Last chance to comment on updated EU tire labels

The EU has proposed substantial modifications to its tire labelling laws, due to come into force from 1 June, 2020.

The EC has published a near-final rule and opened it for comments. The final opportunity to comment closes on 30 July.

This near-final rule follows the consultation exercise that took place from October 2017 to January 2017, when 70 responses were collected.

All parties are invited to comment on the latest documents. This will be the final opportunity to comment before the document becomes law. The comment page has been available since May 17. Up to now, just one respondent has taken the opportunity to comment.

Main amendments

• The labelling of tires delivered with vehicles;
• Online labelling;
• The inclusion on the label of snow and ice performance information;
• Extending the scope of the labelling requirement to C3 (truck) tires;
• Strengthening the requirements relating to technical documentation;
• Amendments to the annexes on testing methods and extending the type approval process to include the label declaration;
• The future inclusion of mileage and abrasion as a performance parameters;
• Re-adjustment of the label classes; and
• The inclusion of tires in the product registration database established under Regulation (EU) 2017/1369.

Reasoning for the update

The update is designed to take account of new technology in tire design and materials and also to meet two weaknesses identified by research into the use and effectiveness of the label. The investigation questioned 6000 consumers in six Member States. The results identified two key weaknesses:

• Reduced effectiveness of the tire label due to poor visibility;
• Non-compliance due to weak enforcement.

The new label is therefore intended to:

• Increase consumers’ awareness of and confidence in the label (which will make them more likely to use the label information when purchasing tires), and
• Improve market surveillance to ultimately achieve in full the three objectives of the Tyre Labelling Regulation (TLR).

The new label (main image) has a fresh design with space for more performance categories such as mileage and abrasion, which may be included in future revisions, but also cold-weather grip and ice grip (see below)

Product registration

The new label includes a QR code (top right) that will permit purchasers and/or retail outlets to register their tires. Under the new proposals, registration will be mandatory for manufacturers.

Manufacturers will be “obliged to upload product information including energy labels and technical documentation (including test reports).

The documents acknowledge that, “manufacturers will face some extra costs for uploading the necessary information into the database.”

The documents say that the database should make it “easier and less costly for Market Surveillance Authorities (MSAs) to access the required documentation. In addition, retailers will have easy access to download labels and product information sheets including electronic versions for labelling of tires in web shops.”

The database is intended to provide data on the distribution of tires across the different performance classes. It is also expected to support market surveillance, which is essential for enforcement of the Regulation. Enforcement will also be aided by requiring Member States to inform the Commission of the penalties and enforcement mechanisms applicable to infringements of the Regulation.

It is not clear whether the database will be open to the public, or only to contributors.

New categories for ice and cold weather

The 2020 label has space to accommodate two measures of cold-weather performance.

On the left is three peaks mountain snowflake symbol (3PMSF), that has become familiar in the industry and represents performance in accordance with UNECE regulation 117.

The new symbol on the right represents ice grip measured according to a new standard, ISO 19447.

Stricter standards for wet grip, fuel economy

The label classes for all tires are being adjusted. The new set of grades includes A, B, C, D, E and F ratings for all classes of vehicle. The new B, C, D grades for both rolling resistance and wet grip for the C1 and C2-classes of vehicle (cars and light trucks) are equivalent to the old A, B and C ratings, respectively. The new E and F are the same as the old E and F. The G class has been eliminated.

For C3 vehicles (heavy trucks), the grades all move up by one letter.

The proposed legal instrument can be downloaded from here:

The annexes, with the new limits for rolling resistance, wet grip and noise as well as the new label layout and size can be downloaded from here:

The main web page, together with links for existing and future comments can be found here:

Note: the EC appears to have removed the page for comments a week earlier than it said. All the page references have changed - we have updated the links as far as we can, but it appears there is some kind of glitch on the website.

This report was first published in our weekly report on the China tire industry earlier this week.