# C_2009228EN.01008101.xml

| 22.9.2009 | EN | Official Journal of the European Union | C 228/81 |
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22.9.2009

EN

Official Journal of the European Union

C 228/81

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Opinion of the European Economic and Social Committee on the Proposal for a Directive of the European Parliament and of the Council on labelling of tyres with respect to fuel efficiency and other essential parameters

COM(2008) 779 final — 2008/0221 (COD)

2009/C 228/15

On 17 December 2008 the Council decided to consult the European Economic and Social Committee, under Article 95 of the Treaty establishing the European Community, on the

‘Proposal for a Directive of the European Parliament and of the Council on labelling of tyres with respect to fuel efficiency and other essential parameters’

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for preparing the Committee’s work on the subject, adopted its opinion on 12 March 2009. The rapporteur was Mr RANOCCHIARI.

At its 452nd plenary session, held on 24 and 25 March 2009 (meeting of 25 March), the European Economic and Social Committee adopted the following opinion by 130 votes nem. con., with five abstentions.

1.   Conclusions and recommendations

Conclusions and recommendations

| 1.1 | The Committee endorses the decision of the European Commission to follow up its proposal for a Regulation on the general safety of motor vehicles (in the process of being adopted) with a system to certify the values that will be established by that Regulation, in respect of three key tyre parameters: fuel efficiency, safety and external rolling noise. |
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1.1

The Committee endorses the decision of the European Commission to follow up its proposal for a Regulation on the general safety of motor vehicles (in the process of being adopted) with a system to certify the values that will be established by that Regulation, in respect of three key tyre parameters: fuel efficiency, safety and external rolling noise.

Regulation on the general safety of motor vehicles

| 1.2 | The Committee also welcomes the fact that the labelling system is intended to provide direct information to consumers, helping them to make a more informed choice when purchasing replacement tyres manufactured after the present proposal is adopted - tyres which account for 78 % of the European market. |
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1.2

The Committee also welcomes the fact that the labelling system is intended to provide direct information to consumers, helping them to make a more informed choice when purchasing replacement tyres manufactured after the present proposal is adopted - tyres which account for 78 % of the European market.

| 1.3 | With regard, however, to originally-installed tyres, i.e. tyres fitted by car manufacturers, the Committee considers the initiative superfluous, as existing legislation already requires manufacturers to provide the relevant data at the point of vehicle type-approval and subsequently with the vehicles’ technical promotional literature and user manuals. |
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1.3

With regard, however, to originally-installed tyres, i.e. tyres fitted by car manufacturers, the Committee considers the initiative superfluous, as existing legislation already requires manufacturers to provide the relevant data at the point of vehicle type-approval and subsequently with the vehicles’ technical promotional literature and user manuals.

| 1.4 | As regards the means proposed by the Commission to inform consumers, i.e. a sticker to be affixed to the tyre, the Committee suggests providing for an alternative means to cover the (not unlikely) eventuality that the sticker may be lost or damaged. |
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1.4

As regards the means proposed by the Commission to inform consumers, i.e. a sticker to be affixed to the tyre, the Committee suggests providing for an alternative means to cover the (not unlikely) eventuality that the sticker may be lost or damaged.

| 1.5 | Finally, the Committee hopes that, just as with the General safety of motor vehicles, a Regulation will be chosen as the appropriate form of legislation rather than a Directive, so as to ensure uniform time frames and control systems across all Member States. |
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1.5

Finally, the Committee hopes that, just as with the General safety of motor vehicles, a Regulation will be chosen as the appropriate form of legislation rather than a Directive, so as to ensure uniform time frames and control systems across all Member States.

General safety of motor vehicles

2.   Introduction

Introduction

| 2.1 | As we know, the Energy Efficiency Action Plan proposes an energy-saving of 20 % by 2020 by means of a series of measures, which by reducing energy intensity help reduce consumption and therefore environmental pollution. |
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2.1

As we know, the Energy Efficiency Action Plan proposes an energy-saving of 20 % by 2020 by means of a series of measures, which by reducing energy intensity help reduce consumption and therefore environmental pollution.

| 2.2 | In this context, there is a particular and constant focus on road transport, which is responsible for over 20 % of CO2 emissions. |
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2.2

In this context, there is a particular and constant focus on road transport, which is responsible for over 20 % of CO2 emissions.

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| 2.3 | In addition to the numerous measures already in force or in the process of being adopted with regard to vehicles, EU legislation is now seeking to address tyre performance. Representing the sole point of contact between the vehicle and the road, tyres are required to contribute primarily to occupant safety, but also to reducing fuel consumption. |
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2.3

In addition to the numerous measures already in force or in the process of being adopted with regard to vehicles, EU legislation is now seeking to address tyre performance. Representing the sole point of contact between the vehicle and the road, tyres are required to contribute primarily to occupant safety, but also to reducing fuel consumption.

| 2.4 | To this end, the proposal for a Regulation of the European Commission on the general safety of motor vehicles, currently under discussion at the European Parliament (1), seeks, inter alia, to establish new, more stringent parameters for the type-approval of tyres, in terms of fuel consumption, safety and noise. |
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2.4

To this end, the proposal for a Regulation of the European Commission on the general safety of motor vehicles, currently under discussion at the European Parliament (1), seeks, inter alia, to establish new, more stringent parameters for the type-approval of tyres, in terms of fuel consumption, safety and noise.

proposal for a Regulation of the European Commission on the general safety of motor vehicles

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inter alia

| 2.5 | In energy-saving terms, it should be pointed out that tyres can account for up to 20 % of a vehicle’s fuel consumption, as a result of rolling resistance (RR) - the loss of energy due to resistance to motion, caused in turn by the heating and deformation of the wheels while rolling. It should be added that RR, as well as tyre noise, are significantly influenced by the state of the road surface, which in certain cases can cancel out the technological advances of the tyres. |
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2.5

In energy-saving terms, it should be pointed out that tyres can account for up to 20 % of a vehicle’s fuel consumption, as a result of rolling resistance (RR) - the loss of energy due to resistance to motion, caused in turn by the heating and deformation of the wheels while rolling. It should be added that RR, as well as tyre noise, are significantly influenced by the state of the road surface, which in certain cases can cancel out the technological advances of the tyres.

3.   The European Commission’s proposal

The European Commission’s proposal

| 3.1 | The draft Directive aims to guarantee standardised information for users on fuel efficiency generated by reduced rolling resistance, as well as on wet grip and rolling noise, three of the parameters which are the subject of proposal for a Regulation COM(2008) 316. |
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3.1

The draft Directive aims to guarantee standardised information for users on fuel efficiency generated by reduced rolling resistance, as well as on wet grip and rolling noise, three of the parameters which are the subject of proposal for a Regulation COM(2008) 316.

| 3.2 | The Commission wants to enable consumers to know the future minimum requirements governing rolling resistance (RR) and, most importantly, to choose tyres with still lower RR, cutting fuel consumption. For passenger cars, for instance, a tyre set with a different RR can reduce fuel consumption by up to 10 % thanks to new technologies. |
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3.2

The Commission wants to enable consumers to know the future minimum requirements governing rolling resistance (RR) and, most importantly, to choose tyres with still lower RR, cutting fuel consumption. For passenger cars, for instance, a tyre set with a different RR can reduce fuel consumption by up to 10 % thanks to new technologies.

| 3.3 | This is particularly important for the replacement market which represents 78 % of the total. For tyres placed on new vehicles by manufacturers (22 % of the market), information on fuel consumption is a selling point and is included in the instruction manual. Consumers in the replacement market, however, do not have access to the information needed to compare the price difference of tyres with their impact on fuel consumption. |
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3.3

This is particularly important for the replacement market which represents 78 % of the total. For tyres placed on new vehicles by manufacturers (22 % of the market), information on fuel consumption is a selling point and is included in the instruction manual. Consumers in the replacement market, however, do not have access to the information needed to compare the price difference of tyres with their impact on fuel consumption.

| 3.4 | Since tyre performance is both interrelated and contradictory (RR compared to wet grip and wet grip compared to rolling noise), the information can indicate the best possible compromise between the three main parameters, allowing the consumer to make an informed choice. |
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3.4

Since tyre performance is both interrelated and contradictory (RR compared to wet grip and wet grip compared to rolling noise), the information can indicate the best possible compromise between the three main parameters, allowing the consumer to make an informed choice.

| 3.5 | The Commission proposal therefore plans for an ‘energy sticker’ to be placed on tyres, graded from A to G for RR and wet grip, along the lines of the already-established labelling for domestic appliances, with the addition of noise level indications, given in decibels. |
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3.5

The Commission proposal therefore plans for an ‘energy sticker’ to be placed on tyres, graded from A to G for RR and wet grip, along the lines of the already-established labelling for domestic appliances, with the addition of noise level indications, given in decibels.

| 3.6 | The proposal assigns responsibility to Member States for monitoring labelling provisions and deciding on sanctions in the event of infractions. |
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3.6

The proposal assigns responsibility to Member States for monitoring labelling provisions and deciding on sanctions in the event of infractions.

4.   General comments

General comments

4.1   The Committee supports the Commission’s initiative, which is intended partly to ensure a more sustainable consumption pattern, but also to provide more information, enabling the consumer to make a more informed choice when replacing tyres. This information relates not only to fuel consumption but also to other parameters such as wet grip and external rolling noise. Consumers will thus be able to assess whether the higher cost of a particular tyre would be outweighed by the benefits in terms of performance. A more informed consumer would help increase competition amongst manufacturers by encouraging them to upgrade their products.

4.2   In fact, the Commission initially intended only to require information on fuel consumption; the other two parameters were added in the light of the public consultation on the issue. Whilst endorsing the final decision, the Committee would fear, however, that this will make it more difficult to manage the data and carry out the relevant controls.

4.3   The Committee would have misgivings, however, as to the proposed means of presenting the information to consumers. If only stickers are used, the desired result may not always be achieved.

4.3.1   The purchaser does not normally see the replacement tyres before they are taken from the store room of the sales outlet and fitted to the vehicle. Moreover, in store rooms and sales outlets a label can come away and get lost, and sometimes be reapplied to a different tyre. More likely still is that labels could be lost in transit or storage, particularly in the case of silicone-coated tyres, which are less adhesive. Experience has shown that a considerable percentage of the manufacturers’ labels currently affixed to tyres are either lost or substantially damaged in the transit or handling of tyres, which – it should be pointed out – are not individually packaged, for obvious cost reasons (2) According to the industry’s European representative body, the ETRMA (European Tyre and Rubber Manufacturer Association), between 10 % and 15 % of labels are lost in the transit or handling of tyres.

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4.3.2   In the Committee’s view, an alternative solution should also be foreseen, where stickers are missing. Here, the vendor should be able to issue, along with the invoice, a label/document exactly replicating the data on the sticker, data which, in any case, would have been received from the manufacturer.

4.4   With regard, though, to tyres fitted to new vehicles, labelling would seem an unnecessary cost. Existing legislation already stipulates the way in which car manufacturers should inform purchasers about fuel consumption and CO2 emissions following type-approval of the vehicle. This is also the case with wet grip and external rolling noise, which are also regulated at vehicle type-approval, as the Commission itself acknowledges in the report accompanying the proposal.

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Moreover, it is in the manufacturer’s own interest always to use the most ‘high-tech’ tyres available in order to reduce CO2 emissions from the target level of 130 g/km to the potential level of 120 g/km, attainable through non-engine technology, including tyres.

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4.4.1   To that end, the dealer, who is often also a vendor of tyres, could be required to issue an additional document to the purchaser of a car detailing the legal parameters to which the car’s tyres conform, and also to propose an alternative, where possible. Such an initiative could also act as a flanking measure to the information and awareness campaigns that the Member States will be required to launch on this issue.

4.5   The Committee is also aware of the request made by sectors in the industry (3) for the proposal to be changed from a Directive to a Regulation. It endorses the reasons advanced, i.e. that a Regulation would ensure uniform implementation time-frames and control standards across the Member States, as is the case with the aforementioned General safety of motor vehicles Regulation, the precursor to the present proposal.

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General safety of motor vehicles

4.5.1   The Committee therefore hopes that agreement can be reached during discussions between the Commission, European Parliament and Council, as on previous occasions with such sensitive issues as safety and the environment.

4.5.2   Indeed, the Committee considers it crucial to provide Member States with clear harmonised rules to check rigorously that tyres meet the specified requirements. Such checks are particularly important in a market where a significant share of the products comes from outside the EU.

5.   Specific comments

Specific comments

| 5.1 | The Committee welcomes the fact that the Commission has exempted retreaded and off-road professional tyres from the proposed legislation, as advised by the Committee itself in its aforementioned opinion on the General safety of motor vehicles, while affirming of course that the envisaged safety requirements would still have to be observed. |
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5.1

The Committee welcomes the fact that the Commission has exempted retreaded and off-road professional tyres from the proposed legislation, as advised by the Committee itself in its aforementioned opinion on the General safety of motor vehicles, while affirming of course that the envisaged safety requirements would still have to be observed.

General safety of motor vehicles

| 5.2 | In line with that opinion, the Committee recommends, finally, that:






  a) | tyres manufactured before this legislation enters into force be exempted. On average, there are some 80 million tyres circulating at any one time in the distribution chain of the European market. Applying stickers to all of these distributed tyres would not be feasible; and stresses that |
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5.2

In line with that opinion, the Committee recommends, finally, that:

a)

tyres manufactured before this legislation enters into force be exempted. On average, there are some 80 million tyres circulating at any one time in the distribution chain of the European market. Applying stickers to all of these distributed tyres would not be feasible; and stresses that

| b) | the industry needs at least 18 months’ lead time to implement the adopted measures. |
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b)

the industry needs at least 18 months’ lead time to implement the adopted measures.

Brussels, 25 March 2009.

The President of the European Economic and Social Committee

Mario SEPI

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(1)  COM(2008) 316, on which the Committee has already issued an opinion, at the plenary session of 14 January 2009 (ref. CESE 1741/2008).

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(2)  According to the industry’s European representative body, the ETRMA (European Tyre and Rubber Manufacturer Association), between 10 % and 15 % of labels are lost in the transit or handling of tyres.

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(3)  ETRMA: European Tyre and Rubber Manufacturer Association.

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