Official Journal of the European Union

C 62/280

Opinion of the European Economic and Social Committee on ‘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 — 2018/0148 (COD))

(2019/C 62/44)




European Parliament, 11.6.2018

Council, 14.6.2018

Legal basis

Articles 194(2), 114 and 304 of the Treaty on the Functioning of the European Union



Section responsible

Transport, Energy, Infrastructure and the Information Society

Adopted in section


Adopted at plenary


Plenary session No


Outcome of vote



1.   Conclusions and recommendations


The EESC welcomes this new review, by the European legislator, of the overall performance and quality, as well as labelling, of tyres used in the EU, in keeping with its own recommendations. Tyres, as the only point of contact between a vehicle and the road, make a substantial contribution to the safety of transport in general and in terms of fuel consumption.


The EESC agrees that improving the labelling of tyres will give consumers more information on fuel efficiency, safety and noise, allowing them to obtain relevant and comparable information when purchasing new tyres, and to make informed decisions.


A further important aspect is the fact that good labelling enables consumers to make choices based on a more realistic balance between deciding factors, i.e. performance data, brand image and pricing. This also assists informed buyers in making profitable and environment-friendly purchasing decisions that simultaneously benefit the environment and save money — a not insignificant factor.


The EESC acknowledges that the proposal for a regulation will help improve the effectiveness of the tyre labelling scheme so as to ensure cleaner, safer and quieter vehicles and to maximise the scheme’s contribution to the modernisation and decarbonisation of the transport sector.


Developing, producing and re-treading high-quality tyres can indirectly make a considerable contribution to safeguarding high added-value European manufacturing and, consequently, high-quality employment. With regard to society as a whole, this could lower the total costs for end-users and expenditure, both in financial terms and with regard to health and accident prevention.


The EESC backs the review of the tyre labelling scheme, as it feeds into the EU’s efforts to reduce greenhouse gas emissions and air pollution and thereby to improve road transport safety, health protection and economic and environmental efficiency.


The EESC considers that it is essential for tomorrow’s mobility system to be safe, clean and efficient for all EU citizens. The aim is to make European mobility safer and more accessible, European industry more competitive, European jobs more secure, and for the Union to be cleaner and better adapted to the imperative of tackling climate change. This will require the full commitment of the EU, Member States and stakeholders.


The EESC welcomes the strengthening of the requirement to display the label in situations where consumers do not see the tyre(s) they are considering buying (because the tyres are stocked elsewhere, or with distance or internet selling).


The Committee approves the proposal’s plan to include tyres in the product registration database recently established under Regulation (EU) 2017/1369 in order to improve market surveillance and information for consumers.


The EESC agrees that suppliers should be required to enter information in the new product database. This is information that they currently have to provide to national market surveillance authorities on request. The ensuing additional burden is therefore considered minimal and proportionate to the benefits, particularly since it is possible in this regard to link with existing databases, and prevent consumers from being inundated with information.


The deadline for implementing the regulation should be extended by one year to allow for detailed preparation. Regarding the reference date, account should be taken of the date of manufacture indicated on the product rather than the date of placing on the market, which entails a risk of overlap or double entry.


The proposal for compulsory inclusion on the label of performance on snow and the brand new ice logo (design to be introduced by ISO by December 2018) is a positive initiative, and especially relevant for countries in northern Europe. A sure testing method for grip on ice is yet to be developed and finally adopted; a gradual introduction is therefore justified.


The EESC welcomes the increase in the number and importance of safety-related aspects among the parameters appearing on the label. However, this does not appear to be compatible with the proposed change to the format of the label, in particular its internal proportions and overall dimensions.


Arrangements for the regular re-examination of the regulation, facilitated by research, impact analysis and consultation, operate smoothly and, due to the considerable complexity of the subject, should continue to apply in the future, before any substantial technical amendment. The Commission’s delegated powers between re-examinations are justified for minor, logical amendments on the grounds of technical progress.


The existing classes of parameter are appropriate for at least one additional re-examination cycle, given that an amendment to the scale is not justified in the light of the top classes which are currently practically empty.


It is up to the Member States to encourage manufacturers to secure stable and high-quality results in terms of emissions and technical development, but these must be kept within class C and above on the basis of standard principles.


The inclusion of mileage and abrasion information on the label, or among the technical data, could be encouraged in the future. However, until there is a standardised and adequate testing method available, we cannot afford to undermine the credibility of labelling by introducing uncertain and insufficiently grounded information.


The future introduction of labelling for re-treaded C3 tyres is to be welcomed. Here again, relevant and reliable testing methods will need to be finalised in advance. SMEs carrying out re-treading must be protected from any excessive cost arising from testing methods.


If all the rules are to be successful, it is vital to provide appropriate information and ensure that consumers and users have the necessary knowledge and are well prepared by means of training, information, campaigns, purchase advice and the broad involvement of civil society.

2.   Introduction: background and key points of the proposal


The proposal for a regulation under examination repeals and replaces Regulation (EC) No 1222/2009 (1) on the labelling of tyres with respect to fuel efficiency and other essential parameters (the Tyre Labelling Regulation, TLR).


The TLR was amended twice in 2011 before it entered into force in 2012. First, to include a new testing method for wet grip, and subsequently to add a stricter laboratory alignment procedure for the measurement of rolling resistance. The proposal currently presented by the Commission incorporates these two amendments.


In 2009, the EU adopted two sets of rules relating to tyres, to reflect new requirements and professional advice:

the TLR, which set out Union requirements harmonising the information on tyre parameters to be provided to end-users to enable purchasers to make an informed choice; and

the Regulation (2) on type-approval requirements for the general safety of motor vehicles (GSR), which put in place harmonised technical requirements that tyres must satisfy before they can be placed on the Union market.


The GSR puts in place minimum requirements, inter alia, for tyres as regards: (i) rolling resistance; (ii) wet grip performance; and (iii) external rolling noise of tyres.


These requirements became applicable from 1 November 2012, with a second stage of more stringent requirements for rolling resistance starting to apply on 1 November 2016 (with further adjustments coming into application in 2018 and 2020).


The general energy labelling framework was updated in 2017 with the adoption of Regulation (EU) 2017/1369 (3). This repealed and replaced Directive 2010/30/EU and introduced a number of new elements, such as a product registration database and new rules on visual advertising and on distance and internet sales.


The Council referred the first proposal to the EESC on 17 December 2008, and the section responsible adopted its opinion on 12 March 2009 (TEN/369, rapporteur: Virgilio Ranocchiari). The EESC then adopted its opinion on 25 March 2009 during its 452nd plenary session.


The European Commission commissioned a detailed study and impact assessment [SWD(2018) 189 final] in order to assess the effectiveness of Regulation (EC) No 1222/2009. Their conclusions have served as the basis for presenting its proposal for an amendment. It adds two parameters to the GSR, i.e. the possibility of indicating: iv. snow performance; and v. ice performance. The correlation between the parameters measured and the areas concerned is set out in the following table:



Rolling resistance

Wet grip






















3.   General comments


Transport accounts for more than 30 % of energy consumption in the EU. Road transport in particular is responsible for about 22 % of the EU’s total greenhouse gas (GHG) emissions. The aim of the 2016 communication on A European Strategy for Low-Emission Mobility is to reduce, by 2050, GHG emissions from transport by at least 60 % compared to 1990. The third mobility package seeks to reduce emissions from cars and lorries, improve the safety of road transport and reduce pollution. It also contributes to reducing the EU’s dependence on energy imports. Vehicle tyres affect fuel consumption (and thus GHG emissions), noise and safety.


Stocktaking of the current Tyre Labelling Regulation has shown that it is not sufficient to fully achieve the aim of increasing the environmental efficiency of road transport by promoting fuel-efficient and safe tyres with low noise levels. This is principally due to:


the low visibility, and low public awareness, of tyre labelling;


compliance problems and inadequate enforcement of the rules by Member States;


uncertain performance classes and inaccurate and incomplete information.


EU regulatory action ensures:


the same, harmonised information for end-users in whichever Member State they purchase their tyres;


reduced costs for suppliers, who are able to market their tyres throughout the EU with only one label.


These advantages primarily benefit consumers, increase safety and strengthen the competitiveness of the EU tyre industry. They facilitate the trade of tyres within the internal market, also benefiting consumers in terms of lower overall costs and a wider range of products. For action at EU level to be effective, the market surveillance effort must be consistent across the EU to support the internal market. Manufacturers should be incentivised to invest resources in designing, making and selling energy-efficient tyres.


The open public consultation revealed a consensus on the need to improve awareness of the label through awareness campaigns, mandatory online labelling and the labelling of tyres sold originally with new cars. To improve consumer confidence, respondents agreed on increasing market surveillance and creating a better platform for the authorities to enforce and coordinate activities.


The increase in the number and importance of safety-related parameters among the items appearing on the label is to be welcomed. However, this does not appear to be compatible with the relative reduction of the area given over to showing these parameters, leading to an amendment to the appearance of the label. Neither is it clear why the label dimensions must be changed.


The in-depth impact assessment showed that confidence in labelling systems was a sensitive and important issue, meaning that regulation bears a heavy responsibility, since a small number of precise and reliable information parameters must be selected and communicated. This is a costly task for national market surveillance bodies as they must protect not only consumers, but also honest manufacturers, so that the latter are not put at a competitive disadvantage compared to businesses that are less reliable — or not reliable at all — and therefore carry lower costs and charge lower prices.


A combination of all the elements mentioned above can establish an appropriate framework to support research, development and innovation and properly guide the objectives and key resources allocated to them.

4.   Specific comments


In order to introduce new requirements and bring the annexes into line with technical progress, the European Commission will have to consult experts, using delegated powers. However, amendment of the regulation using delegated powers must be restricted to measures arising from technological progress, and must not concern substantial changes such as new provisions on mileage, abrasion or re-treaded tyres, for which regular re-examination is proposed. This enables better law-making (4). In this regard, strong representation of civil society professional organisations must be ensured. These organisations — unlike other institutions, which have only isolated, cyclical and/or indirect data — receive direct, permanently updated information through the user community (individual consumers and vehicle fleet managers).


On the basis of the research report drawn up with a view to the re-examination of the regulation and market research data, the EESC considers that it is too early to change the parameter classes: in practice, where rolling resistance and wet grip classes are concerned, fewer than 1 % of products on the market obtain an A, and so this category is practically empty. In accordance with Regulation (EU) 2017/1369, an amendment to the scale is only justified if 30 % of products have reached the highest class. Moreover, a scale with six or seven steps, the top two of which are unused, provides little motivation. From the technical point of view, account should also be taken of the fact that tests carried out on a single series of tyres may sometimes give rise to a difference of two classes.


The EESC endorses the future aim of introducing parameters concerning mileage and abrasion — provided that clear and meaningful data are available. In this connection, however, it points out that no adequate and suitable testing method (other than practical testing) has been found over the last century. These test parameters should reflect and characterise sustainable, changing and long-term use. Efficient and reasonably-priced laboratory modelling of all these parameters necessarily comprises an accelerated overload test, which will certainly not be representative of the diversity of real requirements and different natural behaviours under these conditions. These tests, carried out under variable conditions, lead to different classifications and rankings of products with regard to mileage and abrasion.


It may be concluded from this that it would be dangerous, and fatal for label credibility, for consumers to observe performances in practice differing from the information given on the label. No such problem arises for the other parameters, since it is isolated, one-off behaviours that are modelled and demonstrated. Including the two above-mentioned parameters on labels would be highly risky and is not recommended at present.


The identification of several negative environmental impacts demonstrates the importance of reducing wear: firstly, the presence of plastic particles in water, even if the proportion of rubber in it is relatively low, and secondly, the presence in the air, albeit at extremely low concentrations, of benzopyrene, most likely as a result of energy recovery, which is in turn largely responsible for the formation of smog and for certain respiratory disorders.


More broadly, the EESC shares the view that re-treading C3 tyres would permit savings in raw materials and energy to be made around the world. It should, however, be noted that only the three parameters currently appearing on the label can be applied to re-treaded tyres, and only on a limited basis. In the case of data on life expectancy and abrasion, the division of responsibility for quality between the manufacturer of the tyre carcass and the re-treader is even less clearly defined. Including these parameters on the label is therefore not recommended. In view of their negligible market share, it is unreasonable, from an economic and environmental point of view, to include re-treaded C1 and C2 tyres within the scope of the TLR. On the other hand, consideration should be given to voluntary labelling by manufacturers of re-treaded C1 and C2 tyres, to meet the demand for buyers wanting minimum label performance.


The EESC warns of the exponential increase in the number of entries to the product database which will be caused by the inclusion of re-treaded tyres, in comparison with new tyres. The combination of tyre re-treader and tyre carcass manufacturer, the number of re-treadings, and the various re-treading techniques are all aspects that generate a new item number. The large number of product tests represents an excessive financial burden for manufacturers, the vast majority of whom are SMEs, and consumers cannot have a clear view of the excessively high variety of products.


The EESC considers the deadline for preparing for the implementation of the regulation in question is short, and should be extended by a year. For the products covered by these provisions, it would be far simpler and more manageable to consider the date of manufacture rather than the date of placing on the market. The date of manufacture is permanently visible on the tyre, and reduces the risk of being entered twice into the database.


In addition, the new regulation alone will still not enable consumers to compare the performances and prices of tyres according to fuel consumption. Although information on consumption is often available at sales points or in the instructions for use of the vehicle, most consumers still do not have sufficient knowledge or full information on this subject.


Since tyre performances are, moreover, linked but also contrary to each other, the information will thus concern the greatest possible optimisation of the choice between these parameters. This does not, however, enable consumers to make fully informed choices, because they are unaware of the links between the parameters provided.


The EESC recommends that national and European professional organisations, civilian and police bodies responsible for road and transport safety, and driving schools include knowledge about tyres, together with all the technical parameters and symbols that will be applicable under the regulation, in their educational, communication and ongoing training programmes and examinations.


It is also important that manufacturers should ensure that their commercial partners, often tyre dealers, should properly inform buyers about the vehicle sold or the tyres they wish to purchase and, insofar as is possible, offer them alternative options backed by advice.


In the EESC’s view, the EU should press the Member States to develop information and awareness-raising campaigns, not only about the regulation, but also about other tyre-related issues such as the use of the right tyres according to season, general use of tyres, etc.

4.7.   Remarks for future consideration


In the longer term, the Union should consider introducing advisory information concerning the end-of-life recyclability of tyres, not on the label but rather in the technical documentation and technical promotional material.


After the next review period of the regulation, it could be worth reconsidering whether additional differentiation needs to be applied concerning snow tyres (in tests, in the technical documentation and technical promotional material or on the label).

Brussels, 17 October 2018.

The President of the European Economic and Social Committee


(1)  OJ L 342, 22.12.2009, p. 46.

(2)  OJ L 200, 31.7.2009, p. 1.

(3)  OJ L 198, 28.7.2017, p. 1.

(4)  OJ L 123, 12.5.2016, p. 1.