1, Status Nov. 2013”, Link:
https://ec.europa.eu/energy/sites/ener/files/documents/2014_06_ecodesign_impact_accounting_part1.pdf.
99 Odyssee-Mure
Project (2012), “Energy Efficiency Trends in Transport in the EU” , Link:
http://www.odyssee-
mure.eu/publications/efficiency-by-sector/transport/)
100 Lennart Lomaeus, chairman of DFTF Sweden (Swedish Tyre, Rim & Accessories Suppliers Association) (2015), Presentation:
“Winter tyre Market’s segments evolution in the Nordic countries”.
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Sweden (~4,5 million cars)
Finland (~3 million cars)
The results of the C1 end-user survey are shown in the end of this annex.
-
L
EASING COMPANIES
According to Lease Europe
101
, the leasing companies represent around 25% (2010
102
) of the
European carpark. Ten companies were identified as key players in the European car leasing
market, and an attempt to establish contact for potential interviews was done. Most of the
companies did not show any interest in answering questions about the EU-tyre labelling scheme.
Therefore, interviews have only been made with a few leasing companies in Denmark.
The main purpose of interviewing leasing companies was to identify any significant differences in
tyre purchasing behaviour and use of the tyre label compared to private consumers.
-
C2
END
-
USERS
C2 end-users
are the purchasers and users of C2 tyres, used for light duty vehicles (LDV’s). The C2
end-users can be individuals or companies who
own or rent LDV’s. The main difference is that
LDV owners are affected by both the tyre purchase cost and the tyre fuel efficiency (in terms of fuel
cost), whilst lessees of LDV’s holds only the costs for fuel.
-
C3
END
-
USERS
The C3 end-users are primarily truck fleet owners and operators. Existing truck fleet surveys were
used in this study to reach a larger amount of truck fleet operators than would otherwise have been
possible. The two main studies applied were performed by M2 Conceal (on behalf of Goodyear)
103
and by Commercial Motors Trucking Britain
104
. Since it was not possible within the frame of this
study to make an equally thorough survey with fleet owners, results from these two surveys were
used for information on C3 end-users.
-
M
EMBER
S
TATE
A
UTHORITIES
(MSA
S
)
As part of the 2016 Review Study, MSAs from Belgium, Finland, Germany (3 Regions), Estonia,
Malta, Netherlands (mail), Sweden, United Kingdom, Hungary (mail), Poland and Slovakia were
interviewed. This provides insight in the types of activities carried out and the differences in how
market surveillance is approached in the Member States.
An overview of the market surveillance activities in the Member States is shown in the table below.
The information is both form the interviews and from ADCO minutes. The inspections are counted
as either number of shops or number of tyres or tyres sets inspected and the units are therefore not
aligned.
The prevailing type of Market Surveillance in all Member States is the point of sales inspections.
Some Member States inspected only physical shops, while many also inspected internet shops. In
101 Lease Europe represents about 92% of the entire European leasing market; Link:
http://www.leaseurope.org/uploads/documents/ranking/Leaseurope%20Ranking%20Survey%202013_public.pdf
102
Lease Europe (2011), “The European
Leasing & Automotive Rental Markets
– State of Play” Link:
http://www.leaseurope.org/uploads/documents/events/seminar_for_lessors/2011/Jurgita%20Bucyte_WEB.pdf
103 MV2 Conseil on behalf of Goodyear (2013), Truck fleet survey, Link: http://www.fleetfirst.eu/ff_home_en/news/goodyear-fleet-
survey-reveals-growing-influence.jsp
104
Commercial Motor (2013), “The Ronseat approach”, Ocotber 10th 2013 pp 32-35.
Link:
http://archive.commercialmotor.com/article/10th-october-2013/32/the-ronseat-approach
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all Member States, the main task was to inspect the presence of the label, and that it was positioned
correctly.
In general, the MSAs found high level of compliance regarding position of the label and
information on bills and invoices. However, the actual level seemed to vary greatly, from 0% non-
compliance to 25%, which seems to be due to differences in inspection procedures. The non-
compliance occurred in various ways with the most widespread being the label entirely missing or
positioned wrong.
Document control was only carried out by four of the interviewed Member State. Both the Swedish
MSA and the MSAs of the individual federal states of Germany reported difficulties in requiring the
documentation due to lacking jurisdiction when suppliers/supplier representatives are located in
other countries/Member States. The MSAs are appointed and empowered by national law in a
specific Member State, and hence suppliers located in other Member States can claim they have no
obligation toward the MSAs.
In most Member States, it was not attempted to require the technical documentation, since they
were either aware of the problem of lacking jurisdiction, or because without laboratory testing, there
were no frame of reference to verify the information in the technical documentation.
Only two of the interviewed MSAs, Germany and Belgium, performed laboratory tests to verify the
label values. All Member States mentioned the high costs and too few accredited test facilities to be
the greatest barriers for laboratory testing.
Member State
Sweden
Surveillance activities
Shop inspections including
internet shops
Document control
Tyre documents and
questionnaire regarding supplier
responsibility
Shop inspections (physical shops)
Shop inspections
Information campaign by the
ministry not the MSA itself
Inspections at suppliers,
importers, retailers
Technical documentation
inspection
Shop inspections including
internet shops
Technical documentation
Laboratory testing
Shop inspections
Technical documentation
inspection
Laboratory tests
Germany
–
Baden
Wüerttemberg
Germany
–
Bavarian
Shop inspections
Technical promotional material
Shop inspections
Number of inspections
>30 shops since 2012
10 that failed (no documents
received)
Around 100 tyre sets per year
Around 5-10 tyre sets per
year
760 shops since 2012
Targeting mainly end-users
135 entities since 2013, 640
tyre models
No specific number, but
reports that it is many
172 shops in 2014
Requested 5 documents
Send to Rhineland-Palatinate
362 inspections in 2014
674 inspections in 2015
For the tyres they test in
laboratory
4 models in 2014
8 models in 2015
174 models/41 shops in 2014
316 models/31 shops in 2015
30 inspections
50 shops, 64 tyre models
No or low non-
compliance
No problems of
receiving
documentation
19 shops with no
labelling
All received
119 of the 362
inspections in 2014
Problem with
varying test results
No non-compliance
(2015 final numbers
to be registered)
12 non-compliance
Low non-compliance
<10% non-
compliance
Non- compliance
No non-compliance
Estonia
Netherlands
Poland
Germany
–
Hesse
Germany
–
Rhineland-
Palatinate
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cases from missing
or faulty label
Technical documentation
inspection
Laboratory tests
Finland
United Kingdom
Shop inspections (physical shops)
Awareness campaigns; tyre
dealers, importers, car dealers
Shop inspections
Website monitoring
Technical documentation control
Malta
Information campaigns; end-
users, tyre dealers
Shop inspections, including
internet
Shop inspections
Technical documentation control
8 tyre models (same models
that were tested)
8 tyre models
150 shops since 2013
More than 500 visits in total
since 2013
Requested for 10 models
Merged with energy labelling
campaign
15 shops 1 internet store (87
tyre models)
76 shops since 2013 (only
C1)
36 in 2013 and 40 in 2015
Requested for 10 C1 models
1 not compliant, 1
pending
Low non-compliance
Website monitoring,
2013: 62 tyre brands
–
10 had not label,
18 had incomplete
information
Received for 8
models
Two tyre models not
compliant
In 2015: all showed
the label*
Only received some
of them. Request
again.
Test ongoing
Belgium
Portugal
Italy
Slovakia
Lab test
2 C1 models currently tested
Have not yet implemented the national legislation to appoint a
MSA
Reported that no inspection or other market surveillance activities
were conducted
Shop inspections including
70 dealers inspected in 2014
internet shops
(solely based on complaints)
4 were non-
compliant
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-
R
ESULTS OF THE CONSUMER SURVEY WITH
C1
END
-
USERS
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Appendix 2: Methods and analytical models
I.
-
-
-
-
-
-
-
-
-
-
-
-
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.
C1 vehicle fleet consists of 41% diesel and 59% petrol (ACEA, 2017)
C2 vehicle fleet consists of 88% diesel and 12% petrol (ACEA, 2017)
C3 vehicle fleet consist of 96% diesel and 4% petrol (ACEA, 2017)
105
C1 vehicles drive 13,500 km per year on average
C2 vehicles drive 21,000 km per year on average
C3 vehicles drive 57,500 km per year on average
EU HICP rates are used to convert all prices to 2017 fixed prices
106
Vehicle fleet data was obtained from ACEA:
http://www.acea.be/statistics/article/Report-
Vehicles-in-Use
Fuel prices were obtained from:
https://www.eea.europa.eu/data-and-maps/indicators/fuel-
prices-and-taxes/assessment-7
Road safety and accident data was obtained from:
https://ec.europa.eu/transport/road_safety/specialist/statistics_en#
Road safety costs was obtained from:
https://ec.europa.eu/transport/road_safety/specialist/knowledge/measures/monetary_valuatio
n_of_road_safety_en
and
http://heatco.ier.uni-stuttgart.de/HEATCO_D5.pdf
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”107.
In the 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 analysed “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%
105
http://www.acea.be/uploads/statistic_documents/ACEA_Report_Vehicles_in_use-Europe_2017_FINAL2.pdf
106
http://ec.europa.eu/eurostat/tgm/table.do?tab=table&init=1&language=en&pcode=tec00118&plugin=1
107
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
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-
Also, for each scenario it was considered how many already uses the label in their
purchasing decision, and only the additional influenced end-users were assumed to be
impacted.
S
TOCK MODEL ASSUMPTION
-
Sales figures were received from the industry organisation ETRMA
108
back to 2003 and backed up
by sales data from the market research organisation GfK
109
. The sales data are seen in the table
below.
Table 63: 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
2010
2012
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
224.30 249.72 226.42
77.61
74.64
71.12
24.92
27.75
25.16
7.51
4.98
4.98
11.42
11.56
9.61
4.74
2.72
3.33
350.50 371.36 340.62
Source: ETRMA and GfK
Average tyre lifespans were based on assumptions regarding 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 form the Ecodesign Impact Accounting
110
.
Table 64: Assumption on tyre lifespans and mileage
Average distance
Expected life in
Average tyre
Tyre type
driven per year,
km
lifespan, years
km
56 700
13 500
4.2
C1
71 400
21 000
3.4
C2
200 000
57 500
3.5
C3
Source: Ecodesign Impact Accounting background calculation model, 2017.
Further assumptions used in the stock model:
Table 65: 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
108
http://www.etrma.org/statistics-2
109
http://www.gfk.com/about-gfk/about-gfk/
110https://ec.europa.eu/energy/sites/ener/files/documents/Ecodesign%20Impacts%20Accounting%20%20-
%20status%20January%202016%20-%20Final-20160607%20-%20N....pdf
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-
-
-
-
BAU S
CENARIO ASSUMPTIONS
2008 Impact Assessment No-Label scenario was used as basis for RRC market distribution,
however, not all tables added up to 100% market. These have been adjusted.
For C3 an entirely new market distribution had to be estimated for the BAU scenario, since
the 2008 IA was unrealistically low compared to actual market data.
The three tables below show the percentage market shares assumed for each tyre type (C1,
C2, C3):
T
able 66: BAU Rolling resistance market shares for C1 tyres
RRC bands
6 to 7 7 to 8 8 to 9
9 to 10
10 to 11
11 to 12
Above 12
Market
Band average
6.5
7.5
8.5
9.5
10.5
11.5
13.3 average
0%
0%
1%
4%
12%
24%
60%
2004
12.30
0%
1%
6%
5%
16%
29%
43%
2012
11.79
0%
1%
7%
6%
19%
37%
30%
2013
11.48
0%
1%
8%
7%
22%
43%
19%
2014
11.20
0%
1%
9%
8%
27%
55%
2015
10.76
0%
1%
9%
8%
28%
54%
2016
10.75
0%
1%
11%
12%
40%
36%
2017
10.49
Source: 2008 Impact Assessment
RRC bands
Band
average
2004
2013
2014
2015
2016
2017
Table 67: BAU Rolling resistance market shares for C2 tyres
5.5 - 6.5 6.5 - 7.5 7.5 - 8.5 8.5 - 9.5 9.5 - 10.5 above 10.5 Market
6
7
8
9
10
11.75 average
0%
0%
0%
0%
0%
0%
0%
1%
1%
1%
1%
1%
3%
11%
26%
4%
18%
42%
4%
21%
50%
6%
27%
67%
6%
27%
67%
8%
46%
45%
Source: 2008 Impact Assessment
61%
35%
23%
10.68
10.30
10.06
9.60
9.60
9.35
RRC bands
Band
average
2004
2013
2014
2015
2016
2017
Table 68: BAU Estimated rolling resistance market shares for C3 tyres
Below 4
4 to 5
5 to 6
6 to7
7 to 8
Above 8
Market
3.7
4.5
5.5
6.5
7.5
9.8 Average
0%
0%
3%
28%
33%
38%
0%
2%
5%
34%
26%
34%
0%
2%
5%
35%
29%
29%
0%
2%
5%
36%
58%
0%
3%
6%
37%
54%
0%
3%
6%
45%
46%
Source: Viegand Maagøe, estimates based on real-life market data
7.81
7.78
7.67
6.99
6.93
6.85
-
-
-
-
Wet grip was only given in the 2008 Impact Assessment for C1 superficially.
The market distribution of wet grip classes in the BAU Scenario for the three tyre types (C1,
C2, C3) therefore had to be estimated by extrapolating form real-life market data.
The estimated market shares are shown in the three tables below.
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Table 69: BAU Wet grip market shares for C1 tyres
Wet grip classes
A
B
C
E
F
Market
Class average, C1
1.6
1.47
1.32
1.17
1.0 average
1%
3%
15%
30%
51%
2012
1.12
1%
4%
19%
35%
41%
2017
1.15
Source: estimated based on 2008 Impact Assessment and real-life data (with label)
Table 70: BAU Estimated wet grip market shares for C2 tyres
Wet grip classes
A
B
C
E
F
Market
Class average, C2
1.45
1.32
1.17
1.02
0.9 average
1%
3%
15%
30%
51%
2012
0.99
1%
4%
18%
32%
45%
2017
1.01
Source: estimated based on 2008 Impact Assessment and real-life data (with label)
Table 71: BAU Estimated wet grip market shares for C3 tyres
Wet grip classes
A
B
C
D
E
F
Market
Class average, C3
1.3
1.17
1.02
0.87
0.72
0.6 average
1%
3%
15%
15%
15%
51%
2012
0.75
1%
4%
18%
18%
19%
40%
2017
0.78
Source: estimated based on 2008 Impact Assessment and real-life data (with label)
The Noise level was given in the 2008 Impact Assessment, but TOL had data available for the
market distribution as far back as 2008, which was used as basis for the BAU noise level for each
tyre type (C1, C2, C3). A very limited development in average noise was expected in the BAU
scenario until 2017. The 2008 data and the 2017 estimated value are shown in the table below:
Table 72: average noise level in BAU scenario
2008 average
2017 average
noise, dB
noise, dB
71.20
71.05
C1
72.51
72.35
C2
72.00
71.85
C3
Source: 2008 TOL data and 2017 estimated
-
C
URRENT
L
ABELLING
S
CENARIO MODEL
Only tyres sold on the replacement market, i.e. to replace tyres on a vehicle already in use, are
expected to be affected by the label Regulation. This assumption was made for the following
reasons:
-
-
-
It is not mandatory to always show the tyre label for tyres sold with new vehicles, but only if
the end-user is offered a choice between different tyres.
The 2016 consumer survey showed that less than 5.6% of end-users were offered a choice
and were shown the label information for different tyres when purchasing a new vehicle
The tyres are not expected to be the primary focus of end-users when purchasing a new
vehicle, but rather the car itself is important.
The entire energy consumption of all tyres (including OEM tyres) are included in the modelling, but
only the replacement tyres are expected to change significantly in terms of the performance
parameters on the label.
The following data and assumptions were used in the modelling of the current labelling scenario:
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-
-
-
The OEM performance level for RRC, WG and Noise was assumed equal to the BAU
performance levels, i.e. only the replacement tyres are affected by the label
Before 2012: Linear interpolation from 2008 Impact Assessment estimated performance in
2004.
All performance parameters (for all tyres) are assumed to follow the BAU scenario until
2009, from when linear interpolation is made to 2012, where real-life market data is
available.
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)
The 2016 Review Study showed low degree of market surveillance, and the few tests that have been
performed show a high rate of non-compliance. This low compliance rate is taken into account in
the BAU Scenario, but since no actual EU-wide non-compliance rates are available, the following
assumptions have been made:
-
-
-
10% of tyres on the market does not live up to the performance appearing on their label.
The non-compliant tyres are assumed to be on average
3 classes lower
than stated on the
label.
Table 73: Current label Rolling resistance market shares for C1 tyres
A
B
C
E
F
G
Market
Market average with
average
non-compliance
6.3
7.4
8.7
10
11.5
12.4
0%
3%
29%
42%
24%
1%
9.92
10.28
1%
6%
36%
39%
17%
1%
9.64
10.01
0%
5%
36%
43%
15%
1%
9.63
10.00
0%
5%
38%
42%
14%
0%
9.57
9.93
0%
5%
34%
43%
17%
1%
9.68
10.05
0%
6%
37%
42%
15%
1%
9.59
9.96
Source: Data from TOL (Tyres On-Line, Germany).
Table 74: Current label Rolling resistance market shares for C2 tyres
A
B
C
E
F
G
Market
Market average with
non-compliance
5.3
6.4
7.7
8.9
10.2
10.8 average
0%
0%
0%
0%
0%
0%
1%
26%
56%
15%
2%
8.80
4%
20%
44%
28%
3%
8.97
6%
25%
41%
25%
2%
8.82
5%
29%
40%
24%
1%
8.77
4%
25%
42%
27%
3%
8.92
4%
28%
41%
25%
2%
8.83
Source: Data from TOL (Tyres On-Line, Germany).
9.13
9.30
9.15
9.10
9.25
9.16
RRC class
Class average
2012
2013
2014
2015
2016
2017
RRC class
Class average
2012
2013
2014
2015
2016
2017
Table 75: Current label Rolling resistance market shares for C3 tyres
RRC class
Market
Market average with
A
B
C
D
E
F
non-compliance
Class average
3.8
4.7
5.7
6.7
7.7
8.6 average
2%
10%
33%
37%
16%
3%
6.07
2012
6.43
2%
11%
33%
37%
15%
2%
6.34
2013
6.70
1%
10%
36%
36%
14%
2%
6.30
2014
6.66
1%
7%
29%
38%
20%
5%
6.28
2015
6.64
1%
7%
29%
40%
18%
4%
6.54
2016
6.90
0%
16%
44%
26%
13%
1%
6.50
2017
6.86
Source: Data from TOL (Tyres On-Line, Germany).
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Table 76: Current label Wet grip market shares for C1 tyres
Wet grip class
A
B
C
E
F
Market
Market average with
non-compliance
Class average
1.6
1.47
1.32
1.17
1.04 average
10%
27%
61%
9%
3%
1.36
2012
1.32
18%
37%
52%
8%
3%
1.39
2013
1.35
21%
37%
52%
8%
3%
1.40
2014
1.35
23%
40%
50%
8%
1%
1.41
2015
1.36
21%
38%
49%
11%
3%
1.40
2016
1.35
26%
41%
48%
9%
3%
1.41
2017
1.36
Source: Data from TOL (Tyres On-Line, Germany).
Table 77: Current label Wet grip market shares for C2 tyres
Market
Market average with
Wet grip class
A
B
C
E
F
average
non-compliance
Class average
1.45
1.32
1.17
1.02
0.9
2%
29%
61%
8%
1%
1.21
2012
1.16
3%
27%
56%
13%
1%
1.20
2013
1.15
5%
31%
49%
15%
1%
1.21
2014
1.16
6%
32%
45%
17%
0%
1.21
2015
1.16
6%
30%
43%
20%
1%
1.20
2016
1.16
8%
34%
38%
18%
1%
1.22
2017
1.17
Source: Data from TOL (Tyres On-Line, Germany).
Table 78: Current label Wet grip market shares for C3 tyres
Wet grip class
A
B
C
D
E
Market
Market average with
non-compliance
Class average
1.3
1.14
1
0.85
0.7 average
11%
65%
21%
3%
0%
1.12
2012
4%
46%
47%
2%
0%
1.07
2013
5%
47%
45%
3%
0%
1.08
2014
6%
53%
38%
3%
0%
1.09
2015
2%
39%
54%
4%
0%
1.06
2016
3%
42%
51%
4%
0%
1.06
2017
Source: Data from TOL (Tyres On-Line, Germany).
Table 79: 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).
1.07
1.03
1.03
1.04
1.01
1.02
-
-
-
E
FFECT OF
R
OLLING RESISTANCE ON FUEL CONSUMPTION
Based on the calculations form the official “fuel savings calculator”
111
Fuel savings calculator is based on measurements performed by IDIADA for the European
Commission
112
111
https://ec.europa.eu/energy/en/topics/energy-efficiency/energy-efficient-products/tyres
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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 forms 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 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 22. In the scenario calculations 50/50 share of urban and non-urban driving was
assumed.
Table 80: K-factors used in calculation of fuel consumption from RRC development
∗
%
RRC development
Increase in RRC
Decrease in RRC
Road type
Urban
Non-urban
Average (50/50)
Urban
Non-urban
Average (50/50)
C1
0.104
0.158
0.131
0.145
0.183
0.164
C2
0.098
0.118
0.108
0.109
0.125
0.117
C3
0.095
0.112
0.1035
0.106
0.118
0.112
Source: IDIADA background report on the fuel savings calculator
-
E
FFECT OF
W
ET GRIP ON SAFETY
The societal costs related to a change in tyre wet grip rating have been estimated using a
methodology from a 2014 study by TNO on Potentials benefits of Triple-A tyres in the
Netherlands
113
. 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 and
accordingly the distribution between fatal, severe and slightly injured people can be translated into
societal costs.
112
http://www.applusidiada.com/en/aboutUs/inbrief
113 TNO
185
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Figure 24 Methodology flow diagram
114
Data and assumptions
-
Data has been 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
115
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 on mode of transportation
116
and is therefore assumed
to be the same as for fatalities. The distribution between severe and slight injuries are based
on rough estimates
117
:
o
19% Severely injured
o
81% slightly injured
It is assumed that improved wet grip only affects accident on wet road. The share of
accidents on wet road was 9%
118
in 2015. The share is assumed to be constant through the
whole modelling period.
The distribution of accidents by road type are divided into the following based on 2015
numbers
119
:
o
Urban
–
37,3%
o
Rural
–
55,0%
-
114 TNO
115 https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/statistics/dacota/asr2017.pdf
116 https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/observatory/historical_evol.pdf
117 https://ec.europa.eu/transport/road_safety/specialist/statistics_en#
118 https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/statistics/dacota/asr2017.pdf
119 https://ec.europa.eu/transport/road_safety/sites/roadsafety/files/pdf/statistics/dacota/asr2017.pdf
186
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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 23
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 unit-less, and
compared to a Standard Reference Test Tyre (SRTT).
Table 81: G limit values for wet grip scales of the three tyre types C1, C2 and C3
C1 tyres
C2 tyres
C3 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
1,40 ≤ G
1,25 ≤ G ≤ 1,39
1,10 ≤ G ≤ 1,24
Empty
0,95 ≤ G ≤ 1,09
G ≤ 0,94
Wet grip
class
A
B
C
D
E
F
G
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
Wet grip class
A
B
C
D
E
F
Regulation 661/2009 sets out minimum wet grip requirements for C1 tyres only. For normal tyres
the limit value is ≥1.1.
Braking distance
There is a clear relation between wet grip level and braking distance as seen in the table below. E.g.
wet grip level F has a 55% longer braking distance than wet grip level A. To simplify the
calculations a linear trend has been assumed making it possible to calculate the change in braking
distance as a function of wet grip index (G). The ratio is assumed equal for all three tyre types (C1,
C2, C3), but will of course vary due to different wet grip intervals.
Table 82: Braking distance for different wet grip levels compared to rating A. Assumed equal for C1,
C2 and C3 tyres.
Tyre label
Increased
braking
distance
(index)
100
111
124
132
141
155
A
B
C
D
E
F
Impact speed
187
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1896114_0094.png
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 83 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.
Figure 25 Injury risk of passenger car occupants as a function of impact speed (km/h)
120
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.
120 TNO study
188
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Table 84 Baseline distribution of injury types based on average accident impact speeds for different
road types
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
Road type
-
S
OCIETAL COSTS
The estimation of societal costs of accidents is based on values from the 2006 HEATCO report
121
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 correlate to the GDP of the Member State. The
valuation of the three remaining Member States 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 Member State have 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 27).
Table 85 Societal costs based on injury types
122
Injury type Societal costs
thousand
EUR (2017)
Fatal
1,673
Severe
251
Slight
19
-
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
123
for 2012-2016 (see Table
28). Data for number of employees are from ETRMA
124
, which has been upscaled to EU-28 based
on ETRMA’s market share.
121
Developing Harmonised European Approaches for Transport Costing and Project Assessment - http://heatco.ier.uni-
stuttgart.de/HEATCO_D5.pdf
122
Converted to 2017 price level - Developing Harmonised European Approaches for Transport Costing and Project Assessment -
http://heatco.ier.uni-stuttgart.de/HEATCO_D5.pdf
189
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1896114_0096.png
Table 86 Turnover and employees - tyre manufacturers
Year
2012
2013
2014
2015
2016
Avg.
Turnover Employees Turnover/
million
employee
EUR
EUR
17,634
257,434
68,501
16,800
258,440
65,007
16,813
16,801
16,836
16,977
260,124
272,018
281,839
265,971
64,635
61,764
59,738
63,929
The average turnover of 63,929 EUR/employee has been fixed throughout the whole modelling
period and therefore assumed to be constant. Similar the mark-up factor relative to the retail
turnover, calculated to an average of 2, is assumed 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
125
, which is an average for all industries. It is unknown if the tyre wholesale
industry deviate from this.
Retail
The yearly retail turnover has been 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
126
giving an accurate estimate of the individual unit prices.
127
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
128
, giving a relatively low sample size. Results should therefore be considered with care.
123 Sold production, exports and imports (NACE Rev. 2)
–
Product codes 22111100, 22111355, 22111357
124http://www.etrma.org/uploads/20170912%20-%20Statistics%20booklet%202017%20-
%20alternative%20rubber%20section%20FINAL%20web1.pdf
and personal correspondence with ETRMA.
125 http://www.eurocommerce.eu/retail-and-wholesale-in-europe/facts-and-figures.aspx
126 Germany, France, UK, Spain, Italy
127 GfK data
128
http://www.daekonline.dk
Based on 180 tyre models.
190
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RRC
–
WG
A
B
C
E
F
G
Table 87 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*
T
able 88 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 89 Unit price matrix - 2018 EUR
–
C3 tyres. *Identified as an outlier and adjusted
129
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 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 90 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)
129
http://www.daekonline.dk
Based on 180 tyre models.
191
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Table 91 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 92 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 93 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
192
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Annex 6: Results
This annex provides further graphs and tables of the results from the model calculations made by
Viegand Maagøe, for which the underlying data and assumptions are presented in Annex 4.
1. List of policy options, including modified policy option
Short
name
BAU
PO2
PO3
PO3B
PO3C
PO3D
PO3E
PO3F
PO4
PO4B
PO4C
PO4D
PO4E
PO4F
Description
Baseline
–
Business as usual. How the market would develop without changing
the current regulation
Policy Option 2. Non-legislative measures only
Policy Option 3. Legislative amendments
As policy option 3, but without the effect of rescaling the label classes
As policy option 3, but without the effect of third-party independent testing
As policy option 3, but without the effect of online labelling
As policy option 3, but without the effect of the Digital Registration database
As policy option 3, but without the effect of mandatory labelling of OEM tyres
Policy Option 4: Option 2 + Option 3. Non-legislative and legislative
amendments are all applied
As policy option 4, but without the effect of rescaling the label classes
As policy option 4, but without the effect of third-party independent testing
As policy option 4, but without the effect of online labelling
As policy option 4, but without the effect of the Digital Registration database
As policy option 4, but without the effect of mandatory labelling of OEM tyres
2. End user expenditure
End user purchase prices for C1, C2 and C3 tyres (price per tyre) are shown in the three tables
below.
Table 94: End user purchase prices in each scenario and sub-scenario for C1 tyres
PO short name
BAU
PO2
PO3
PO3B
PO3C
PO3D
PO3E
PO3F
PO4
PO4B
PO4C
PO4D
PO4E
PO4F
2017
83
83
83
83
83
83
83
83
83
83
83
83
83
83
2020
85
86
90
89
87
89
88
89
90
89
88
90
90
89
2025
87
88
91
90
90
91
91
91
91
90
90
91
92
91
2030
89
89
94
91
92
94
93
94
92
90
91
93
93
93
193
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Table 95: End user purchase prices in each scenario and sub-scenario for C2 tyres
PO short name
BAU
PO2
PO3
PO3B
PO3C
PO3D
PO3E
PO3F
PO4
PO4B
PO4C
PO4D
PO4E
PO4F
2017
97
97
97
97
97
97
97
97
97
97
97
97
97
97
2020
97
100
107
108
102
104
103
107
112
110
106
110
108
110
2025
100
103
107
113
103
105
103
107
117
114
113
117
115
117
2030
103
106
105
115
100
103
99
105
119
115
115
118
117
119
Table 96: End user purchase prices in each scenario and sub-scenario for C3 tyres
PO short name
BAU
PO2
PO3
PO3B
PO3C
PO3D
PO3E
PO3F
PO4
PO4B
PO4C
PO4D
PO4E
PO4F
2017
528
528
528
528
528
528
528
528
528
528
528
528
528
528
2020
525
519
516
514
517
519
519
516
515
515
514
511
514
511
2025
523
520
521
518
521
521
523
519
514
518
514
516
515
516
2030
525
519
523
518
526
527
527
525
517
516
512
514
514
512
194
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The three graphs below show the development in total end-user expenditure in terms of total cost of
ownership (TCO) for C1, C2 and C3 tyres respectively.
Figure 26: End- user net expenditure (Total Cost of Ownership, TCO), for C1 end users
C1 End-user net expenditure (purchase cost - energy cost savings)
5.700
5.600
Million Euro
5.500
5.400
5.300
5.200
5.100
5.000
2017
BAU
PO2
PO3
PO4
2019
2021
2023
Year
2025
2027
2029
Figure 27: End- user net expenditure (Total Cost of Ownership, TCO), for C2 end users
C2 End-user net expenditure (purchase cost - energy cost savings)
12.500
12.000
BAU
PO2
11.000
PO3
PO4
Million Euro
11.500
10.500
10.000
2017
2019
2021
2023
Year
2025
2027
2029
195
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1896114_0102.png
Figure 28: End-user net expenditure (Total Cost of Ownership, TCO), for C3 end users
C3 End-user net expenditure (purchase cost - energy cost savings)
90.000
85.000
Million Euro
80.000
BAU
PO2
75.000
PO3
70.000
PO4
65.000
2017
2019
2021
2023
Year
2025
2027
2029
196
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3. Economy: Business turnover
Turnover - Retailers
60.000
55.000
BAU
PO2
45.000
PO3
PO4
40.000
Mln. EUR
50.000
35.000
2017
2019
2021
2023
Year
2025
2027
2029
Turnover - Wholesaler
38.000
36.000
34.000
32.000
BAU
PO2
PO3
PO4
Mln. EUR
30.000
28.000
26.000
24.000
22.000
20.000
2015
2017
2019
2021
2023
Year
2025
2027
2029
197
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1896114_0104.png
Turnover - Manufacturer
30.000
28.000
BAU
PO2
24.000
PO3
PO4
22.000
26.000
Mln. EUR
20.000
18.000
2017
2019
2021
2023
Year
2025
2027
2029
Turnover - Total
125.000
120.000
115.000
110.000
BAU
PO2
105.000
100.000
95.000
90.000
85.000
80.000
2017
PO3
PO4
Mln. EUR
2019
2021
2023
Year
2025
2027
2029
198
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1896114_0105.png
Turnover - Cumulative growth TOTAL
120.000
100.000
80.000
BAU
PO2
PO3
PO4
Mln. EUR
60.000
40.000
20.000
0
2015
2017
2019
2021
2023
Year
2025
2027
2029
Employment - Total
3.400.000
3.200.000
3.000.000
BAU
Employees
2.800.000
2.600.000
2.400.000
2.200.000
2.000.000
2015
PO2
PO3
PO4
2017
2019
2021
2023
Year
2025
2027
2029
199
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4. Safety and safety costs
Turnover - Cumulative growth TOTAL
100.000
80.000
BAU
Mln. EUR
60.000
PO2
PO3
40.000
PO4
20.000
0
2015
2017
2019
2021
2023
Year
2025
2027
2029
Road safety (Severe injuries)
16.000
15.500
15.000
14.500
Severe injuries
14.000
13.500
13.000
12.500
12.000
11.500
11.000
2015
2017
2019
2021
2023
Year
2025
2027
2029
PO4
PO2
PO3
BAU
200
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1896114_0107.png
Road safety (Minor injuries)
144.000
142.000
Minor injuries
BAU
140.000
PO2
138.000
PO3
PO4
136.000
134.000
2015
2017
2019
2021
2023
Year
2025
2027
2029
Safety Cost (Fatalities)
4.000
3.800
3.600
3.400
BAU
PO2
3.000
2.800
2.600
2.400
2.200
2015
PO3
PO4
Mln. EUR
3.200
2017
2019
2021
2023
Year
2025
2027
2029
201
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Safety Cost (Severe injuries)
3.900
3.700
3.500
Mln. EUR
3.300
3.100
2.900
2.700
2.500
2015
BAU
PO2
PO3
PO4
2017
2019
2021
2023
Year
2025
2027
2029
Safety Cost (Minor injuries)
2.800
2.780
2.760
2.740
Mln. EUR
2.720
2.700
2.680
2.660
2.640
2.620
2.600
2015
2017
2019
2021
2023
Year
2025
2027
2029
PO4
BAU
PO2
PO3
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Safety Cost savings (Total)
800
700
600
BAU
500
Mln. EUR
PO2
400
300
200
100
0
2015
PO3
PO4
2017
2019
2021
2023
Year
2025
2027
2029
Safety Cost savings cumulative TOTAL
9.000
8.000
7.000
6.000
Mln. EUR
5.000
4.000
3.000
2.000
1.000
0
2015
2017
2019
2021
2023
Year
2025
2027
2029
PO2
PO3
PO4
BAU
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5. Energy and GHG emissions
Fuel consumption for all types PJ/a
12 700
12 600
Energy consumption, PJ
12 500
12 400
12 300
12 200
12 100
12 000
2015
2020
Year
2025
2030
BAU
PO2
PO3
PO4
Cumulative fuel savings for all tyre types, PJ
120,00
100,00
Energy saving, PJ
80,00
BAU
PO2
60,00
PO3
PO4
40,00
20,00
0,00
2015
2017
2019
2021
2023
Year
2025
2027
2029
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GHG emissions for all types
940
930
920
CO2 emission, Mt
910
900
890
880
2015
BAU
PO2
PO3
PO4
2017
2019
2021
2023
Year
2025
2027
2029
Cumulative GHG emission mitigation for all types
120,00
100,00
80,00
60,00
40,00
20,00
0,00
2015
BAU
PO2
PO3
PO4
GHG mitigation, MT CO2-eq
2017
2019
2021
2023
Year
2025
2027
2029
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Annex 7: Glossary
Term or acronym
RRC
WG
BAU
PO2
PO3
PO4
OPC
SRTT
MSA
C1 Tyres
C2 Tyres
C3 Tyres
LCV
HCV
TCO
LCC
GHG emissions
OEM tyres
TLR
GSR
Rolling Resistance Coefficient
Wet Grip
Business as Usual
Policy Option 2
Policy Option 3
Policy Option 4
Open Public Consultation
Standard Reference Test Tyre
Market Surveillance Authority
Passenger car tyres
Light commercial vehicle tyres
Medium and Heavy commercial vehicle tyres
Light Commercial Vehicle
Heavy Commercial Vehicle
Total Cost of Ownership
Life Cycle Cost
Greenhouse Gas emissions
Original Manufacturer Equipment tyres (supplied with new vehicles)
Tyre Labelling Regulation, Regulation (EC) 1222/2009
General Safety Regulation for motor vehicles, Regulation (EC) No 661/2009
Meaning or definition
Type Approval Process The tyre testing process under the GSR
OPC
MS
3-PMSF
ICSMS
ADCO groups
SMEs
DALY
VOLY
Open Public Consultation
Member State
3-Peak Mountain Snow Flake
The internet-supported information and communication system for the pan-
European market surveillance
Administrative Cooperation Groups
Small and Medium Enterprises
Disability Adjusted Life Years
Value of One Life Year
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Retreading
Studded tyres
Thee worn-out tread of the tyre is replaced with a new one, which can be repeated
as long as the casing integrity is guaranteed, and which extends the life of used tyres
Tyres with metal studs embedded within the tread in order to increase the traction of
the tyre, in particular on ice.
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