EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 13.11.2008 
SEC(2008) 2860 
  
COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the 
 
Proposal for a 
 
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
  
on labelling of tyres with respect to fuel efficiency and other e ssential parameters  
  
IMPACT ASSESSMENT  
 
{COM(2008)779} 
{SEC(2008)2861} 
 
EN 2   EN TABLE OF CONTENTS 
1. Procedural Issues and Consulta tion of Interested Parties ..................................... 5 
1.1. Organisation and Timing ............................................................................................. 5 
1.2. Consultation and Expertise .......................................................................................... 5 
2. Problem Definition..................................................................................................... 7 
2.1. Fuel-efficient Tyres: the Potential................................................................................ 7 
2.2. Possible Trade-Offs...................................................................................................... 9  
2.3. Underlying Drivers of the Problem.............................................................................. 9 2.4. Impact on Stakeholders.............................................................................................. 11 2.5. Interactions with Type -Approval Legislation ............................................................ 12 
2.6. Evolution of the Problem without EU Action............................................................ 12 2.7. Legal Basis for EU Action ......................................................................................... 12 
3. Objectives.................................................................................................................. 13 
3.1. General, Specific and Operational Objectives ........................................................... 13 
3.2. Consistency with Other EU Policies.......................................................................... 13 
4. Policy Options........................................................................................................... 14 
4.1. Identified Policy Options ........................................................................................... 14 
4.2. Options Discarded at  an Early Stage.......................................................................... 15 
5. Analysis of Impacts .................................................................................................. 16 
5.1. Option 1: No EU Action........................................................................................... 16 
5.1.1. Drivers of RR Improvement....................................................................................... 16 
5.1.1.1. Type-Approval Legislation governing Vehicles........................................................ 17 5.1.1.2. Type-Approval Legislation governing Tyres............................................................. 17 5.1.1.3. Market Demand......................................................................................................... . 17 
5.1.2. Expected Market Transformation – Baseline Scenario.............................................. 18 
5.2. Option 2: Labelling Scheme for RR wi th Minimum Requirements on Wet Grip 
and External Rolling Noise for C1 Tyres............................................................... 19 
5.2.1. Minimum Requirements Set for Wet Gr ip and External Rolling Noise .................... 19 
5.2.2. Factors Determining the Design of a Banding Scheme ............................................. 20 5.2.2.1. State of the Art ...................................................................................................... ..... 20 
5.2.2.2. Production Costs ...................................................................................................... .. 20 
5.2.2.3. Cost-Effectiveness of Fuel-E fficient Tyres – Case Study.......................................... 22 
5.2.2.4. Precision of Testing Methods .................................................................................... 22 
5.2.2.5. Relative versus Absolute Labelling ........................................................................... 23 
5.2.3. Proposal for a Grading Scheme.................................................................................. 23 
 
EN 3   EN 5.2.4. Expected Market Transformation and End-User Benefits......................................... 25 
5.3. Option 3: Dual-Labelling Scheme for C1 Tyres regarding RR and Wet Grip .. 27 
5.3.1. Potential for Wet Grip Improveme nt above Minimum Requirements....................... 27 
5.3.2. Assessment of Safety Gains....................................................................................... 28 5.3.3. Factors Determining the Design of  a Banding Scheme for Wet Grip........................ 29 
5.3.3.1. State of the Art ...................................................................................................... ..... 29 
5.3.3.2. Production Costs of Optimised Wet Grip and RR ..................................................... 30 5.3.3.3. Cost-Effectiveness – Case Study ............................................................................... 30 5.3.4. Grading Scheme for Wet Grip ................................................................................... 30 5.3.5. Expected Market Transformation regard ing Fuel Efficient Tyres and End-User 
Benefits ...................................................................................................................... 3 1 
5.4. Option 4: Multi-Criteria Labelling Sc heme for C1 Tyres regarding RR and Wet 
Grip Extended to External Rolling Noise .............................................................. 32 
5.4.1. Potential for External Rolling Noise Im provement above Minimum Requirements. 32 
5.4.2. Effectiveness of a Low-Noise Mark in Promoting Lower External rolling noise ..... 34 
5.5. Option 5: Extension of the Labelling Scheme Developed for C1 Tyres (Option 2, 
3 or 4) to C2 and C3 Tyres ...................................................................................... 36 
5.5.1. Wet Grip and External Rolling Noise Minimum Requirements................................ 36 
5.5.2. Design of a Banding Scheme for C2 and C3 Tyres and Expected Market 
Transformation........................................................................................................... 36 
5.5.3. Inclusion of Wet Grip in a Labell ing Scheme for C2 and C3 Tyres.......................... 39 
5.5.4. Inclusion of External rolling noise in a Labelling Scheme for C2 and C3 Tyres ...... 39 
5.6. Option 6: Economic Instruments and Public Procurement................................. 40 
6. Comparing the Options ........................................................................................... 42 
6.1. Qualitative Assessment .............................................................................................. 42 
6.2. Aggregated Cost-and-Benefit Analysis...................................................................... 45 6.2.1. C1 Tyres – Options 2, 3 and 4 ................................................................................... 45 6.2.1.1. Fuel and CO
2 Aggregated Net Savings...................................................................... 45 
6.2.1.2. Administrative Costs.................................................................................................. 48 
6.2.1.3. Costs of Testing ...................................................................................................... ... 48 
6.2.1.4. Costs of Display of the Labelling Scheme................................................................. 50 6.2.1.5. Potential Impact on Import/Export............................................................................. 51 6.2.2. C2 and C3 Tyres – Option 5 ...................................................................................... 52 6.2.2.1. Fuel and CO
2 Net Savings ......................................................................................... 52 
6.2.2.2. Further Costs ......................................................................................................... ..... 53 
6.2.3. Summary ................................................................................................................. ... 53 
 
EN 4   EN 7. Monitoring and Evaluation..................................................................................... 58 
 
EN 5   EN COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the 
 
PROPOSAL FOR A DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF 
THE COUNCIL 
on labelling of tyres with respect to fuel efficiency and other e ssential parameters  
 
FULL IMPACT ASSESSMENT 
Lead DG: TREN 
Other involved services : ECFIN, ENTR, ENV, LS, RTD, SANCO and SG (also invited: 
EMPL, MARKT, INFSO, JRC, RTD, TAXUD and TRADE) 
Agenda planning or WP reference : 2008/TREN/079* 
1. P ROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
1.1. Organisation and Timing 
In its “Energy Efficiency Action Plan”, th e European Commission committed to consider 
drawing up a proposal for energy labelling of  tyres by 2008. The Annual Policy Strategy 
(COM(2008) 72) announced an initiative for 2009, but the urgent need to act on energy 
savings led to acceleration of the process with th e aim of tabling a proposal before the end of 
the legislature, as announced in the Co mmunication on Greening Transport (COM(2008) 
433). 
The impact assessment (IA) work was launched in January 2008 supported by an Inter-
Service Steering group (ISG) in cluding SG, LS, ENTR, ENV, ECFIN, SANCO, RTD. The 
agreement of the ISG was forthcoming during a ll critical steps of th e impact assessment, 
namely: design of the IA and policy options at  the 7 March meeting, dr afting and publication 
of the stakeholders’ consulta tion working document, results of the 26 May workshop and 
feedback on the prelimin ary draft IA on 12 June. 
1.2. Consultation and Expertise 
An external study was contracted from Decemb er 2007 to July 2008 with the European Policy 
Evaluation Consortium (bringing together the consultancy firms GHK and TNO), further 
referred to as [EPEC 2008], to give input to th is IA. The external study looked at the technical 
background supporting the design of a labelli ng scheme, including market structure and 
cost/benefit analysis. 
 
EN 6   EN The opinion of stakeholders was gathered consistently throughout the process through 
bilateral meetings and various  consultations, including a dedi cated stakeholder workshop, and 
thus the Commission’s minimum standards on public  consultation can be considered to be 
met. 
• First reactions were gathered during ENTR’s1 public consultation on the Advanced Safety 
of Motor Vehicles from August to October 2007, which included a proposal for a grading 
of tyre fuel efficiency2. This provision was finally withdr awn from ENTR’s proposal so as 
to allow for a more in-depth analysis within this impact assessment, but feedback on this 
grading proposal has been taken into account. 
• An expert group meeting with representatives of the tyre industry took place on 21 April 
2008 in order to clarify technical issues (see minutes in Annex 1). 
• A stakeholder workshop was held on 26 May 2008 with Member State representatives, 
NGOs, consumer and business organisations, th e tyre industry and car producers (see 
minutes in Annex 2). The working documen t containing questions on various policy 
choices to be addressed at the workshop and stakeholders’ replies were published on the 
Europa website3. 
Stakeholder consultation was instrumental in  defining policy options and the design of a 
labelling scheme. All respondents throughout the consultation process in general 
supported the introduction of a labelling scheme  but with reservations on some technical 
issues: 
• The first public consultation by ENTR highlight ed the need not to downgrade tyre safety 
performance characteristics when designing a labelling scheme to support fuel-efficient 
tyres (see Box 1). The tyre industry developed the concept of a “Tyre Performance 
Integrated Approach” calling for simultaneous consideration of all relevant parameters. 
This concern was taken into account in two wa ys: (1) extensive research, as part of the 
external study, on the technica l relation and possible trade-o ffs between tyre parameters, 
and (2) consideration of additional policy op tions which would include, together with 
rolling resistance, a grading of  wet grip (relevant for safety) and possibly external rolling 
noise. 
• Of the seven respondents taking a position on the specific fuel efficiency grading of tyres 
presented by ENTR in August-October 2007 (E NTR initially proposed four bands from A 
to D, “A” being the most energy-efficient), six asked for band A to be more demanding 
and for the banding scheme to be the same as the one in place for household appliances (labelling which grades products on an “A to  G” scale, see sample in Annex 4). The 
rationale is that the actual range of tyre pe rformance allows for seven bands and that the 
“A to G” scale is alrea dy a labelling scheme well known by consumers and makes for 
better differentiation between  products (see Section 5.2.2). 
• Some stakeholders request ed the inclusion of external rol ling noise in the labelling scheme. 
External rolling noise, which was not originally  included within the scope of the IA, was 
consequently addressed in the fourth policy option: multi-criteria grading scheme. 
                                                
 
1 Directorate-General for Enterprise and Industry of the European Commission. 
2 See http://ec.europa.eu/enterprise/automotive/pagesbackground/safety/consultation/index.htm. 
3 See http://ec.europa.eu/energy/demand/legislation/under_discussion_en.htm . 
 
EN 7   EN • The International Road Transport Union (IRU) representing the road transport industry 
was in favour of including C2 and C3 tyres in  the labelling scheme. This possibility was 
addressed in one of the policy options. 
Box 1: Fuel-efficient tyres  refer to tyres with lower rolling resistance hence lower fuel 
consumption. They are also referred to as eco-tyres, green tyres, or low-rolling-resistance 
tyres (LRRTs).  Currently there is no common defi nition of such tyres, though the 
designation LRRTs is sometimes used for all tyre s made with silica (50% of the market), but 
this cannot be considered as a valid definition as there is still a significant range of RR 
performance among those tyres. In this study, th e terms fuel-efficient tyres or LRRTs will be 
used in the same way, and will refer to tyres w ith rolling resistance lower than the average 
level on the market. 
2. P ROBLEM DEFINITION  
2.1. Fuel-efficient Tyres: the Potential 
Against the backdrop of current concern to redu ce the environmental foot print of transport, 
the Commission is looking into vehicle compone nts as formulated in the new integrated 
strategy to reduce CO 2 emissions from passenger cars a nd light-duty vehicles (COM(2007) 
19). 
Tyres are an important component of cars as they account for 20% to 30% of fuel 
consumption  depending on vehicle speed  (over 70km/h, aerodynamic drag exceeds rolling 
resistance as a parameter influencing consumpti on). This share of fuel is used to overcome 
rolling resistance  (RR) caused mainly by what is calle d “hysteretic loss”  (loss of energy 
through the heating and deformation of the wh eels while rolling). There has been constant 
improvement on rolling resistance over the past d ecades but at a low rate, with a 5% decrease 
in RR per decade according to OECD/IEA 20054 (after accounting for performance 
improvements). 
New technologies have made it possible to significantly lower the RR of tyres without 
downgrading other tyre performan ce characteristics such as safe ty or handling, so that today 
the RR of tyres put on the market (usually measured with a coefficient expressed in kg/t or 
‰) can vary by up to 100%: between 7kg/t and 14kg/t for passenger cars, according to the 
ETRMA5 state of the market in 2004. Studies a nd tyre manufacturers demonstrate that a 1kg/t 
decrease in rolling resistance of passenger car tyres leads to about a 1.5% fuel saving  
independent of the drive cycle6, which means a difference in total vehicle fuel consumption 
between the best- and the worst-performing tyre  of up to 10%. This is equivalent to a 
reduction of 15 to 20 g/km CO 2 emission for a medium-size car depending on whether it is a 
diesel or petrol car. For truck tyres , a 1kg/t variation in RR means on average a 5% fuel 
saving . 
                                                 
4 European Conference of Ministers of Transport, Making Cars more Fuel -Efficient –  Technology for 
Real Improvements on the Road, OECD/IEA, 2005, p.44. 
5 ETRMA is the European Tyre an d Rubber Manufacturer Associatio n representing the tyre industry. 
6 Drive cycle refers to urban, extra-urban or moto rway driving. RRC remains almost constant up to 
120km/h. See Reducing Tire Rolling Resistance to  Save Fuel and Lower Emissions , Jerome Barrand, 
Jason Bokar, Michelin, April 2008, available on  http://www.sae.org/technical/papers/2008-01-0154. 
 
EN 8   EN Fuel efficient tyres  (see Box 1) are cost-effective7. The increased production costs, i.e. the 
purchase price paid by consumers, will be compensated by fuel savings made in the in-use period with a payback period of less than eigh t months (including tax) for the most fuel-
efficient tyres (see Tables 9 and 11).  
They have also been identified as a relatively low-cost way of reducing CO
2 emissions, as 
illustrated by Figure 1 . 
Figure 1: Road Transport CO 2 Abatement Costs by Policy Options 
 
 
Source: Joint Transpor t Research Centre 20078 
                                                 
7 Life cycle analysis shows in addition that no adve rse impacts on the environment are to be expected 
from the increased use of fuel efficient tyres – see, for example, Review and Analysis of the Reduction 
Potential and Costs of Technological and Other Measures to Reduce CO 2 Emissions from Passenger 
Cars , TNO, 2006, p. 119. 
8 http://internationaltransportforum.org/docs/SPnordwijk07.pdf. 
 
EN 9   EN Studies9 differ on the exact CO 2 abatement costs due to the use of fuel efficient tyres, some 
estimating it to be negative, others to be at €73 t/CO 2eq depending on the fuel price and 
reduction assumptions in fuel savings due to rolli ng resistance, but it is very clear, as shown 
in Figure 1 above, that CO 2 abatements costs due to the incr eased use of fuel efficient tyres 
are relatively low compared to other policy options to reduce greenhouse gas emissions. One 
could also point out that the graph above is based on conserva tive estimates (€50 per oil 
barrel); with the recent increases in the fuel price, CO 2 abatement costs due to market take-up 
of fuel efficient tyres were  calculated to be indeed negative (see Section 6.2.1.1).  
It is clear from all the above that the prom otion of market transformation towards fuel 
efficient tyres may be in the inte rest of both consumers and society. 
2.2. Possible Trade-Offs 
Preliminary results of the IA and the opinions  expressed during the stakeholder consultation 
have shown that lowering rolling resistance may have  an adverse impact on other tyre 
parameters , the most important of which is wet grip  (see Box 2), but also  tread wear (life 
duration of tyres) and external rolling noise. Numerous surveys show indeed that while it is 
possible to improve different tyre attributes at the same time but often at higher production 
costs, it is also possible to optimise at no additional cost one parameter within a given 
technology but at the expense of another. 
The potential trade-off between tyre perfor mance characteristics  has therefore been 
included in the analysis . 
Box 2:  Wet grip  refers to the safety performance of ty res; it reflects the cap acity of a tyre to 
brake on a wet road. There are other parameters which are relevant for safety (namely road 
holding ability, directional control, deceleratio n ability on wet and dry surfaces at higher 
speed and aquaplaning behaviou r) but existing testing met hods make it possible only to 
measure wet grip. Since the expert group meeti ng concluded on 21 April that the correlation 
between wet grip and the other safety parameters  is good (see minutes in Annex 1), the impact 
assessment will consider only wet grip. 
2.3. Underlying Drivers of the Problem 
The development of fuel efficien t tyre tends to be hampered by a market failure arising 
from the lack of information for end-users  on tyre fuel efficiency (including road transport 
companies, according to interviews with the In ternational Road Transport Union). This is 
especially true for the replacement market, constituting 78% of market share (see Box 3). 
Box 3: The original equipment  (OE) market refers to the market of tyres originally fitted on 
new vehicles before sale. Those OE tyres are developed and selected by car producers in close 
cooperation with tyre supp liers in the design phase of a give n vehicle. It accounts for 22% of 
the entire tyre market (see details in Annex 5). The replacement market  in contrast refers to 
tyres designed to replace those originally fitted on new vehicles once they are worn out, 
usually after 40 000 km in Europe. It constitute s 78% of market share. Legislation makes the 
replacement of tyres mandatory once the tread wear indicator has reached 1.6 mm10. 
                                                 
9 See Cost-Effectiveness of Greenhouse Gases Em ission Reductions in Various Sectors, INFRAS, 
November 2006, p. 111 or [OECD/IEA 2005] and [TNO 2006]. 
10 UNECE Regulation No 30: 
http://eur-lex.europa.eu/LexUriServ/LexUriSe rv.do?uri=OJ:L:2008:201:0070:0096:EN:PDF . 
 
EN 10   EN Figure 2 shows the distribution of RR for all tyre classes (see Box 4). 
Box 4:  Tyre classes  reflect the different market segmen t of tyres related to the type of 
vehicles for which they are designed. They ar e defined in the proposal  for a Regulation on the 
general safety of motor ve hicles (COM(2008) 316) as C1, C2 and C3 tyres  representing 
respectively tyres fitted on passenger cars (87% of total tyre sales), light-duty vehicles (8% of 
tyre sales) and heavy-duty vehicles (5% of ty re sales). Each class may then be broken down 
into winter and summer tyres, respecti vely 28% and 72% of  the EU market. 
Figure 2: Market Distribution of RR by Tyre Classes in 2004 
RR State of the Art Truck, C-type & Passenger
0%5%10%15%20%25%30%35%40%45%
3456789 1 0 1 1 1 2 1 3 1 4 1 5 1 6 1 7
RRCPercentageTruck_Summer
Truck_Winter
C-Type Summer
C-Type Winter
Pass_Summer
Pass_Winter
 
Source: ETRMA 
The graph clearly illustrates the existence of a market failure. For C1 summer tyres, for 
example, (“Pass_Summer” curve on the graph), more than 80% of tyres sold on the market 
(OE and replacement markets included) have a rolling resistance above 10.5kg/t, and only 2% under 9kg/t, even though the latter tyres are cost -effective (around 3% fuel savings compared 
to average – see Section 5.2.2). 
The tyre market has traditionally been a concentrated one. Recent trends on the tyre market 
(i.e. increasing imports
11, demand from specialised tyre re tailers for exclusive brands, and 
new brand strategies by the tyre industry) have greatly strengthened competition, so that today 
consumers are confronted by an increasing number of tyre brands. In the Netherlands and the 
UK, for example, consumers may be faced re spectively by as many as 140 and 250 different 
brands. This increase in competition ob liges producers to work more on product 
differentiation and improving product quality. Th e lack of a harmonised labelling scheme, 
however, does not enable tyre  producers to communicate objectively with consumers on the 
quality of their products. 
                                                 
11 Imports from third countries (China, India and South Korea) for example have increased by 300% over 
the last five years. 
 
EN 11   EN Up to now the information available to consumers/ end-users regarding the fuel efficiency of 
tyres is provided by manufacturers only. Various claims have indeed been made as regards 
tyre impact on fuel consumption, but the in formation provided does  not enable fair 
comparison between tyres and is sometimes difficult to understand12. Consumers/end-users 
cannot reliably compare tyre purchase costs with prospective fuel savings in the in-use phase 
of the tyres. 
Finally, the distribution market has also considerably changed over the past years with the 
development of new distribution chains, such  as hypermarkets and specialised branches 
(Figure 3) which would increase th e visibility and effectiveness of a labelling scheme if it 
were introduced. 
Figure 3: Share of Replacement Market by Point of Sales 
0%10%20%30%40%50%60%70%80%90%100%Total (mil)     31.4       25.4       50.9        16.5        28.1       6.0       15.5         5.1         4.1        3.6  
Other
Crash Repair
Hypermarket
Petrol Station
Vehicle Manufacturer 
Networks
Tyre Specialist
Garage
Autocentre
Fast Fit
 
Source: Datamonitor, quoted in [EPEC 2008] 
2.4. Impact on Stakeholders 
This market failure impacts: 
• End-users (consumers, companies or local authoritie s owning small or larger fleets such 
as leasing companies, and road transport operators) who do not benefit from the net 
savings that they could obtain  with fuel efficient tyres. 
• Tyre producers  who have more difficulties in obtai ning a return on thei r investments in 
R&D (R&D is already instrume ntal in obtaining market sh are on the OE market as car 
producers have the know-how on tyres, but is less rewarding on the replacement market). 
• Society  as a whole, with potential social bene fits exceeding consumer benefits due to 
transport externalities (reduced greenhouse gase s (GHG) emissions, heal th effect from air 
pollution caused by vehicles’ pollutant emissi ons (NOx, particulat e matter, etc.) and 
increased security of supply (fro m increased fuel efficiency). 
                                                 
12 See in-depth description of the tyre market in VTI, Consumer Label for Tyres in Europe, U. Sandberg, 
March 2008. 
 
EN 12   EN A labelling scheme could also improve competition between tyre producers while providing a 
level playing field for all. Producers may both have incentives to provide better-performing 
tyres on the market and benefit from reduced entry barriers as  brand reputation may loose its 
importance compared to objective tyre performance characteristics. 
2.5. Interactions with Type-Approval Legislation 
Type-approval legislation refers to the framew ork setting mandatory quality standards in the 
automotive sector. It includes the proposal for a Regulation on the general safety of motor 
vehicles (COM(2008) 316) which defines new minimum requirements for tyres including wet 
grip, external rolling noise and rolling resi stance (see Annex 6). This proposal partly 
addresses the market failure described above : new requirements on we t grip will greatly 
improve road safety since they will ban 30% of  the worst-performing tyre from the market. 
New minimum requirements on ex ternal rolling noise will reduce traffic noise, and the 
minimum requirements on RR will progressively improve tyre fuel efficiency. 
However, given the urgent need to improve tr ansport energy intensity, momentum exists for 
going beyond these minimum requirements. It is pr oposed to follow an integrated approach in 
order to improve tyre fuel efficiency. While type-approval legislati on addresses the supply  
side, this impact assessment considers additional measures addressing the demand  side. The 
objective is to support dynamic improvement of tyre fuel efficiency above the minimum 
requirements  through the operation of market forces . As for energy-using products, 
combined action through eco-design (the set ting of minimum require ments) and labelling 
have proven to be the most effective way of supporting fuel efficiency  and innovation. This 
approach was also favoured for passenger cars,  with type-approval legislation defining 
emission requirements on the one hand and th e Car Labelling Directive on the other: 
minimum requirements ban the worst-perfor ming product while energy labelling gives 
incentives and rewards to producers to put  better-performing products on the market. 
Another interaction is related to  the test procedures. It is pr oposed to follow the same test 
procedures as those defined in the type-approv al legislation and its implementing measures. 
2.6. Evolution of the Problem without EU Action 
Improvements in RR (relevant for tyre fuel effi ciency) have been and will be further driven 
first by the OE market, due to the regulat ory pressure put on producers to reduce car 
emissions, and second by the minimum require ments governing RR which are laid down in 
the proposal for a Regulation on the general safety of motor vehicles (COM(2008) 316) 
described above. Demand from road transport pr ofessionals interested in reducing their costs 
per km must also have driven the market towa rds lower RR, but to a lesser extent (see Section 
5.1 for detailed explanation). 
Estimation of tyre market distribution by RR in 2020 without EU action shows that the 
market will go towards lower RR but still not at an optimum level (see Section 5.1.2). For C1 
summer tyres, for example, tyres below 7.5kg/t w ill make up only 1% of the market and only 
12% will be below 8.5kg/t,  even though the technology exis ts and is cost-effective. 
No measures have been put in place on the re placement market to respond to the identified 
market failure, even though the periodic tyre replacement during vehicle lifetime provides the 
opportunity to gradually fit road transport fleets with energy-efficient tyres. 
2.7. Legal Basis for EU Action 
The legal basis for a legislative proposal is Arti cle 95 of the Treaty. In order to achieve a level 
playing field for all and to avoid fragmentation of the internal market, it is proposed to set a 
harmonised labelling scheme European-wide. 
 
EN 13   EN 3. O BJECTIVES  
3.1. General, Specific and Operational Objectives 
The above problem definition and its drivers l ead to the setting of the following objectives. 
• General Policy Objectives 
– Reduce fuel consumption and related CO 2 and pollutants emissions due to road 
transport in the framework of sustainabl e mobility and the fight against climate 
change.  
– Promote fuel efficiency, henc e contributing to security of supply as part of the 
Community objective of saving 20% of  the EU’s energy consumption by 2020.  
– Promote competitiveness of the tyre industry through innovation within the 
internal market.  
• Specific Objectives 
– Promote market take-up of  fuel-efficient tyres. 
– Drive investments in R&D towards environmentally friendly tyres. 
– Maintain other tyre parameters at least at  the same level (especially wet grip and 
external rolling noise). 
• Operational Objective 
– Create a level playing field for the provisi on of information on the performance of 
tyres (C1 and possibly C2 and C3 vehicles) (i.e. a labelling scheme) with targeted 
and easy-to-understand information for c onsumers, companies and retailers. 
– This may include performance grading that  would be made available to users via 
different media (e.g. electronic, catalogu es, label) allowing fair and objective 
comparison between tyres13. 
3.2. Consistency with Other EU Policies 
Increased market take-up of fuel-efficient ty res, through the introduction of an energy 
labelling scheme, will contribute to achieving the 20% energy savings potential by 2020 
identified in the Energy Efficiency Action Plan (COM(2006) 545) – subsequently endorsed 
by the Energy Council and the European Council as well as the European Parliament14. It is 
also in line with the input of the CARS 21 high-level group (COM(2007) 22) and the new 
integrated strategy to reduce CO 2 emissions from passenger cars  (COM(2007) 19, see Box 5). 
                                                 
13 The measured RR coefficient is by definition independent of vehicle load. This allows comparison 
across all tyres irrespective of vehicle size. 
14 TTE, (Energy) Council on 23 Nove mber 2006, 15210/06; Brussels European Council 8/9 March 2007, 
Presidency Conclusions, 7224/07; European Parliament resolution of 24 October 2007 on the 
Community Strategy to reduce C0 2 emissions from passenger cars and light commercial vehicles 
(2007/2119 (INI)), point 32. 
 
EN 14   EN Box 5: The revised Co mmission strategy on CO 2 from passenger cars and light commercial 
vehicles is based on an integrated  approach to reach the 120g/km CO 2 target by 2012. It 
includes a target of 130g/km CO 2 achieved by means of a legi slative instrument on car 
emissions as measured at type approval (COM (2007) 856) and a further 10g/km or equivalent 
achieved by means of a closed list of additi onal measures (COM(2007) 19). These additional 
measures include the setting of minimum requi rements on tyre rolling resistance but not a 
labelling scheme. The benefits of the ma rket take-up of LRRTs beyond these legal 
requirements discussed in this impact assessment will therefore add up  to the 10g/km CO 2 
target. 
Promotion of market transformation towards fuel  efficient tyres complies with the Lisbon and 
renewed Sustainable Development Strategy15 as it will encourag e investment in R&D, 
provide for a level playing fiel d for all and reduce the carbon footprint of road transport, 
thereby contributing to the policy goal towards sustainable mobility as expressed in the Communication on Greening Tr ansport (COM(2008) 433). 
One of the key objectives defined in the Community Lisbon Programme for 2008-2010 
(COM(2007) 804) is the promotion of an “industr ial policy geared towards more sustainable 
consumption and production”, as further elaborated on in th e Action Plan on Sustainable 
Consumption and Production and Sustaina ble Industrial Policy (COM(2008) 397/3). 
Tyre labelling will also play an important pa rt in the objective of “empowering consumers” 
formulated in the EU Consumer Policy St rategy 2007-2013 (COM(2007) 99) since it will 
enable consumers to make an informed a nd better choice when buying replacement tyres. It 
will be reinforced by the revised car labelling scheme  (Directive 1999/94/EC) which will 
lay down a harmonised label for pa ssenger cars across Europe. It is  proposed to use the same 
energy class design (grading on an "A  to G" scale) for both cars and tyres in order to enhance 
recognition of the label. 
Energy savings due to fuel efficient tyres w ould also be increased by the proposal for a 
Regulation on the general safety of motor vehi cles (COM(2008) 316) which will make a tyre 
pressure monitoring system mandatory on passenger cars. 
4. P
OLICY OPTIONS  
4.1. Identified Policy Options 
Several policy options have been identified for promoting market transformation towards 
more fuel-efficient tyres. 
• Option 1: No EU action. This is the baseline sc enario, including the adoption of minimum 
requirements governing RR as proposed in CO M(2008) 316 and existing incentives for car 
producers to fit their vehicles with fuel effi cient tyres in order to  reduce type-approved 
(TA) emissions measured levels. 
• Option 2: Single-criterion labelling scheme for passe nger car tyres (C1 tyres, see Box 3) 
regarding fuel efficiency (RR), with minimum requirements on other parameters  (wet grip 
and external rolling noise), but  no labelling of truck and van ty res (C2 tyres) and for trucks 
and buses (C3 tyres). 
• Option 3:  Dual-labelling scheme for C1 tyres regard ing fuel efficiency (RR) and wet grip, 
with minimum requirements on external rolling noi se, but no labelling for C2 and C3 tyres. 
                                                 
15 OJ L 242, 10.9.2002, and Council Document 10917/06 of 26.6.2006. 
 
EN 15   EN • Option 4:  Multi-criteria labelling scheme for C1 ty res regarding fuel efficiency (RR) and 
wet grip extended to external rolling noise , but no labelling for C2 and C3 tyres. 
• Option 5:  Extension of the labelling scheme devel oped for C1 tyres (Option 2, 3 or 4) to 
C2 and C3 tyres. 
• Option 6: Economic instruments and public procurement. This option does not necessarily 
substitute Options 2 to 5 but could complement them. 
In Options 2 to 5, the width of the bands and the design of the grading scheme will greatly 
influence the impact of tyre labelling; they will therefore be assessed in detail. 
4.2. Options Discarded at an Early Stage 
Five options have been dis carded at an early stage: 
• Self regulation/voluntary agreements : Although there is a rather  high concentration of 
sales among EU producers, voluntary agreements  appear difficult in practice because of 
recent changes in the tyre market resulting in an increasingly scattere d market: tyre imports 
now account for 30% of the mark et, with a 300% grow th in imports from Asian countries 
(China, India and South Korea) over the past five years. Cons equently, there appear to be 
too many actors on the market for a voluntary ag reement to be effective and to avoid free 
riders. The tyre industry itself did not table a voluntary agreement, but asked instead for a 
harmonised labelling scheme. In addition, cons umer organisations are sceptical about the 
value of such voluntary agreements a nd favour a harmonised labelling scheme16. 
• Use existing regulatory initiatives:  a possibility could have b een to include tyres as an 
implementing measure of a revised Energy Labe lling Directive (Direc tive 92/75/EC on the 
energy labelling of household appliances) if extended to “energy-related products”. 
However, considering the complexity and the number of other relevant Community 
measures already affecting them, vehicles and their components will not be covered in the 
reviewed Directive. 
• Implement a CO 2 bonus scheme for car producers usin g fuel efficient tyres on the OE 
market:  some stakeholders called for a bonus sc heme which could reward car producers 
(for instance with a rebate on the CO 2 emissions threshold) for using energy-efficient tyres 
or tyres below the worst one used for “type-a pproval” emission measurements (mandatory 
measurement of emissions to check whether a car complies with the EU standards defined 
in the “type-approval” legislation). A bonus sche me would run the risk of interfering with 
the ongoing co-decision process on the proposed Regulation on CO 2 from cars, or with the 
agreed shares of emission reductions under the in tegrated approach (see Box 5 above). It is 
therefore not pursued further at this stage. 
• Inclusion of retreaded tyres: Retreaded tyres are truck tyres whose life is extended by 
replacing the worn-out tread. It accounts for approximately 50% of the C3 market. The 
state of the knowledge and data on this market is too low to design concrete policy actions. 
Though the majority of stakeholders agreed th at the inclusion of retreaded tyres in a 
labelling scheme would be desira ble, in practice it may be im possible to implement. This is 
mainly due to the interaction between tr ead and carcasses, which would require each 
individual retreaded tyre to be tested and would therefore involve too high testing costs 
(see minutes of the workshop, Annex 2, answer to question 6). 
                                                 
16 See i.a. ANEC/BEUC contribution to the revision of the Energy-Using Product s Directive (Directive 
2005/32/EC), Consumer interests in Eco-design (of energy-using products),  Sylvia Maurer, 2008. 
 
EN 16   EN Regarding the design of the labelling scheme, some possibilities were also rejected at an early 
stage: 
• Endorsement label  or “label of excellence” such as  the European eco-label (the green 
flower) declaring that a specific product complie s with high-quality criteria: Experience 
from voluntary endorsement labels for tyres such as the Nordic Swan in the Nordic 
countries, the Blue Angel in Germany or th e Ecologo in Canada proved to have a minor 
impact on the tyre market and to raise litt le interest from the tyre industry itself. 
Stakeholders, including the tyre industry, asked for a “ performance label”  instead – a 
scheme that would enable objective compar ison between products, such as the banding 
scheme with the A to G scale used for hous ehold appliances (see sample in Annex 4). 
• Inclusion of tread wear  (life duration of a tyre) in a multi-criteria grading scheme: 
technical analysis shows that  there may be a trade-off between RR and tread wear in a 
given technology, but this was not taken any further for two reasons (see minutes of the 
21 April 2008 expert group meeting in Annex 1).  
– The life duration (tread wear) of tyres is  a parameter consumers can take clear 
notice of when they have to change thei r tyres. Market surveys show that “long-
lasting tyres” constitute the most impor tant criterion in consumers’ purchasing 
decisions. The market is therefore consider ed to be self-regula ting: no established 
tyre manufacturer would take the risk of  decreasing the lifetime of a tyre, knowing 
that consumers will notice it (even if a few years after the purchasing decision) 
and loose confidence in the brand. 
– There are no reliable testing methods for tread wear and testing would be very 
costly (due to the necessity to test tyres over 10 000 km). 
– Aware of the necessity to avoid the poten tial adverse impact on the environment 
of reduced tread wear (which would increa se tyre waste, hence compensate for the 
gains due to fuel efficiency ), tyre experts agreed that  it may be necessary, some 
time after the implementation of a labelling scheme, to reassess the situation and its impact on tread wear. 
• Distinguishing between winter/summer tyres  in the labelling scheme: First figures 
seemed to indicate that a diffe rent grading scheme should be implemented in both market 
segments accounting respectively for 28% and 72% of the market [EPEC 2008]. However, 
there are two major concerns opposing such an approach: (1) the abse nce of a satisfactory 
definition of winter tyres and summer tyres, which is still being discussed at UNECE level, and (2) contradictory data on the average RR of winter and summer tyres, which makes it 
impossible to draw any conclusions on the desi gn of a distinct grading scheme. ETRMA’s 
2004 state of the market shows a difference in the average RR of winter and summer tyres 
of 1kg/t (winter tyres 1kg/t above summer tyres), while VTI and M+P found the opposite 
results (winter tyres 1kg/t less than summer tyres). 
5. A
NALYSIS OF IMPACTS  
5.1. Option 1: No EU Action 
5.1.1. Drivers of RR Improvement Option 1 is the baseline scenario and includes EU  initiatives already in the pipeline – namely 
(1) type-approval legislation for vehicles, whic h puts pressure on motor vehicle producers to 
reduce emissions, (2) type-approv al legislation governing ty res and (3) market demand. 
 
EN 17   EN 5.1.1.1. Type-Approval Legislation governing Vehicles 
Directive 2007/46/EC provides a framework for all requirements with which car producers 
have to comply, including mandatory  requirements on pollutant emissions17 measured in what 
is known as the type-approval (TA) proced ure. New future requirements for car CO 2 
emissions18, and tax incentives to encourage the pur chase of cars with lower emissions, are 
putting additional pressure on vehicle producers. Th is has led them to re quest their suppliers 
to deliver tyres with lower RR (as tyres have a direct impact on fuel consumption and hence 
TA measured emissions). 
It is also likely that the considered  provision on mandatory measurement of CO 2 and pollutant 
emissions in connection with tyres with the highest rolling resistance19 (out of those 
developed for a specific vehicle) will have a positive impact on the average RR of the OE 
market (tyres fitted on new vehicles, see Box 3) . The rationale is that car producers who have 
to comply with stringent emission limits will put  more pressure on their suppliers for reduced 
rolling resistance of all OE tyres as they will  be obliged to do the testing with the worst-
performing. 
Improvements on tyre fuel efficiency have  therefore been driven  mainly by the OE 
market  which accounts for 22% of market share. Consumer surveys vary  on the real impact 
of the OE market on the replacement market, some showing that around 20% of consumers 
replace their tyre with the same brand as the original one ([EPEC 2008] based on tyre 
producers’ surveys), other estimating it at a bout 50% (ETRMA contribution at the 26 May 
workshop). While it is certain that car producers’ choice on the OE market has a spillover 
effect on the replacement market, it can be expected  that consumers will turn back to cheaper 
replacement tyres unless they are properly informed about the monetary, safety and 
environmental benefits of buying better-performing ones. 
5.1.1.2. Type-Approval Legislation governing Tyres Standards for tyres were de fined in Directive 1992/23/EC and its subsequent amending 
Directives. They will be replaced by the propo sal for a Regulation on th e general safety of 
motor vehicles (COM(2008) 316) which lays down the gradual introduction of minimum 
requirements regarding rolli ng resistance (see Annex 6).  
5.1.1.3. Market Demand Improvement in RR must also be driven to some extent by road transport companies wishing 
to reduce their costs per km. Bilateral intervie ws with large fleet managers show, however, 
that their knowledge about the relation between rolling resist ance and fuel consumption is 
very diverse, with (i) some fleet managers aware of the i ssue but complaining about the 
difficulty of comparing tyre RR performa nce and its impact on fuel consumption
20, and 
                                                 
17 E.g. Regulation (EC) No 715/2007 on type approval of motor vehicles with respect to emissions from 
light passenger and commercial vehicles (Euro 5 and Euro 6), proposal for a Regulation with respect to 
emissions from heavy-duty vehicles (Euro VI) (COM(2007) 851). 
18 Proposal for a Regulation setting emission performance standards for new passenger cars as part of the 
Community’s integrated approach to reduce CO 2 emissions from light-duty vehicles (COM(2007) 856). 
19 Or second-highest – if there are more than three sizes of tyre. See implementing measure of Regulation 
715/2007 on type approval of motor vehicles with respect to emissions from light passenger and 
commercial vehicles (Euro 5 and Euro 6), Annexes III, point 3.5 and Annexes XII point 3.2, see 
http://ec.europa.eu/enterprise/automotive/directives/proposals.htm. 
20 Fleet managers willing to test fuel-efficient tyres will have to use them on a wider fleet over a year on 
average to obtain reliable results on related fuel consumption. It is understandable, therefore, that their 
capacity to test different products is limited. 
 
EN 18   EN (ii) fleet managers sceptical or unaware of th e fuel savings potential. Market surveys show 
that price and mileage are currently the first and only parameters which fleet managers take 
into account in their purchasing  decision. This is confirmed by the actual market distribution 
of C3 tyres (high variation between tyre fuel -efficiency performance and sub-optimal average 
at 6.5kg/t instead of 4kg/t to 5kg/t, the current stat e of the art) which shows that there must be 
some barriers to the development of fuel efficient tyres on this market as well. It is also likely 
that leasing companies, even though they ma y have the knowledge about technical issues 
related to tyre fuel efficiency, will not take it into account as, in the end, they do not pay the 
fuel bills. 
5.1.2. Expected Market Transformation – Baseline Scenario 
Continuous improvements in rolling resistance  and market share over time due to the 
combination of these three fact ors have been evaluated by [EPE C 2008]. For the sake of this 
impact assessment and to facilitate comparis on between policy options and the reference case, 
the expected market distribution is represented, in Tables 2, 3 and 4, using the same banding 
scheme which is proposed in the other policy options. It assumes, because of the market 
failure, that there will be no C1 and C2 tyres below 7kg/t and 6.5k g/t, even though the 
technology should be availabl e in the years to come. 
Table 1: Market Distributio n of C1 Replacement Tyres (Summer and Winter), Baseline 
Scenario 
RRC 
(kg/t) below 
7 7 to 8 8 to 9 9 to 10 10 to 11 11 to 12 Above 
12 
2012 0% 1% 6% 5% 16% 29% 44% 
2013 0% 1% 7% 6% 19% 37% 29% 
2014 0% 1% 8% 7% 22% 43% 19% 
2015 0% 1% 9% 8% 27% 54% / 
2016 0% 1% 9% 8% 27% 54% / 
2017 0% 1% 11% 12% 39% 36% / 
2018 0% 1% 13% 13% 47% 25% / 
2019 0% 2% 17% 17% 63% / / 
2020 0% 2% 17% 17% 63% / / 
Source: [EPEC 2008]  
 
EN 19   EN Table 2: Market Distribution of C2 Tyres  (Summer and Winter), Baseline Scenario 
RRC (kg/t) below 
6.5 6.5 to 
7.5 7.5 to 
8.5 8.5 to 
9.5 9.5 to 
10.5 above 
10.5 
Base SOA 
2004  0% 5% 18% 36% 41% 
2013 0% 1% 4% 18% 42% 35% 
2014 0% 1% 4% 21% 50% 23% 
2015 0% 1% 6% 27% 66% 0% 
2016 0% 1% 6% 27% 66% 0% 
2017 0% 1% 8% 46% 45% 0% 
2018 0% 1% 10% 58% 30% 0% 
2019 0% 1% 14% 84% 0% 0% 
2020 0% 1% 14% 84% 0% 0% 
 Source: [EPEC 2008] 
Table 3: Market Distribution of C3 Tyres  (Summer and Winter), Baseline Scenario 
RRC (kg/t) below 4 4 to 5 5 to 6 6 to 7 7 to 8 above 8
Base SOA 2004/2008 1% 8% 23% 33% 23% 10% 
2013 1% 9% 24% 34% 25% 7% 
2014 1% 9% 24% 35% 26% 4% 
2015 1% 9% 25% 36% 26% 3% 
2016 1% 9% 25% 36% 26% 2% 
2017 2% 13% 36% 30% 19% 0% 
2018 2% 16% 43% 26% 12% 0 
2019 3% 17% 48% 24% 8% 0 
2020 3% 19% 51% 22% 6% 0 
 Source: [EPEC 2008] 
5.2. Option 2: Labelling Scheme for RR wi th Minimum Requirements on Wet Grip 
and External Rolling Noise for C1 Tyres 
5.2.1. Minimum Requirements Set for We t Grip and External Rolling Noise 
The proposed minimum requirements for wet grip and external rolling noise (if adopted as 
such in the ongoing co-decision procedure, see Annex 6) will already guarantee that improved 
rolling resistance will not be achieved at the expense of a deterioration in these two 
parameters. 
 
EN 20   EN The proposed minimum requirements for wet grip  were defined at UNECE level during the 
adoption of new external rolling noise limits in  order to avoid the la tter from being achieved 
to the detriment of safety. At the time of the negotiations (from 1999  to 2005), the safety 
performance characteristics of tyres were considered to be satisfactory  by all stakeholders 
(confirmed by ENTR and the UK government in its written repl y during the public 
consultation). This judgement seems to be c onfirmed by the Nordic Ecolabel as it requires 
that an eligible tyre demonstrates  a wet grip that is a as good as or better than other equivalent 
tyres on the Nordic market – in other words, the minimum grip for an equivalent tyre on the 
market sets the level at which safety is determined. 
5.2.2. Factors Determining the Design of a Banding Scheme 
The design of a banding scheme  is based on several factors: (1) the state of the art, (2) 
production costs to achieve a certain level of RR which – compared to the related fuel savings 
– will determine the (3) cost-effective levels towards which the market can be rationally expected to be drive n, (4) the precision of te sting methods which may limit the width of the 
bands, and (5) the market structure which ma y call for a relative grading scheme or an 
absolute one. 
5.2.2.1. State of the Art 
According to [EPEC 2008] and figures provided by tyre produ cers, the best tyres on the 
market in 2008 (with good wet grip perfor mance) are around 7.5kg/t but only on the OE 
market. On the replacement market, the state of the art in 2008 is between 8kg/t and 8.5kg/t, 
while a prototype at 5kg/t alrea dy exists. Interviews with the ty re producers showed that it 
would be possible to produce tyres at  6kg/t to 6.5kg/t within a few years. 
It may be possible to reduce RR below this level, some spoke of 3.5kg/t by 2030, but existing 
technologies and know-how make it impossible to anticipate th e production costs of such 
innovations. It is likely that above a certain leve l fuel efficient tyres will cease to be cost-
effective, as any increased gain in RR will be achieved through a disproportionate increase in production costs. 
5.2.2.2. Production Costs Since tyres parameters are interrelated, produ ction costs are related to the performance 
balance achieved (Figure 4). 
 
EN 21   EN Figure 4: Performance Optimisa tion and Production Costs 
 
Notes 
– Relative noise emission: a higher  percentage means a higher nois e emission (i.e. >100% is worse). 
– Relative deceleration: a higher pe rcentage means a better braking pe rformance (i.e. >100% is better). 
– Relative rolling resistance: a higher percentage means  a higher rolling resistance (i.e. >100% is worse). 
– Relative floating speed: a higher percentage means a better aquaplaning behaviour  (i.e. >100% is better). 
– Relative sales price: a higher  percentage means a higher sales price (i.e. >100% is worse) . 
Source: TÜV, quoted in [EPEC 2008] 
The chart clearly shows that it is possible to  reduce RR at lower costs, while decreasing wet 
grip performance. The optimisation of both we t grip and RR can be achieved, but at higher 
production costs. 
A single-labelling scheme promoting the optimis ation of RR while allowing the possibility to 
keep wet grip at the minimum legal requireme nt will therefore lead to reduced production 
costs compared with a dual-labelling scheme  that would be pushing producers to optimise 
both wet grip and RR. The table below, base d on extensive surveys by tyre producers under 
the external study [EPEC 2008], summarises increas ed production costs fo r a given gain in 
RR. It is also likely that pr oduction costs will decr ease over time when fu el efficient tyres 
achieve mass production level, with economies of scale. 
Table 4: Production Costs for Reductions  in RRC by Fuel Efficiency Class, 2012, 
compared to band F  
 A B C D E F G 
RRC (kg/t) below 7 7 to 8 8 to 9 9 to 10 10 to 11 11 to 12 above 12
Single Labelling (Option 2) 16.1% 11.1% 7.6% 4.8% 2.3% 0.0% 0.0% 
Dual Labelling (Option 3) 32.2% 22.2% 15.2% 9.6% 4.6% 0.0% 0.0% 
Source: [EPEC 2008] 
The table shows a non-proportional relationshi p between production costs and RR reduction. 
This is due to a rising marginal cost curve (a  given gain in RR imp lies increasingly higher 
R&D investments and production costs). 
 
EN 22   EN It is not possible to quantify the exact market transfor mation and price evolution should a 
labelling scheme be introduced. It is also likely  that in reality a labelling scheme will change 
retailer strategies and prices accordingly. In additi on, empirical surveys s how that prices do 
not always reflect tyre quality21. For the sake of this impact assessment, however, one can 
assume, taking into account that the market is co mpetitive, that retail price will largely reflect 
production costs. 
Increased production costs applied to the aver age price of tyres ( €87 including VAT and €70 
excluding VAT)  make it possible to make the following price assumption. Costs of testing RR 
are not included in the calcul ation as they are considered  marginal, between €0.02 and €0.006 
per tyre (see Section 6.2.1.3). 
Table 5: Price Premium for Moving from Band F to any Other Band, C1 Summer Tyres 
 A B C D E F G 
RRC kg/t below 7 7 to 8 8 to 9 9 to 10 10 to 11 11 to 12 above 12
Price premium (%) 16.10% 11.10% 7.60% 4.80% 2.30% 0% 0% 
Price premium (€, incl. VAT) 14.0 9.6 6.6 4.2 2.0 0 0 
Price premium (€, excl. VAT) 11.3 7.8 5.3 3.4 1.6 0 0 
Source: [EPEC 2008] 
5.2.2.3. Cost-Effectiveness of Fuel -Efficient Tyres – Case Study 
Estimations of increased produc tion costs by tyre producers s how a potential price increase 
for end-users of 16% compared to average price (€87 including VAT, €70 excluding. VAT), 
which means that a consumer would have to pa y €14 more to buy an A tyre compared to an 
average tyre (in band F). So the price increase for a set of four tyre s will be €56 including 
VAT with 7.5% fuel savings, i.e. €280 fuel savings for a medium-size car22, hence a net 
saving of €224  including VAT. The payback period (retur n on investment) in that case is six 
months. 
This case study shows that it will be cost-e ffective for consumers/e nd-users to buy tyres 
below 7kg/t once they are on the market. It ther efore seems reasonable to expect a labelling 
scheme to drive the whole market towards th is limit in the short to medium term. New 
technological improvements will make the revi sion of the labelling scheme necessary at a 
later stage (around 2020 according to inte rviews with tyre manufacturers). 
5.2.2.4. Precision of Testing Methods It is planned to base the pr ecision of testing methods on the ISO 28580 measuring method 
which should be adopted in the first half of 200 9. It seems that the precision of the tests will 
be sufficient so as to impose no specific constraints on the design of the bands. 
                                                
 
21 The Transportation Research Boar d (TRB) in the USA performed several multiple regression analyses 
to see how tyre prices relate to various tyre charact eristics and found that a substantial proportion of the 
variation in tyre prices remained unexplained by the tyre characteristics. See TRB Special Report 286, 
Tires and Passenger Vehicle Fuel Economy , Informing Consumers, Improving Performance , 2006, 
pp. 110–112. 
22 Based on [EPEC 2008] calculations/average fuel savings on a medium car, fuel price at 0.61 €/l excl. 
VAT, 1.28 €/l incl. VAT, see also footnote 25. 
 
EN 23   EN 5.2.2.5. Relative versus Absolute Labelling 
The European Commission has consistently, within the existing labelling Directive on 
household appliances (Directive 1992/75/EC), fa voured relative grading as against absolute 
grading. The rationale behind this is to allo w consumers to compare products which provide 
similar functionalities and co rrespond to consumers’ needs. Someone needing a big 
refrigerator because he/she has a large fam ily will not change his/her purchasing decision 
because smaller fridges obviously consume le ss energy. The same argumentation may well be 
true for tyres, as consumers have a limited choi ce in the dimension of the tyres they have to 
replace on a given vehicle. 
A relative grading scheme would make sense onl y if there is a proven correlation between 
rolling resistance and other parameters, such as  external diameter (OD) and/or load index 
(LI). Although the available figu res from the tyre industry point to the existence of a 
correlation, it is considered too weak to call for a relative grading scheme (see Annex 3 for a 
detailed explanation). 
5.2.3. Proposal for a Grading Scheme 
Since the labelling scheme for hous ehold appliances ("A to G" scale, see sample in Annex 4) 
is very well known to consumers, it is highly recommended – and this was indeed requested 
by the majority of stakeholders, consumer organisations included23 – to follow the same scale 
design24. The introduction of a car labelling scheme also using the same "A to G" scale at the 
request of car producers25 (on the same grounds) will also reinforce the impact and 
recognition of a labellin g scheme for tyres. 
Taking into account the aboveme ntioned elements, including the technological threshold, 
evaluated around 6kg/t, which provides the st arting point for the A class and the legal 
minimum requirements which provide the basis for the lowest class (see Annex 6), the 
following grading scheme is a feasible option by 2012. 
Alternative 1: Medium Approach 
 A B C D E F G 
RRC (kg/t)  below 7 7 to 8 8 to 9 9 to 10 10 to 11 11 to 12 above 12
Comments: Band A could be set for a ny tyre below 7 on the following grounds. 
– The level of band A depends on the date of entry into force of the labelling scheme. 
Experience from other product gr oups shows that for the credib ility of the scheme it is 
important to have a band A which can be populat ed with some products on the day of entry 
into force. If band A is to be populated say in January 2011 or 2012, it should be set below 7kg/t (if the scheme were to be implemente d a few years later, say 2013 or 2014, band A 
could probably be set below 6.5kg/t). 
– If it is proposed to go for an  absolute grading scheme (see Annex 4), a too stringent limit 
for band A would make it likely that no smaller tyres may achieve this class. 
                                                
 
23 E.g. as part of the public consultation undertaken by ENTR on the Advanced Safety of Motor Vehicles and Tyres. 
24 There is an ongoing discussion on a possible revision of the labelling scheme for household appliances 
(for example by replacing the A to G scale by number s). If the outcome were indeed a revision, it is 
proposed for consistency’s sake that the ty re labelling scheme follows the same design. 
25 Positions expressed in the 5 June 2008 workshop on car labelling. 
 
EN 24   EN – Since tyres parameters are interrelated, sett ing band A at too high a level would imply 
increased costs to maintain other parameters (wet grip, external ro lling noise, etc.) at a 
satisfactory level, so that it may be le ss attractive for consumers to buy band A. 
– In the case of amendments to the proposed  minimum requirements on RR (annex 6), the 
labelling scheme would still be  valid: either the requireme nts are less demanding, then 
there will be more tyres in band G and the la belling scheme would become more important 
in driving market transformation. Either the re quirements are made mo re stringent (which 
is unlikely as the average RR on the mark et in 2008 is around 11.5 kg/t) then band G 
would become empty but this would reflec t the important improvements which have 
occurred on the market.  
The cost-benefit analysis in Section 6 is based on this banding proposal. Other alternatives are 
discussed below taking into account the same elements. 
Alternative 2: More Demanding Approach 
 A B C D E F G 
RRC (kg/t) below 6.5 6.5 to 7.7 7.7 to 9 empty 9 to 10.5 10.5 to 12 above 12 
Comments:  
– The bandwidth of the classe s is decreasing to reflect the non-proportional relationship 
between production costs and RR reduction (due to  a rising marginal cost curve); in other 
words, the investments necessary to achie ve a 1 kg/t reduction from 8 to 7 kg/t are 
significantly higher than the same reduction from  12 to 11 kg/t, this is why the bandwidth 
is decreasing in upper bands.  
– Another advantage of larger bandwidth in the lo west bands (E to G) is that the thresholds 
better reflect the minimum requirements set in  the proposal for a Regulation on the general 
safety of motor vehicles ( 12 kg/t by 2012/14, 10.5 kg/t by 2016/18). 
– The empty band in class D would allow for a greater differentiation between products. This 
in turn is likely to give bo th greater incentives to  the industry to place on the market tyres 
in bands A to C and greater incentives to consumers to pay slightly more for a better graded product (the gap between the bad and better performing tyres is greater).  
– Band A seems still feasible though very challe nging and slightly more likely to drive 
innovation than when it is set at 7 kg/t. Since tyres at 7.5kg/t  are already on the market in 
2008 and 6kg/t was targeted as tech nologically feasible in the shor t run, it is expected that 
band A could be populated by the end of 2012.  
– The drawback of this proposal compared to the preceding one is related to consumer 
information: while a linear bandwidth of 1kg /t is easy to understand (1 band = 1.5% fuel 
saving), empty classes and decreasing bandwidth  blur the message to consumers on related 
fuel savings. But commercial messages can be developed by retailers and manufacturers to 
highlight the benefits of op ting for the higher classes. 
 
EN 25   EN Alternative 3: Less Demanding Approach 
 A B C D E F G 
RRC (kg/t) below 8 8 to 9 9 to 10 10 to 11 11 to 12 12 to 13 above 13 
Comments:  
– Since tyres at 7.5kg/t are already on the mark et in 2008, band A below 8 would not provide 
an incentive for further innovation. In additi on, bands F and G would become empty in 
2014 – the presumed date of entry into for ce of the minimum requirements governing RR 
for all tyre types – if the proposal for a Regul ation on the general safety of motor vehicles 
(COM(2008) 316) is adopted. 
5.2.4. Expected Market Transforma tion and End-User Benefits 
The table below, based on the first banding proposal, summarises the expected market 
transformation and benefits for consumers/end-us ers due to a single-crit erion grading scheme 
(total economic benefits excludi ng VAT are presented in Section 6) . It presents two scenarios, 
a slow and a fast pace of change (i.e. market transformation towa rds fuel efficient tyres), in 
order to reflect unavoida ble uncertainties surrounding the eff ectiveness of a labelling scheme. 
This is confirmed by the expe rience with househol d appliances where certain products 
experienced a very fast market transformati on while others took more time to develop26. 
                                                 
26 Europe Economics, Impact assessment study on a possible extension, tightening or simplification of 
Framework Directive 92/75 EEC on energy labelling of household appliances, October 2007, pp. 13–
18. 
 
EN 26   EN Table 6: Possible Grading Scheme and Consum er Benefits per Set of 4 C1 Tyres (Winter 
and Summer, VAT incl.) for Moving from Band F (the average RR in 2012) to any 
Other Band 
Source: [EPEC 2008] 
The table illustrates that once the market failu re caused by lack of information is removed 
(labelling scheme, Option 2), the ma rket take-up of fuel-efficient tyres is excepted to be faster 
than with no policy intervention (baseline scenar io, Option 1) even in the most conservative 
scenario, with between 16 and 44% of tyres in band A and B compared to 2% in the baseline 
scenario and the average RR in band D or C in Option 2 (slow or fast pace of change) compared to E in Option 1. 
                                                
 
27 The calculation is based on average EU passenger car fleet consumption in 2012, where 1.5% fuel 
savings (due to 10% reduction in RR) means 0.11 l/100km, i.e. 44 litres saved over 40 000 km (the 
average lifetime of a tyre set) for a monetary value of €56 with a fuel price assumption of 1.28 €/l incl. 
VAT (€75/bbl). 
28 Assuming that the average mileage of a set of tyre s before they are worn out (40 000 km) is achieved 
within 2.5 years.  A B C D E F G 
RRC (kg/t) 6 to 7 7 to 8 8 to 9 9 to 10 10 to 11 11 to 12 above 12
Price premium 
(€) 56 38.4 26.4 16.8 8 0 -8 
Total fuel 
savings (€)27 280 224 168 112 56 0 -56 
Payback period 
(months)28 6 5 5 4 4 0 / 
CO 2 real world 
savings (g/km) 13.6 10.9 8.2 5.4 2.7 0 -2.7 
in 2012 0% 1% 4% 15% 16% 23% 23% 
in 2020 
(slow 
pace) 4% 12% 27% 36% 22% 0% 0% 
in 2020 
(fast pace) 21% 23% 27% 16% 14% 0% 0% Market share 
in 2020 
(baseline 
scenario) 0% 2% 17% 17% 63% 0% 0% 
 
EN 27   EN 5.3. Option 3: Dual-Labelling Scheme fo r C1 Tyres regarding RR and Wet Grip 
In a competitive market a dual-labelling scheme will provide incentives to optimise all 
parameters on which information is provided. A si gnificant drawback of this measure is that it 
will blur the information given to consum ers. Figure 5 below illustrates consumer 
preferences. 
Figure 5: Consumer Preferences for Tyre Parameters, 2006 
 
Source: (TAAS) Tyre Awareness and Atti tude Study, Frequency & Methodology: 
Yearly (since 1999) quoted in [EPEC 2008]29. 
This shows that between 66% and 69% of consumers consider wet grip and braking 
performance to be very important  and 55% of them deem fuel e fficiency to be very important. 
It is difficult to predict the impact on cons umers of providing information on both parameters, 
but it is likely, given the above, that consumer s will choose safety first and pay less prominent 
attention to fuel efficienc y. This would slow down market  transformation towards fuel 
efficient tyres. It is therefore important to assess the real safety gains above the minimum 
requirements set for wet grip to know if it is worth losing on potential fuel savings. 
5.3.1. Potential for Wet Grip Improvement above Minimum Requirements 
Data on the market distribution of tyres related to wet grip are scarce. The figure below shows 
the market distribution of tyres according to wet grip measured using ISO 23671 and 
compared to the UNECE Regula tion 117 minimum requirements. 
                                                 
29 Includes face-to-face (or online) interviews and a 30-minute structured questionnaire (incl. physical tyre check). 
Countries & No of respondents (2006): France, Italy, UK, Sp ain, Switzerland, Portugal, Belgium, Austria, Greece, 
Denmark: 6 908 respondents + Germany (run by IPSOS): 1 038 respondents. Total: 7 946 respondents. Contracted 
agency: Open Air Market Research www.open-air.fr . 
 
EN 28   EN Figure 6: Tyre Distribution by Wet grip 
 
Source: GRRF quoted in [VTI 2008]  
The chart shows that potential indeed ex ists for improving wet grip performance (up to 
140% in 2004) above the wet grip minimum requirements. In 2008, the limit is closer to 
160% according to tyre producers. For example, for a car travelling at 80km/h on a wet road 
with a friction coefficient of 0.5 (corresponding to a road polished by traffic), the gain in 
braking distance between the best - and worst-performing tyres may be up to 18 metres above 
the wet grip minimum requirement; at higher speed the gain would obviously be higher. 
5.3.2. Assessment of Safety Gains 
The gains due to improved braking distance ar e difficult to assess. First, vehicle-tyre 
interactions will play an importa nt role in the real on-road braking performance of a tyre. 
Second, there are few solid analyses of the relation between tyres and accident rates30. 
National statistics and accidents databases do not  make for an in-depth analysis of accident 
causes and the impact of tyre performance. Accidents, due fo r instance to running into an 
unexpected traffic jam on the motorway and wh ich may have been avoided with a better-
performing tyre, will be attributed to “excessive speed” or “insufficient safety distance”. Gain 
in braking distance may make the difference in avoiding an accident, but  it will be impossible 
to quantify and will never be reported in  statistics as the cause of the accident. 
                                                 
30 The EC project “safety net” started extensive resear ch into accident causes including tyres, but results 
are expected only in five years. 
 
EN 29   EN Although knowing the shortcomings of  the data available, [TÜV 2004]31 nevertheless made 
an estimation of tyre-related accidents. It show s that tyres account for a large share (45%) of 
vehicle accidents due to technica l failures (25% of all accidents resulting in personal injury or 
fatalities), but for a relatively low share in all reported moto r vehicle accidents (0.4% in 
Germany and Switzerland, 0.1% in Italy32). 
Analysis of tyre-related accidents shows, first,  that the main causes of accidents are deficient 
maintenance (tread depth below legal limit va lue) and under-inflation, and, second, that 
accidents more often occur on wet a nd snow-covered roads (around 60%)33. In addition, 16% 
of passenger car casualties involving personal injury were found to occur with skidding34. 
This does not make it possible to draw a dir ect conclusion on the relationship between wet 
grip and accidents, but as it shows a direct link between low friction (occurring on wet or 
snow-covered road and with low tread depth below the legal requirement35) and accidents, it 
is likely, by extrapolation, that ty re wet grip must also play a non-negligible role  in avoiding 
accidents. As [TÜV 2004] points ou t: “It is hardly possible to reconstruct an accident to 
establish the case as whether or not a better ty re would have helped to prevent the accident 
under the given circumstances or would have at least reduced its severity and consequences 
(…). From the technical point of view, it can  be assumed with maximum probability that 
there is a non-negligible number of unknown cas es of tyre-related accidents related to 
inadequate tyre performance.36” 
Social benefits in the form of reduced accident  rates due to improved wet grip performance –
above the minimum requirement to be set for 2012 – are therefore difficult to predict. But a calculation made by [EPEC 2008] based on the social cost of one road traffic accident, 
estimated at €1 million
37, shows that only a small reduction in road traffic casualties would 
need to be achieved (around 0.01 to 0.02%) to compensate fo r the economic loss occurred by 
the implementation of a dual-labelling scheme in stead of a single-labell ing scheme. It also 
goes without saying that human lives take  precedence over economic considerations. 
5.3.3. Factors Determining the Design of  a Banding Scheme for Wet Grip 
5.3.3.1. State of the Art 
As already highlighted above, th ere are few data on the state of  the art on wet grip and the 
related increased production costs. There seem s to be a consensus among the tyre industry 
that the state of the art in 2008 is around 160%. 
                                                 
31 TÜV Automotive, Survey on motor vehicle tyres and related aspects, June 2004 
http://ec.europa.eu/enterprise/automotive/projects/report_motor_vehicle_tyres.pdf. 
32 According to an unpublished report by S. Reed, A. Morris and R Elliman, within the Safety Net Work 
Package 5 (issued in June 2008 for the purpose of this impact assessment) and based on a database of around 2 000 accidents, a tyre defect was recorded in only 1.5% of fatal accidents and tyres were 
identified as a possible contributory fact or in 3% of all recorded accidents. 
33 Results from [TÜV 2004], confirmed by the [Safety Net Work Package 5 2008]. 
34 Analysis of a database of 20 349 accidents 1985- 2006 by GIDAS (German In-Depth Accident Study). 
Written contribution to this impact assessment by Otte, Dietmar, Medizinische Hochschule Hannover, 
VerkehrsUnfallForschung, 2008. 
35 Tread depth refers to the “sculpture” on tyres to enab le evacuation of water, thus increasing wet grip. It 
can vary between 8 to 9mm depth when a tyre is new and 1.6mm which is the legal limit indicating when a tyre must be replaced. 
36 ibid pp. 33 & 34. 
37 Cordis Europe and Trawn et al, 2001. 
 
EN 30   EN 5.3.3.2. Production Costs of Optimised Wet Grip and RR 
Production costs and the related price premium (t he assumption that pr ice reflects production 
costs in a competitive market) for optimisation of both wet grip and RR are presented in Table 7. Costs of wet grip testing are not included as  they can be considered marginal, around 0.01 
cent per tyre (Section 6.2.1.3). 
Table 7: Price Premium for Moving from Band F to any Other Band (Dual Labelling), 
C1 Summer Tyres 
 A B C D E F G 
RRC (kg/t) below 7 7 to 8 8 to 9 9 to 10 10 to 11 11 to 12 above 12
Increased production costs (%) 32.2% 22.2% 15.2% 9.6% 4.6% 0% 0% 
Price premium (€, incl. VAT) 27.9 19.2 13.2 8.3 4.0 0 0 
Price premium (€, excl. VAT) 22.6 15.6 10.7 6.7 3.2 0 0 
Source: [EPEC 2008] 
5.3.3.3. Cost-Effectiveness – Case Study Estimates of increased production costs by tyre  producers indicate a pot ential price increase 
for end-users of 32% compared to the aver age price (€87 including VAT, €70 excluding 
VAT), which means that a consumer/end-user w ould have to pay €28 mo re to buy an A tyre. 
So the price increase for a set of four ty res will be €112 including VAT, with 7.5% fuel 
savings compared to the average (in band F), i.e. a €280 fuel saving, hence a net saving of 
€168  including VAT
38 with a payback period (return on inve stment) of eight months. So band 
A would still remain cost-effective in a dual- labelling scheme even with the increased 
production costs it may entail. 
5.3.4. Grading Scheme for Wet Grip 
Taking these elements into account and the cu rrent precision of th e ISO 23671 test method, 
which currently does not make for bands narro wer than 15%, the following banding schemes 
seem feasible. 
Alternative 1: Medium Approach 
 A B C D E F G 
Wet grip 
index above 145 145 to 
130 130 to 
115 below 
115 empty empty empty 
Comments: This proposal would leave three clas ses (bands E, F and G) empty and set band D 
above the legal requirement for wet grip, first,  to reflect the improvement which the legal 
requirement will bring about (30% of the worst- performing tyres will be banned), and second, 
to convey the information to consumers that ty res in band D are alre ady safe. They would 
indeed comply with the proposed legal requirement considered by all stakeholders at the time 
                                                 
38 Based on [EPEC 2008] calculations/average fuel savings on a medium car, fuel price at 0.61 €/l excl. 
VAT, 1.28 €/l incl. VAT. 
 
EN 31   EN of adoption at UNECE level to be satisfactory in guaranteeing drivers’ safety (see Section 
5.2.1). 
Alternative 2: More Demanding Approach 
 A B C D E F G 
Wet grip index above 
155 155 to 
140 140 to 
125 empty 125 to 
110 below 
110 empty 
Comments: This proposal is reflecting alternativ e 2 on fuel efficiency grading. Class D empty 
would allow for more differen tiation between product performa nce characteristics and give 
more incentives both on consumers to buy better performing tyres regarding wet grip and on 
the industry to place on the market better tyres re garding wet grip. Class A is more ambitious 
compared to the alternative 1 and is therefore likely to give more long-term incentives for 
innovation. A drawback of this proposal however is that "Alternative 2" both for RR (class A 
below 6.5 kg/t) and wet grip (class A above 155) would mean that in practice no tyres, in the 
short term, will be able to qualify in class A for both parameters. It is also likely that no winter tyres would perform in class A, above 155. However, it gives in the long run greater 
incentives for innovations and is likely therefore to la st longer without having to amend the 
classes. 
5.3.5. Expected Market Transformation regardi ng Fuel Efficient Tyres and End-User 
Benefits 
The table below on expected benefits due to a dual-labelling scheme for fuel efficiency and 
wet grip (Option 3) shows a slower market tr ansformation than in Option 2 (single-criterion 
labelling scheme for tyre fuel efficiency), fo r the reason presented in the previous Section: 
consumers are likely to give pr iority to wet grip over fuel consumption. On the other hand, a 
label putting the emphasis on fuel efficiency but  still providing gradi ng of wet grip would 
combine the advantage of achieving higher fuel savings without affecting safety. 
Market transformation regarding wet grip is not reflected in the following table because the 
related social benefits are uncer tain (Section 5.3.1). It is, however, very likely that consumers 
will choose tyres above the minimum wet grip requirements and drive the market towards dynamic optimisation of both wet grip and RR. 
 
EN 32   EN Table 8: Market Transformation and Consum er Benefits per Set of 4 C1 Tyres (Winter 
and Summer, VAT incl.) for Moving from Ba nd F to any Other Band – Dual-Labelling 
Scheme 
Source: [EPEC 2008] 
Market transformation is slower than in Option 2 but still higher than in the baseline scenario 
(no EU action, Option 1) with 14% to 30% of ty res in band A and B (slow and fast pace of 
change) and only 2% in the baseline scenario. 
5.4. Option 4: Multi-Criteria Labelling Sc heme for C1 Tyres regarding RR and Wet 
Grip Extended to External Rolling Noise 
5.4.1. Potential for External Rolling Noise Improvement above Minimum Requirements Figure 7 below shows that there is a potential fo r further reducing external rolling noise above 
the minimum requirements set out in the proposa l for a Regulation on th e general safety of 
motor vehicles (COM(2008) 316) (see Annex 6). However, the cost implication of 
optimisation of all three parameters (wet gr ip/RR/external rolling noise) is not well known, 
the main trade-off lying between wet grip and exte rnal rolling noise. It is likely that they will 
be higher than the assumed production costs for optimising both wet grip and rolling 
resistance presented in Tabl e 8 in the previous Section. 
                                                
 
39 Assumption: fuel price at 1.28 €/l incl. VAT, see footnote 26. 
40 See footnote 30.  A B C D E F G 
RRC (kg/t) below 7 7 to 8 8 to 9 9 to 10 10 to 11 11 to 12 above 12
Price premium (€) 112 77 53 33 16 0 -16 
Total fuel savings (€)39  280 224 168 112 56 0 -56 
Payback period (months)40 8 8 7 7 7 0 0 
CO 2 real world savings 
(g/km) 13.6 10.9 8.2 5.4 2.7 0 -2.7 
in 2012 0% 1% 4% 15% 16% 23% 23% 
in 2020 (slow pace) 3% 10% 25% 38% 24% 0% 0% 
in 2020 (fast pace) 10% 15% 25% 25% 25% 0% 0% Market share in 2020 (baseline 
scenario) 0% 2% 17% 17% 63% 0% 0% 
 
EN 33   EN Figure 7: Distribution of Tyre Market According to External rolling noise 
 
Source: T&E contribution to the stakeholder consultation. 
Since the range of tyre performance in terms of noise does not seem sufficient for a labelling 
scheme (e.g.. with 1dB bandwidth), a  low-noise mark was proposed instead by T&E for all 
tyres 3dB below the minimum requirement pr oposed for 2012/16 (see design example in 
Annex 5). An alternative would be simply to include the external rolling noise measured 
value  in a labelling scheme as is  the case with several househol d appliances, something which 
may not be very straightforward to understa nd for consumers but could be useful for 
professionals and public authorities willing to take action on traffic noise reduction. 
Some stakeholders often refer to the necessity to  act on road surfaces instead of tyres in order 
to reduce traffic noise. If the potential for reduced traffic noise is indeed higher with low-
noise road surfaces, various studies41 show that external rolling noise abatement costs due to 
technical improvement of tyres are lower than the costs of lo w-noise road surfaces, which 
does not exclude the necessity to act on road su rfaces, but shows that acting on tyre external 
rolling noise is cost-effective.  According to [VTI 2008], reduci ng road surface external rolling 
noise by 5dB to 6dB increases road costs, compared to the average road surface in Europe, by a factor of 2 or 3
42 (with a later depreciation of 1dB per year), while current market research 
shows no evident correlation betw een tyre prices and external rolling noise (also for tyres 
                                                 
41 See for instance 
http://circa.europa.eu/Public/irc/env/noisedir/libra ry?l=/position_papers/workingpaper_sept2005pdf/_E
N_1.0_&a=d. 
42 Another study by the Chalmers University of Technology estimated this factor at 4, see Reduction 
Potential of Road Traffic Noise, a Pilot Study, W. Kropp, T. Kihlman, J. Forseen and L. Ivarsson, 2007. 
 
EN 34   EN with good wet grip performance)43. In any case, production cost s of low-noise tyres would 
certainly not imply the same scale of cost increase. 
5.4.2. Effectiveness of a Low-Noise Mark in Promoting Lower External rolling noise 
If it is indeed possibl e to improve external rolling noi se above the minimum requirements 
proposed for 2012/14, the question arises whether its  inclusion in a label ling scheme would be 
effective in achieving this potential. 
• Consumer Preferences 
The first question crucial for the effectiveness of  a labelling scheme is  whether consumers are 
likely to consider external rolling noise in th eir purchasing decision. If  not, external rolling 
noise may be better addressed through minimum requirements in order to reduce its negative 
externalities. 
Two elements make it possible to answer this question: the first is the correlation between 
interior and exterior noise (since the measured value is the exterior  noise, consumers will 
want to know if they will benefit inside  their vehicles from lowe r rolling-noise tyres), the 
second are consumer surveys. 
(1) According to [M+P 2007], the correlation is good around 1 000 Hz which are the most 
disturbing frequencies for human ears, but not at 250–300 Hz due to diffe rent noise sources 
(inside the car, noise mainly comes from the po wer train at low frequencies while outside the 
car aerodynamic noise at high frequencies will dominate). Noise coming from the power train 
is due to the interaction between the vehicle an d the tyre; it therefore depends much more on 
the vehicle design characteristics rather than on the tyre itself. For some stakeholders this 
correlation is satisfactory for a labelling scheme c overing external rolling noi se, for others it is 
considered insufficient (see minutes of the workshop in Annex 2). 
Empirical experiments show in addition a disc repancy between subjective perceptions of a 
noise level and the external rolling noise meas ured value. Two tyres demonstrating the same 
noise level in the ISO test procedure may be pe rceived very differently by the human ear, one 
being perceived to be much louder than the ot her, even though both have the same measured 
noise value. Since each vehicle will also signif icantly change the inside noise perception of 
the same tyres, a grading scheme for tyre extern al rolling noise might be considered unreliable 
by consumers and affect its credib ility also with regard to th e other parameters covered (RR 
and wet grip). 
(2) There have been few surveys on consumer preferences as regards rolling noise. However, 
the existence of various marketing campaigns in itiated by the tyre industry on low-noise tyres 
may demonstrate that there is a demand for such pr oducts, or that they cons ider that there is a 
potential for it. According to resear ch done in Austria by Fallast et al44, 94% of respondents 
would be willing to buy low-noi se tyres and 70% of them to pay a small price premium. 
However, it is not clear if respondents differe ntiated between interior and exterior rolling 
noise on the one hand, and on the other if they would indeed pa y more for less noisy tyres, 
possibly at the expense of wet grip. 
                                                 
43 See M+P, Exterior Noise, Grip and Rolling Resistance Levels of C1, C2 and C3 Tyres in Relation to the 
Tyre Noise Directive (EU Directive 2001/43/EC) and Consumer Interests , Erik de Graaf and Gijsjan 
van Blokland, Inter-Noise 2007, Istanbul, Turkey, p. 6. 
44 Quoted in [VTI 2008], pp. 39–41. 
 
EN 35   EN • Effectiveness in Re duced Traffic Noise 
Since the aim of including external rolling noi se in a labelling scheme would be to reduce 
traffic noise, one has to consider whether it woul d be an effective tool for this purpose. Given 
the logarithmic scale of noise, th e effect of a grading scheme on traffic noise may be marginal 
as long as high-noise ty res are on the market. 
Example: If an entire tyre population rolls wi th a external rolling noise value of 71dB, the 
overall traffic noise level will be 74dB. Now if  the introduction of a grading scheme leads to 
half of the tyre population having  a 68dB noise level (3dB less), and the other half remains at 
71dB, the overall traffic noise level will decreas e to 72.8dB, and so the overall gain is only 
1.2dB which is inaudible for normal ears (at these fr equencies ears start to hear a difference in 
noise level when such difference is 3dB to 4dB).  
At EU level however, a 1.2dB reduction in traffi c noise may be considered significant. A 1dB 
reduction on 74dB has been attributed a valu e of €15 per person exposed to traffic noise45. To 
illustrate the potential in economic terms, a study conducted in Denmark in 2005 estimated 
benefits of a 1dB noise reduction at €11.4m per year46 The same calculation extended to the 
remaining 26 EU Member States would give  impressive results. The FEHRL report also 
attributed a value for the EU-27 of €5.5 billion benefit per 1dB reduction per year47, which 
may be an overestimate but still gives a good insi ght into the potential benefits the promotion 
of low-noise tyres may bring. 
Minimum requirements seem the most effective t ool for reducing traffic noise levels as they 
ban the loudest tyres. On the other hand, tech nological improvements are needed for setting 
more ambitious minimum requirements, and th ey are driven by the demand side. Without a 
labelling scheme, consumers have no access to the information, and this therefore provides 
tyre producers with fewer incentives to fu rther optimise and innovate above the minimum 
requirements. A labelling scheme for external rolling noise may also contribute to awareness-
raising which is one of the objectives of  Directive 2002/49/EC on environmental noise. 
In addition, transparency of data on external ro lling noise may facilitate the implementation of 
public policies (e.g.. financial incentive schemes) against traffic noise, especially within the 
framework of Directive 2002/49/ EC which provides for implementation of action plans to 
reduce traffic noise (for cities  with more than 250 000 inhab itants, airports, railways and 
roads with more than six million vehicles per year). Access to external rolling noise values 
may also be useful for public procurement officers and fleet owners anticipating the 
implementation of the revised Eurovignette Directive (Directive 1999/62/EC) (proposal 
expected by July 2008) and its related report on the internalisation of exte rnal costs, including 
noise emissions. 
The main concern as regards feasibility (of the inclusion of external rolling noise in a 
labelling scheme) is related to the variati on in measured values among ISO 10844 certified 
test tracks which was estimated at 5dB to 6dB. There is a risk that specialist magazines or 
consumer organisations would contest the clai med low-noise mark if they found different 
results due to variability of te st tracks, and hence discredit the labelling scheme. Work is in 
progress at ISO and UNECE level to monitor the extent of this variation and address it where 
                                                 
45 CE Delft, Handbook on Estimation of External Costs in the Transport Sector , produced within the study 
on Internalisation Measures and Policies for All Exte rnal Cost of Transport (IMPACT), February 2008, 
p. 67. 
46 Cost-Benefit Analysis on Noise-Reducing Pavements, VI report 146, Schultz Information, 2005, 
http://www.vejdirektoratet.dk/publikationer/VI rap146/html/entire_publication.htm#Section7.7 , p. 20. 
47 FEHRL, Tyres/Road Noise , May 2006, Volume 1, p. 91. 
 
EN 36   EN necessary. According to M+P and T&E, work is under progress at ISO level to limit this 
variation between test tracks to +/- 1.5dB. 
To conclude, there is no clear evidence as to the effective impact on road traffic noise of 
including external rolling noise in a labelling scheme, though it is clea r that it would provide 
further incentives to innovate  above the minimum requirement s and contribute to raising 
awareness. The evaluation of Option 4 will th erefore greatly depend on the values and 
priorities given to noise reduction by each stakeholder. An alternative would be to simply indicate the external rolling noise measured valu e on the label (in the light of what is already 
done for white goods) so as to make it possible for Member States or end-users to develop 
targeted policies if they so wish.  
5.5. Option 5: Extension of the Labelling Scheme Developed for C1 Tyres (Option 2, 
3 or 4) to C2 and C3 Tyres 
C2 and C3 tyres account respectively for 8% and 5% of tyre sales in the EU but as they 
consume more fuel and drive more annually, the potential for fuel savings in absolute term 
will be higher in these two markets than for C1  tyres (see Section 6.2.2). This chapter does 
not discuss in-depth each policy option (singl e-, dual- or multi-criteria labelling scheme) 
because the same argumentation as for C1 tyres applies. In other words, the same option 
preferred for C1 tyres should apply to C2 and C3 tyres. 
5.5.1. Wet Grip and External Rolli ng Noise Minimum Requirements 
Minimum requirements for external rolling noise are already laid down regarding C2 and C3 
tyres in the proposal for a Regul ation on the general safety of motor vehicles (see Annex 6) 
but for the time being no minimum requirements are laid down for wet grip because of the 
lack of harmonised testing method. The adopti on of Standard Reference Testing Tyres for 
these two categories is under way at ISO level
48 and should be ready by 2010. Transposal at 
UNECE level and adoption of wet grip minimum requirements are expected at the same time. 
ENTR’s objective is to trans pose minimum requirements governing wet grip for C2 and C3 
tyres into EU law as soon as they are adopted at UNECE level, i.e. before the implementation of external rolling noise minimum requirement s for C2 and C3 tyres (by October 2012/16). 
The adoption of a single-labelling scheme fo r RR with minimum requi rements for wet grip 
and external rolling noise could therefore be possi ble by October 2012. 
5.5.2. Design of a Banding Scheme for C2 and C3 Tyres and Expected Market 
Transformation 
It has been argued by some stakeholders that there was no need for RR labelling of C3 tyres 
on the grounds that they are sold to profe ssionals who already have all the information 
necessary for their purchasing decision. A labelling scheme w ould therefore not bring any 
added value. This is objected to by road transport companies themselves, including their 
European federation, the International Road Tran sport Union, and is also contradicted by the 
current state of the market (showing a large ra nge of RR variation). Since “costs per km” is 
one of the first parameters road transport companies want to optimise, if there were indeed no barrier to the deve lopment of fuel efficient tyres, the range in RR tyre performance of C3 
tyres would be much narrower (see more  in-depth analysis in Section 5.1.1.3). 
                                                
 
48 Wet grip is evaluated on a relative performance basi s compared to a Standard Reference Testing Tyre 
(SRTT). 
 
EN 37   EN Based on the same criteria as for C1 tyres, the state of the art of  C2 and C3 tyres was 
estimated respectively at around 5.5kg/t49 and 4 kg/t at affordable production costs. With the 
same calculations as in the preceding sections , the following market transformation due to 
labelling can be expected. The same market tr ansformation path as for C1 tyres is assumed. 
This is likely, however, to be a conserva tive assumption since fleet managers are 
professionals and will have the know-how as well as stro nger incentives to reduce fuel 
expenditure in their total running costs. This is confirmed by the fact that tyres on average 
account for only 6% of total running and main tenance costs compared to 80% for fuel. 
Table 9: Possible Grading Scheme and Consum er Benefits in 2012 per Set of 4 C2 Tyres 
(Winter and Summer, VAT incl.) for moving from Band F to any Other Band 
Source: [EPEC 2008] 
                                                 
49 For C2 tyres designed to be fitted on vehicles above 3.5t.  A B C D E F G 
RRC 5.5 to 6.5 6.5 to 7.5 7.5 to 8.5 8.5 to 9.5 9.5 to 10.5 above 10.5 / 
Price premium 45.2 31.2 21.2 13.6 6.4 0 / 
Total fuel savings50 460 368 276 184 92 0 / 
Payback period51 
(months) 2.4 2 1.8 1.7 1.5 0 / 
CO 2 g/km savings 22.5 18 13.5 9 4.5 0  
Market share in 2004 0% 0% 5% 18% 36% 41% / 
in 2020 (slow pace) 7% 24% 39% 27% 0% 0% / 
In 2020 (fast pace) 45% 23% 21% 10% 0% 0% / 
Baseline scenario in 
2020 0% 1% 14% 84% 0% 0% / 
 
EN 38   EN Contrary to what was done for C1 tyres and C2 tyres, Table 10 for C3 tyres shows the 
calculation of fuel savings and payback period star ting from band D. This is to reflect the fact 
that the market is segmented52. There is a distinction, for instance, between highway and 
motorway use and between steer, drive and trailer axles. Not all tyres may be substituted so that transport companies will rarely have the choice of buying tyres in the whole RR range of 
the C3 market. It is agreed, however, that a 1kg/t reduction for C3 tyres means 5% fuel 
savings which at a diesel price of €1.02/l (i ncluding tax, assuming that 100% of heavy-duty 
vehicles run on diesel) for an annual mileag e of 60 000 km means an €800 saving per year. 
This leads to very sign ificant fuel savings, a 3kg/t reduction in RR for a truck for example 
will give a cumulated fuel saving of €3 800 a ssuming an average tyre lifetime of 100 000 
km (which is very conservative, most tyres last more than 200 000 km). 
The table below has bands with 1kg/t width in or der to give an indicativ e estimate of market 
transformation. It could also be possible for C3  tyres to make a distinction between traction 
(drive axle) and normal tyres (ste er and trailer axles) as in th e proposal for a Regulation on the 
general safety of motor vehicles (COM(2008) 316). The RR measured value (as suggested in 
[VTI 2008]) could also be displa yed together with the fuel effi ciency classes. In any case, 
narrower bandwidth should be defined for a gr ading scheme for C3 tyres, pending on the 
accuracy of the testing method, in order to refl ect the significant impact on fuel savings of a 
given reduction in RR. 
                                                                                                                                                        
 
50 Assumption: fuel price at 1.28 €/l incl. VAT. 
51 Assumption: 40 000 average total mileage (in km) over 1.8 years. 
52 See Annex 5 of [EPEC 2008], Section 5.4., for an estimate of price premium and related payback 
periods. 
 
EN 39   EN Table 10: Possible Grading Scheme and E nd-User Benefits in 2012 per Set of 10 C3 
Tyres (Winter and Summer, VAT excl., Fuel Tax incl.) for Moving from Band D to 
Higher Bands 
Source: [EPEC 2008] 
As for C1 tyres, the two tables clearly show th at a labelling scheme fo r C2 and C3 tyres is 
expected to speed up the market take-up of fu el-efficient tyres compared to the baseline 
scenario. 
5.5.3. Inclusion of Wet Grip in a L abelling Scheme for C2 and C3 Tyres 
There are no reliable data, nor endorsed wet gr ip measurement methods for C2 and C3 tyres, 
that would support the extension of  wet grip grading to these ty re classes. The tyre industry 
considers that the inclusion of wet grip in a labelling scheme is not appropriate for C3 tyres 
because wet grip varies too much with the load  of the trucks (see Annex 1). Road transport 
companies on the contrary seem to be in favour , but emphasise that it is not a priority (as 
opposed to RR and external rolling noise). It is  proposed for the time being not to consider 
wet grip grading for C2 and C3 tyres. This ma y be introduced into tyre labelling at a later 
stage once testing methods become available. 
5.5.4. Inclusion of External rolling noise in  a Labelling Scheme for C2 and C3 Tyres 
Some stakeholders have emphasised that mini mum requirements on noise  in the proposal for 
a Regulation on the general sa fety of motor vehicles (COM(2008) 316) have been 
                                                 
53 Assumption: fuel price at 1.28 €/l in cl. VAT, for a mileage of 100 000 km. 
54 Assumption: 100 000 average total mileage (in km) over 1.6 years (19 months).  A B C D E F G 
RRC below 4 4 to 5 5 to 6 6 to 7 7 to 8 above 8 / 
Price premium 1080 650 310 0 / / / 
Total fuel savings53 3780 2520 1260 0 / / / 
Payback period54 
(months) 5 5 5 0 / / / 
CO 2 g/km savings 99 66 33 0 / /  
Market share in 2004 1% 8% 23% 33% 23% 10% / 
in 2020 (slow pace) 11% 28% 43% 14% 3% 0% / 
In 2020 (fast pace) 39% 35% 21% 4% 1% 0% / 
Baseline scenario in 
2020 3% 19% 51% 22% 6% 0% / 
 
EN 40   EN downgraded in comparison to the initial proposal  put forward in the FEHRL study for C2 and 
C3 tyres, and the implementation date postponed to 2016 for existing tyre  types. They believe 
that this makes the inclusion of external roll ing noise for C2 and C3 tyres in a labelling 
scheme more necessary (see minutes of the 26 May workshop in Annex 2). 
Possible Design of a Low-Noise Mark for C2 and C3 Tyres 
Figure 8 below representing the st ate of the market in 2007 show s that a low-noise mark for 
tyres below 3dB will request further innovations but seems feasible in the short run and will 
provide incentives for further improvements. It  is suggested for C2 and C3 tyres that the 
external rolling noise measured value is also displayed to facilitate the design of targeted 
policies at Member State or local  level in favour of low traffi c noise (see costs of testing in 
Section 6.2.1.3.). 
Figure 8: Distribution of Tyre Market According to External rolling noise 
 
 
Source: T&E contribution to the stakeholder consultation. 
To sum up, there is clear eviden ce that extending the grading scheme for RR to C2 and C3 
tyres would be beneficial. The same conclusion  as for C1 tyres in Section 6.5.2 is valid for 
external rolling noise, but inclus ion of a low-noise mark or si mply the external rolling noise 
measured value would be an option. 
5.6. Option 6: Economic Instruments and Public Procurement 
Market transformation can be accelerated by publi c procurement specifications and incentives 
in line with the Community guidelines on State aid for environmental protection55, through 
either quotas, specification of minimum bands above which public  authorities may buy tyres, 
or guidelines (e.g. incentives to include in-use costs in the award criteria such as in the 
proposal for a Directive on the promotion of clea n and energy-efficient road transport vehicles 
(COM(2007) 817)). 
                                                 
55 OJ C 82, 1.4.2008, pp. 1–33. 
 
EN 41   EN The Action Plan on Sustainable Consumpti on and Production and Sustainable Industrial 
Policy (COM(2008) 397/3) suggests that impl ementing measures of the revised Energy 
Labelling Directive 1992/75/EC  setting the banding schemes for “energy-related products” 
should identify one of the labelling classes as  a level below which public authorities (1) 
would not be allowed to procure and (2) will not be allowed to set fiscal incentives. The 
following criteria are given for the designation of this level: 
(1) It should be based, as a minimum, on the least life-cycle costs taking into account 
intended use of the product (this may be very difficult to predict at EU level for tyres, 
depending on vehicle use). 
(2) It should ensure an adequate  level of competition in the market, taking into account 
product availability. 
There are already some precedents for this approach such as (1) in the Regulation on a 
Community energy-efficiency la belling programme for office equipment (Regulation (EC) 
No 106/2008) which requires EU institutions  and central Member State government 
authorities to use energy-efficiency criteria  no less demanding than those defined in the 
ENERGY STAR programme when purchasing o ffice equipment; or (2) in Directive 2005/55 
(Article 6) relating to the measures to be take n against the emission of gaseous and particulate 
pollutants from compression igniti on engines for use in vehicl es, which provides a framework 
for the implementation of fiscal incentives in Member States. 
Economic or market-based instruments56 may indeed boost market change by, for example, 
decreasing levies on energy-effici ent tyres and increasing it on worst-performing tyres as is 
being done in France and the UK in  relation to vehicles (indexi ng taxes to vehicle emissions 
as reported in the car labelling scheme). This  would improve price sign als by placing a value 
on the external costs and benefits. This may be especially effective on the fleet market, which accounts for up to 50% of the passenger car ma rket in some Member States, since fleet 
owners do not pay fuel bills, and may therefore have less interest in buying more fuel efficient tyres. 
A labelling scheme could be also instrumental for cities, companies and public authorities in 
the design of proactive purchasing policy or fiscal incentives, and would be in line in this 
sense with the Green Paper on market-based in struments for environment and related policy 
purposes (COM(2007) 140). 
If the same approach were followed as the one proposed in the Action Plan on Sustainable 
Consumption and Production and Sustainable I ndustrial Policy for C1 tyres, band B or C 
should be set as the minimum level for public procurement. Band A provides for the highest 
fuel savings, but today band B to C would seem  appropriate, taking into consideration the 
necessity to ensure an adequate level of comp etition. It may indeed happen that only a few 
tyre producers may be able to produce tyre s under 7kg/t (or 6.5kg/t depending on the grading 
alternative chosen), so ther e may be some concerns about free competition and product 
availability in the A band for public procuremen t procedures. Since fuel savings may not be 
achieved in a stop-and-go driving  cycle
57, exemptions in public procurement procedures may 
be provided for such specific driving. 
                                                 
56 See Green Paper on market-based instrument s for environment and related policy purposes 
(COM(2007) 140). 
57 This is mainly due to the fact that RR varies with tyre operating temperature: a cold tyre has on average 
30% more RR. 
 
EN 42   EN Estimates of the total number of public pr ocured replacement tyres made by [EPEC 2008] 
(Table 11) show, however, that they constitute a small share of the replacement market and 
are therefore unlikely to have a signif icant impact on market transformation. 
Table 11: Total Number of Public Procured Replacement Tyres (2005)  
 Passenger 
Cars (C1) Light-Duty 
Vehicles (C2) Trucks and 
Buses (C3) Total 
Total Replacement Tyres 173 000 361 000 281 000 815 000
Share of Total Replacement Market 0.1% 2% 2% 0.3% 
Source: [EPEC 2008] estimates. 
6. C OMPARING THE OPTIONS  
6.1. Qualitative Assessment 
 
EN 43   EN  
 Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 
Market 
take-up of fuel efficient tyres + Bans worst tyres from the 
market and progressively improves (i.e. decrease) average RR 
– Does not harness all 
potential benefits from fuel efficient tyres + Information on 
RR only Æ faster 
market take-up of fuel efficient tyres 
 – Lower market 
take- up of fuel efficient tyres 
+ May avoid 
concerns of consumers that a fuel-efficient tyre, i.e. lower rolling resistance, implies lower safety  – Lower market 
take- up of fuel efficient tyres – Lower market 
take- up of fuel efficient tyres + Speeds up 
market take-up 
– Matter for 
subsidiarity: better dealt with at Member State or local level depending on national preferences 
Market failure – Does not address the 
market failure on the replacement market + Removes the market failure caused by lack of information  
R&D + Improvement on RR 
driven by the OE market with spillover effect on the replacement market  
– No incentives for 
innovation on the replacement market  + Strong incentives 
and rewards for investment in R&D + Strong incentives 
and rewards for investment in R&D 
+ Optimisation of 
wet grip and RR at the same time + Strong incentives 
and rewards for investment in R&D 
+ Optimisation of 
wet grip, RR and external rolling noise at the same time + Strong incentives and rewards for 
investment in R&D 
Safety + Wet grip requirements 
considered satisfactory by all stakeholders – No incentives for 
improvement of wet grip beyond + Incentives to optim ise wet grip beyond 
minimum requirements 
– No information on other safety No specific impact 
expected on road safety / wet grip No specific impact 
expected on road safety 
 
EN 44   EN + Wet grip requirements will 
significantly improve road safety, they will ban 30% of the worst-performing tyre from the market minimum 
requirements parameters: aquaplaning, handling in 
curve, etc. 
+ Possible gain in reduced accident rates 
but impossible to quantify 
– Risk of giving an incentive for unsafe 
driving by those buying an “A” tyre grading not 
considered for the time being given the lack of measurement standards 
Noise – No incentives for 
improvement of external rolling noise above minimum requirements – No incentives for 
improvement of external rolling noise beyond minimum requirements – No incentives for 
improvement of external rolling noise beyond minimum requirements – No evidence as to 
the effect on real traffic noise 
– May not be 
feasible in practice due to test track variation 
+ Relatively low 
noise abatement costs + Noise grading 
may boost innovation and market take-up of low-noise tyres + Noise grading 
would allow public authorities to promote low-noise tyres 
Response to consumer preferences NA + Simple message 
to consumers, raises awareness 
– Does not reflect 
consumer preferences (safety first) + Responds to 
consumer interest in tyres 
– Potential 
difference between TA value and real on-road performance because of vehicle/ tyre interaction – Subjective 
perception of noise does not always reflect the measured values 
– No correlation 
between exterior and interior noise at low frequencies, 
+ Raises awareness NA NA 
 
EN 45   EN 6.2. Aggregated Cost-and-Benefit Analysis 
6.2.1. C1 Tyres – Options 2, 3 and 4 6.2.1.1. Fuel and CO
2 Aggregated Net Savings 
The table below summarises aggregated production costs and benefits due to fuel savings and 
CO 2 reduction in Options 2, 3 and 4 compared to  the reference case over the period 2012-
2020 reported as the net present va lue (NPV) using a discount rate  of 4%. They can therefore 
be considered to be the net added value of implementing a labelling scheme. The calculation 
assumes October 2012 as the date of entry into force of the labelling scheme for simultaneous 
adoption with the proposal for a Regulation on the general safety of motor vehicles 
(COM(2008) 316), but the sub-section on the “inten sity of the measure” considers an earlier 
implementation date. As a reminder, total benefit in Options 3 and 4 is lower than in Option 2 (single-criterion labelling) because of increas ed production costs due to optimisation of both 
RR, wet grip and possibly external rolling noi se, and because of the assumed lower market 
take-up of fuel-efficient tyres ( on the grounds that consumers will  very likely favour wet grip 
over tyre fuel efficiency). 
The calculation encompasses benefits  only from the replacement market . It is assumed 
that car producers already have enough pressu re to reduce the RR of OE tyres (Section 
5.1.1.1) and will not significantly change their be haviour in the event of a labelling scheme. 
However, it is not excluded that a labelling scheme will have a spillover effect on the OE market, as some car producers (further confirme d by ACEA in a bilateral interview) agreed 
that they could use a labelling scheme in their marketing strategies and would benefit from it. 
Total benefit could in this case be sligh tly higher than the estimations below. 
In addition, total benefit in Options 3 and 4 (mu lti-criteria labell ing) is considered the same 
though in reality the benefit from Option 4 should be significantly higher if a monetary value 
were given to noise reduction. According to the FEHRL report, for in stance, a €5.5 billion 
benefit should be added per one  dB reduction per year at EU- 27 level (see S ection 5.4.2). The 
exact benefits due to traffic noise reduction we re not calculated in the framework of this 
impact assessment, as they will depend on e ach road and city, and the number of persons 
exposed to noise
58. 
                                                 
58 See calculation method proposed in the technical annex to the strategy on internalisation of external 
costs of transport (COM(2008) 435). 
 
EN 46   EN Table 12: Cumulated Impact of Energy La belling of C1 Summer and Winter Tyres on 
the EU Economy, NPV of Costs and S avings, 2012-2020, 2008 Prices (VAT excl.) 
 Additional 
Tyre Costs 
(€m, NPV) Fuel Cost 
Savings 
(€m, NPV)Net Cost 
Savings 
(€m, NPV)CO 2 
Savings 
(mill. 
tonnes) CO 2 
Savings 
(€m NPV) Total EU 
Benefit 
(€m NPV) 
Pace of 
Change Slow Fast Slow Fast Slow Fast Slow Fast Slow Fast Slow Fast
Option2 1 042 3 690 2 031 6 915 989 3 224 11 38 208 709 1 198 3 933
Options 3 
and 4 1 653 4 516 1 628 4 320 –25 –196 9 23 167 443 142 247 
Source: [EPEC 2008] GHK estimates base d on unit cost and cost savings and 
estimates of market transformation, values exclude VAT and tax, di scount rate of 4% 
and fuel price at €75/bbl, i.e. 0.61 €/l excl. tax and 1.28 €/l incl. tax. 
Cumulated CO 2 savings translated into g/km would mean between 1.2 (slow pace of change) 
and 4.1 CO 2 g/km (fast pace) under the single-labelling scheme (Op tion 2) and between 1 to 
2.6 CO 2 g/km under the multi-criteria labelling sc heme (Options 3 and 4), which can be 
considered significant as it represen ts almost one fifth of the 10g/km CO 2 savings target by 
2012 formulated in the new integrated strate gy to reduce GHG emissions from passenger cars 
(COM(2007) 19). 
Conclusion 1: The table clearly shows that net benefits in terms of CO 2 reduction and 
fuel savings would be higher for Option 2 in  the event of a single-criterion labelling 
scheme, but Options 3 or 4 may be considered  valid options balancing fuel savings loss 
with marginal safety gains. 
Sensitivity Analysis 
Benefits will depend on fuel prices. Table 13 shows the aver age annual benefit depending on 
fuel prices. The fuel price scenarios are c onsistent with the ener gy outlook published by the 
European Commission up to 203059. 
                                                 
59 European energy and transport: Trends to 2030 – Update 2007 , 
http://ec.europa.eu/dgs/energy_transport/figures/trends_2030_update_2007/energy_transport_trends_20
30_update_2007_en.pdf . 
 
EN 47   EN Table 13: Impact of Energy Labelling of C1  Tyres on the EU Economy, Average Annual 
Benefit, 2012-2020, 2008 prices (sensitivity  analysis to oil price scenario) 
 Total EU 
Benefit (€m) – Scenario 1 (€50/bbl) Total EU 
Benefit (€m) – Scenario 2 (€75/bbl) Total EU 
Benefit (€m) – Scenario 3 (€100/bbl) Range in Total EU 
Benefit Compared to Scenario 2 
 
Pace of Change Slow Fast Slow  Fast Slow Fast Slow Fast 
Option 2 50 157 115 376 179 594 +/–56% +/–58% 
Options 3 and 4 –40 –120 11 18 62 155 +/–463% +/–761% 
Source: [EPEC 2008] based on Eurostat60 Note: scenario 1, fuel price at €50/bbl 
means 0.41 €/l excl. tax and 1.03 €/l incl. tax; scenario 2, fuel price at €75/bbl means 
0.61 €/l excl. tax and 1.28 €/l incl. tax; and scenario 3, fuel price at €100/bbl means 
0.8 €/l excl. tax and 1.53 €/l incl. tax. 
It shows that in the case of a lower fuel pr ice (at €50/bbl) increased production costs may not 
be compensated by fuel savings (if VAT excl uded) in Options 3 and 4. This is, however, 
unlikely to happen given recent trends in fuel prices. 
An estimation of CO 2 abatement costs was also made taking into account different fuel prices 
(Table 14). 
Table 14: CO 2 Abatement Costs (Average Annual) in €/tonne 
 Scenario 1 (€50/bbl) Scenario 2 (€75/bbl) Scenario 3 (€100/bbl) 
Pace of Change Slow Fast Slow Fast Slow Fast 
Option 2 –59 –55 –138 –135 –211 –207 
Options 3 and 4 47 50 –33 –29 –112 –109 
Source: [EPEC 2008]  Note: excludes the economic value of the environmental 
benefits of C02 emissions reduction. 
CO 2 abatement costs are mostly negative except for the lower fuel price in scenarios 1 and 2 
in the event of multi-criteria labelling (Options  3 and 4), but abatement costs in this case are 
still below €50, which can be considered to be re latively effective compared to other measures 
(see Figure 1 in Section 2.1). 
                                                 
60  
http://epp.eurostat.ec.europa.eu/ portal/page?_pageid=1996 39140985&_dad=portal&_schema=PORTA
L&screen=detailref&language=en &product=Yearlies_new_environm ent_energy&root=Yearlies_new_
environment_energy/H/H2/H21/ebc24848 .  
http://epp.eurostat.ec.europa.eu/ portal/page?_pageid=1996 39140985&_dad=portal&_schema=PORTA
L&screen=detailref&language=en &product=Yearlies_new_environm ent_energy&root=Yearlies_new_
environment_energy/H/H2/H21/ebc25360 . 
 
EN 48   EN Intensity of the Measure 
The benefits from the introduction of a la belling scheme two years earlier than 2012, 
according to the [EPEC 2008] calculation (with a 4%  annual discount rate) are equal to 8% of 
the annual average benefit (assuming the benefit of  early implementation is simply the effect 
of avoiding the discount of annual benefits). U nder oil price scenario 2, this ranges between 
€1m in Options 3 and 4/slow pace of change, and €30m in Option 2/fast pace of change. 
It may, however, not be the best option as the ty re industry needs time to invest in testing 
machines – which they will have to do anyway by October 2012 – once the proposal for a Regulation on the general safety of motor vehicles  is adopted (if the implementing date is not 
changed). It therefore seems appr opriate to target a similar date  for implementing the labelling 
scheme. 
6.2.1.2. Administrative Costs Regulatory costs were derived from 
[Europe Economics 2007] which assumed the costs of a 
new Directive to be around €720 000, with additiona l transposition costs in Member States of 
about €4.04 million. Assuming the regulatory cost s are higher for a multi-criteria grading 
scheme, the regulatory costs for all options should lie between €4.76 million and €7.14 million. Given the high transposition costs of  a Directive in Member States, it is 
proposed to adopt a framework directive and th en establish implementing measures under the 
comitology procedure for adaptati on to technological changes. 
Monitoring costs will depend on the type of te st procedure chosen: self-declaration and ex-
post control or declaration with third-party approval, though it is not possible to quantify 
them. 
6.2.1.3. Costs of Testing 
Rolling Resistance (RR) 
RR will be tested according to the future ISO 28580 which is intended to refine the precision 
of the testing methods in prep aration for a grading scheme (s ee Annex 3 for further details). 
The costs of testing rolling resistance are su mmarised in Table 15 based on ETRMA input. 
 
EN 49   EN Table 15: Costs of Rolling Resistance Testing for C1/C2 Tyres 
 Number of Tests per 
Year Average Cost 
per Test Total Annual Cost 
Reference Case – tests 
necessary to show compliance with minimum requirements  400 €260 (250~300) €0.1m 
Grading for C1/C2 3 000 €260 (250~300) €0.8m plus 
annualised fixed cost of €0.3m 
Additional costs of grading compared to reference case (see Box 6)   €1m 
Note: Fixed costs include maintenance and laboratory alignment tests and one-off 
start-up costs or RR grading, estimated to be approximately €2m with an annualised 
cost of €0.3m at 4% discount rate 2012-2020. 
Box 6: In the reference case, the tyre industry will have to  measure the RR of new tyre types 
within the framework of the type-approval (T A) procedure to show compliance with the 
minimum requirements set in the proposal for a Regulation on the general safety of motor 
vehicles. There are ongoing discu ssions on the measuring procedur e to be followed, but it is 
likely that the same approach will be favoured as  for external rolling noise and wet grip: tyre 
families are defined by producers and agreed by TA authorities, with the worst case being 
identified so that it is only n ecessary to measure the worst tyre by a simple pass/no pass test to 
demonstrate the compliance with the minimum re quirement of all the others. This procedure 
has the advantage of reducing the number of te sts to be done and hence the costs of the 
measure. 
This approach, however, cannot be strictly followed for a grading scheme. Tyre producers 
will want to measure more tyres or reduce the range of tyre families in order to optimise the 
grading of each tyre type and size. A grading sc heme will therefore imply a greater number of 
tests and hence higher costs than in the reference case (minimum standards). 
The table shows that annual test ing costs for rolling resistance are approximately €1m (costs 
of grading minus costs for TA testing, whic h will have to be done anyway to prove 
compliance with the minimum requirements governing RR) which means €0.006 per tyre . If 
a more conservative approach is taken, as suming that a labelling scheme with 1kg/t 
bandwidth implies more tests, th e testing costs could rise up to €0.02 per tyre, which is still 
marginal. It is assumed that these costs can be passed on to end-users without any significant 
impact. 
Wet Grip 
Wet grip could be tested according to ISO 23671 (transposed in UNECE Regulation 117) or 
according to a new revised testing method afte r agreement by the tyre industry aimed at 
decreasing the standard deviation of testing me thods and thereby decreasing the risk margin 
for a tyre to be wrongly graded. The costs of wet grip testing are summarised in the table 
below based on ETRMA input. 
 
EN 50   EN Table 16: Costs of Wet Grip Testing for C1/C2/C3 Tyres 
 Number of Tests 
per Year Average Cost 
per Test Total Annual Cost 
Reference Case – tests 
necessary to show compliance with minimum requirements 364 €2 000 
(600~3 800) €0.7m 
Grading for C1 tyres 1 100 €2 311 
(800~4 017) €2.5m plus fixed cost 
(annualised) of €0.7m 
Grading for C2 and C3 tyres   €0.4m 
Additional cost of grading compared to reference case (see Box 7)   €2.5m 
Note: Fixed costs include maintenance and laboratory alignment tests and one-off 
start-up costs or RR grading, estimated to be approximately €4.6m with an 
annualised cost of €0.7m at 4% discount rate 2012-2020. 
The table shows that annual testing costs for we t grip are approximately €2.9 million (costs of 
grading minus costs for TA testing, which will have to be done anyway to prove compliance 
with the minimum requirements, added to initial start-up costs spread e qually over the years) 
which means €0.01 per tyre sold . It is assumed that these costs can be passed on to end-
buyers without any si gnificant impact. 
External Rolling Noise 
Giving information on external rolling noise is li kely to entail only marginal extra costs given 
that it has to be measured alre ady according to the TA legisla tion on tyres (following the ISO 
13325 measuring methods, transposed in UNECE  Regulation 117), and a low-noise mark 
would imply the same “pass/no pass” test procedure. 
Conclusion 2: Costs of testing per tyre sa le can be considered to be marginal. 
6.2.1.4. Costs of Display of the Labelling Scheme 
The costs of the display of the labelling scheme  will depend on the way the 
label/information would be provided. Possibl e measures and relate d cost estimates are 
presented in the table below. The setting-up of a database has not been included in the table. 
Given its complexity and the bu rden of properly managing a data base as well as the principle 
of proportionality of costs and related liability issues, it is proposed not to include it in a 
legislative proposal but to leave it up to subsidiarity and consumer organisations. 
 
EN 51   EN Table 17: Costs of the Disp lay of the Labelling Scheme 
Type of communication Costs Assessment 
Mandatory display of the 
measured value/class in technical documentation, tariffs and/or websites made publicly available Marginal 
Æ will add only one line on 
existing advertising tools and can be easily included in existing communication practices) Would convey the 
information to consumers and retailers before sale 
Stickers on tyres tread €10m per year, i.e. €0.04 per 
tyre sold (C1/C2), according to ETRMA estimates - Would contribute to the 
visibility of varying tyre performance in RR and to awareness-raising 
- Especially adapted to 
tyre dealer shops (see Figure 3) 
Moulding on tyre sidewall €13 per mould if implemented 
for new tyre types only (see 
Box 6) Guarantees the reliability  
of the displayed 
information on tyre 
quality and makes control on compliance easier, but would be difficult for non-professionals to read 
Mandatory display of the information on tyre grading (class) with the bill provided to the consumers or end-users Marginal Allows for greater 
transparency of the tyre grading 
Mandatory display of the information on tyre grading on catalogues and advertising for distance selling Marginal Will be essential in 
reaching consumers/end-users before
 their 
purchase decision 
Conclusion 3: The real added value of mouldi ng the information on the tyre sidewall is 
uncertain – the information may be too difficul t to understand and to read. It is 
proposed to make the information mandatory in all catalogues and advertising tools and 
possibly to add a sticker on tyres' tread (except for the OE  market, e.g. car showrooms). 
6.2.1.5. Potential Impact on Import/Export 
The labelling scheme is likely to have no si gnificant impact on the import of tyres, though 
import tyres were found most of the time to  have low RR but unsa tisfactory wet grip 
performance. Underperforming tyres (30% of the market under the current proposal 
(COM(2008) 316)) will be banned anyway as a result of the minimum requirements set out 
for type approval. It is likely that a proporti on of low-income consumers will continue to buy 
budget tyres (accounting for 21% of the total passenger car replacement market) with or 
 
EN 52   EN without a labelling scheme as they probably have no other choice. In  addition, a labelling 
scheme, providing a level playing field for all, will allow new entrants to demonstrate that 
they produce well-performing tyres. A labelli ng scheme in that sense will reduce entry 
barriers due to brand reputation. 
The market take-up of fuel efficient tyres will also have an impact on th e chemical industry as 
they are produced with silica instead of carbon black. Since si lica and carbon black are both 
produced in Europe61, it is likely to have no significa nt impact on external trade. 
6.2.2. C2 and C3 Tyres – Option 5 
6.2.2.1. Fuel and CO 2 Net Savings 
Table 18 summarises total fuel and CO 2 savings due to Option 5. The monetary value of 
reduced traffic noise has not been included. Total benefits in the case of external rolling noise 
inclusion should therefore be deemed higher than the values given below. 
Table 18: Cumulated Impact of Energy Labelling of C2 and C3 Tyres (Summer and 
Winter) on the EU Economy, NPV of Co sts and Savings, 2012-2020, 2008 prices (VAT 
excl.) 
 Additional 
Tyre Costs 
(€m, NPV) Fuel Cost 
Savings 
(€m, NPV) Net Cost 
Savings 
(€m, NPV)CO2 
Savings 
(mill. 
tonnes) CO2 
Savings 
(€m NPV) Total EU 
Benefit 
(€m NPV)
Pace of Change Slow Fast Slow Fast Sl ow Fast Slow Fast Slow Fast Slow Fast
Single 
Labelling C2 159 314 636 1 202 476 888 4 7 69 130 545 1 018
Single 
Labelling C3 704 2 308 1 587 4 920 883 2 611 9 28 171 530 1 054 3 142
Total (C2/C3) 863 2 622 2 223 6 122 1359 3 499 13 35 240 660 1 599 4 160
Source: [EPEC 2008]  Note: GHK estimates based on unit cost and cost savings and 
estimates of market transformation, values  exclude VAT and tax., discount rate of 
4% and average fuel price of diesel at €75/bbl, i.e. 1.02 €/l incl. tax. (assumption that 
100% of light- and heavy-duty vehicles run on diesel). 
Conclusion 4: Total cumulated net fuel savings and CO 2 benefits for C2 and C3 tyres 
over the period 2012-2020, between €1 599m and €4 160m, would add si gnificantly to the 
total benefit for C1 tyres, between €142m and €3 933m (depending on the options and pace of change). This is because a given fuel  savings percentage for commercial vehicles 
or trucks and buses is much higher in absolute terms than  the same percentage fuel 
savings on smaller cars (consuming far less by  definition). Option 5, the extension of a 
labelling scheme to C2 and C3 tyres , is therefore highly recommended. 
                                                
 
61 Chemical Economics Handbooks  on Carbon Black and Silica, SRI consulting, 2005. 
 
EN 53   EN Sensitivity Analysis 
Table 19: Impact of Energy Labelling of C2  Tyres on the EU Economy, Average Annual 
Benefit, 2012-2020, 2008 prices (sensiti vity analysis to oil price) 
 Total EU 
Benefit (€m) 
– Scenario 1 
(€50/bbl) Total EU 
Benefit (€m) 
– Scenario 2 
(€75/bbl) Total EU 
Benefit (€m) 
– Scenario 3 
(€100/bbl) Range in Total EU 
Benefit Compared to 
Scenario 2 
Pace of Change Slow Fast Slow  Fast Slow Fast Slow Fast 
Single Labelling (C2) 32 57 52 93 71 129 +/–38% +/–39% 
Single Labelling (C3) 40 115 85 254 130 393 +/–53% +/–55% 
Source: [EPEC 2008] 
Table 20: CO 2 Abatement Cost (Average Annual) 
 Scenario 1 
(€50/bbl) 
(€/t CO 2) Scenario 2 
(€75/bbl) 
(€/t CO 2) Scenario 3 (€100/bbl) 
(€/t CO 2) 
Pace of Change Slow Fast Slow Fast Slow Fast 
Single Labelling (C2) –107 –105 –183 –181 –259 –257 
Single Labelling (C3) –44 –39 –120 –115 –196 –191 
Source: [EPEC 2008] 
CO 2 abatement costs are found to be nega tive in all fuel price scenarios. 
6.2.2.2. Further Costs Administrative costs and monitoring costs s hould obviously be higher than for labelling C1 
tyres only. Costs of testing RR for C2 tyres were estimated between €0.01 and €0.06 per tyre 
(Table 15). For C3 tyres, no estimates were provided by ETRMA, but the average cost per 
tyre can be assumed to be similar to that for C1 and C2 tyres, with an aggregated cost proportional to the C3 market share (i.e. 5% of €1m which is equal to €0.05m per year). 
Regarding the display of the labelling scheme fo r C2 and C3, it is proposed only to make 
the grading available in catalogues, websites and advertising tools as this market is 
addressed to professionals . It should be sufficient to make the information available for end-
buyers without further communication tools. The co st of display of the labelling scheme can 
therefore be considered marginal. 
6.2.3. Summary 
• Impact on customers:  Customers will benefit from a labe lling scheme as they will have 
the opportunity to objectively compare tyres a nd make an informed choice. Since fuel 
savings exceed the related increase in produc tion costs, they will make increasing net 
savings the higher the grading of the tyres they buy. The imp act assessment shows that a 
multi-criteria labelling scheme (Options 3 a nd 4) provides for lower cost saving than a 
single-criterion labelling scheme  (Option 2) but this can be  considered offset by an 
improved level of wet grip, even  though it is impossible to quan tify the benefits in terms of 
improved road safety. 
• Impact on producers:  Producers will benefit from a higher return on R&D investment, 
though a labelling scheme may increase compe tition and increase pressure towards better-
 
EN 54   EN performing tyres. A labelling scheme will imply higher costs due to testing, stickers and 
display of the labelling scheme via advertis ing tools. Producers are likely to pass on these 
costs to customers, which per tyre sale rema in marginal (not more than €0.1 per tyre all 
included). 
• Impact on the EU Economy : The impact on the EU economy is summarised below. 
Table 21: Impact of Energy Labelling on C 1, C2 and C3 on the EU Economy, Average 
Annual Benefit, 2012-2020, 2008 Pri ces (Oil Price Scenario 2) 
Total Annual  Average EU Net Benefit (€m)  
Vehicle Type Slow Fast 
C1 – Option 2 (Single labelling) 115 376 
C1– Option 3 and 4 (Multi-c riteria labelling) 11 18 
C2 – Option 5 (Dual Labelling RR/noise) 52 93 
C3 – Option 5 (Dual Labelling RR/noise) 85 254 
Total Option 5 226 591 
Source: [EPEC 2008] 
Options 3 and 4, multi-criteria labelling scheme  for C1 tyres makes for a slower annual 
benefit than Option 2 because of higher prod uction costs and the assumed lower market 
transformation. In fuel savings, however, the difference between Option 2 and Options 3 and 
4 is less significant (Table 22 and Figures 8 and 9). 
Table 22: Average Annual Fuel Savings 
Annual 
Average Fuel 
Savings 
 (mill. litres) Average 
Annual Fuel 
Savings (Mtoe)Equivalent to x 
vehicles less per year 
on EU roads Share of new 
vehicle 
registrations in 
Europe (2006) 
Tyre class Slow Fast Slow Fa st Slow Fast Slow Fast 
C1 (labelling RR) 326 1 104 0.3 1.02 253 420 858 210 2% 6% 
C1 (multi-criteria label) 260 694 0.24 0.64 202 114 539 490 1% 4% 
C2 (labelling RR) 99 181 0.1 0.18 36 000 65 818 2% 3% 
C3 (labelling RR) 226 701 0.22 0.69 14 504 44 987 3% 10% 
Total (Option 5) 585 1576 0.56 1.51 252 620 650 295   
Source: [EPEC 2008]  Note: Assumption for C1 tyres (passenger car fleet): 50% fuel, 
50% diesel. Assumption for C2 and C3 tyres (vans, trucks and buses): 100% diesel.  
 
EN 55   EN Figure 9: Fuel Cost Savings (€m) for the EU Economy for the La belling Options in 
C1/C2/C3 Replacement Market (Slow Pace) – Oil Price Scenario 2 
 
Source: [EPEC 2008] 
Figure 10: Fuel Cost Savings (€m) for the EU Economy for the Labelling Options in 
C1/C2/C3 Replacement Market (Fast Pace), Source: [EPEC 2008] 
 
Source: [EPEC 2008] 
The impact on the EU economy proves to be gr eater in Option 2 (single-criterion labelling 
scheme) than in Options 3 and 4 due to fast er market transformati on, however Options 3 
and/or 4 might be the preferred option due to sa fety gains (see Section 6.1). In any case, the 
impact assessment clearly shows that Option 5, ex tension to C2 and C3 tyres, provides the 
most significant benefits. 
 
EN 56   EN • Impact on society  (health – safety and ex ternal rolling noise – a nd security of supply): A 
labelling scheme ensuring market take-up of  fuel efficient tyres would reduce fuel 
consumption and hence have a positive effect on security of supply. In total for Option 5, all tyre classes (C1/C2/C3) included, the av erage annual fuel savi ngs over the period 2012-
2020 are estimated at between 0.56 and 1. 51 Mtoe, which exceeds the annual oil 
consumption of Latvia (in the fast-pace-of-change scenario). 
A multi-criteria labelling scheme including wet grip would also have a positive impact on 
safety, which is likely to offset the additional costs of tyre purchase. Option 4, inclusion of 
external rolling noise in a labell ing scheme for tyre fuel effici ency and wet grip, does not give 
clear evidence in terms of effectiveness and its assessment will depend on the subjective and 
political weight attached to traffic noise reduction. 
• Impact on the environment: A labelling scheme is a win- win policy – it will generate 
both economic and environmental benefits ev en in the most conservative scenario. In total 
for Option 5, CO
2 savings from all vehicle types per year ranges from 1.5m tonnes to 
4m tonnes , which is equivalent to removing 0.5m to 1.3m passenger cars from EU roads 
per year (equal to from 3% to 8%  of new passenger cars per year)62. 
The table below assesses each policy option compar ed to the initial policy objectives defined 
in Section 3. 
Legend 
Very Positive +++ 
Positive ++ 
Slightly Positive + 
Negligible or No 
Impact 0 
Slightly Negative - 
Negative - - 
Very Negative - - - 
 
                                                 
62 It is also worth emphasising that  life cycle analysis shows that L RRTs will have no adverse impact on 
the environment. First, the greatest environmental impact (86% of total impact) of a tyre occurs during 
its use phase. Second, the partial substitution of bl ack carbon by silica will reduce the environmental 
impact of tyres because carbon  black, which is produced from fossil fuel, has a higher CO 2 footprint. 
 
EN 57   EN Table 23: Summary Assessment of Policy Options 
 General policy objec tive Specific objective Operational 
objective 
 Reduce 
CO 2 and 
pollutants emissions Promote 
fuel 
efficiency Promote 
competitiveness 
of the tyre 
industry Promote market 
take-up of fuel-
efficient tyres Drive 
investments in 
R&D towards 
environmentally 
friendly tyres Maintain other 
parameters at 
least at the same 
level Provide easy-to-
understand 
information to 
consumers/ 
overcome market 
failure Administrative 
burden 
Option 1 + + 0 -- - 0 -- 0 
Option 2 ++ ++ ++ ++ ++ 0 +++ - 
Option 3 + + +++ + + +++ 
exceeds 
objective  ++ -- 
Option 4 + 
same as 
Option 3 + 
same as 
Option 3 +++ + 
same as Option 
3 + 
same as Option 
3 + 
depends on 
national 
preferences and 
feasibility ++ -- 
Option 5 +++ +++ +++ ++ ++ +++ ++ -- 
Option 6 + +  ++ will speed up
market 
transformation + + + --- 
 
 
EN 58   EN Conclusion 5: Summary Table 23 shows that Option 5 should be the preferred option 
with a labelling scheme for C1 tyres on tyre  fuel efficiency including wet grip and a 
labelling scheme for C2 and C3 tyres on RR. The impact assessment was unable to find clear evidence in favour of including external rolling noise . The decision will mainly 
depend on the precision and availability of te sting methods (problem with test track 
variation) and the subjective weight given to traffic noise reduction. 
7. M
ONITORING AND EVALUATION  
The main monitoring element will be the tests carried out for new product grading. 
Monitoring of the effects should be done via ma rket surveillance by Member State authorities 
ensuring that the grading of tyres is truthful. An effective market shift towards the upper band 
will be the main indicator of progress toward s market take-up of fuel-efficient tyres (and 
possibly wet grip). 
The appropriateness of scope, definitions, concept and possible trade-offs will be monitored 
via ongoing dialogue with stakeholders and Memb er States. The main issues for a possible 
revision of the proposed labelling scheme are: 
– Appropriateness of an absolute grading sche me – seeing whether tyres with a smaller 
outside diameter manage in practice to make it into the “A” class. 
– Possible adverse impact on tread wear. 
– Necessity to revise the banding scheme in  line with technological improvements. 
– Development of a more precise information scheme covering safety which may include, if 
proven necessary, safety parameters other th an wet grip, namely road-holding ability, 
directional control, deceleration ability on wet and dry surfaces at higher speed and 
aquaplaning behaviour. 
– Implementation of new minimum requirements governing RR, wet grip and/or external 
rolling noise. 
Revision and adaptation to technical progress (e.g. availability of suitable measurement or 
testing standards, upgrading of classes fo llowing market evolut ion, etc.) could be 
implemented through comitology. 
Taking into account the time necessary for colle cting, analysing and complementing the data 
and experience related to implementation of th e labelling scheme and to assess technical 
progress, it would be possible to  present a review of the main elements of the framework five 
to eight years after entry into  force of a labelling scheme. 
Annex 1: Minutes of the Technica l Expert Group Meeting – 21 April 
Annex 2: Minutes of the Workshop – 26 May Annex 3: Relative versus Absolute Grading Annex 4: Sample of Labelling Scheme Annex 5: Economic Data Relevant for the Impact Assessment Annex 6: Minimum Requirements on Tyre de fined in the Proposal for a Regulation on 
the general safety of motor vehicles (COM(2008) 316) 
 
EN 59   EN Annex 1: Minutes of the T echnical Expert Group Meeting – 21 April 
 EUROPEAN COMMISSION 
DIRECTORATE-GENERAL FOR ENERGY AND TRANSPORT 
 
DIRECTORATE D – New and Renewable Energy Sources, Energy Efficiency & Innovation 
Energy efficiency of products & Intelligent Energy – Europe  
 
 
Brussels, 15.05.2008 
TREN/D3/AC D(2008)  
Final Minutes of the expert gr oup meeting on tyre labelling – 21 April 2008 
Attendees : Johannes-Josef BAUMHÖFER (Continen tal), Alix CHAMBRIS (DG TREN), 
Fazilet CINARALP (ETRMA), Georges DI MITRI (Michelin), Simone FALCIONI 
(Bridgestone), Bernd HARTMANN (Continental) , Stefan KÖPEEN (Good Year), Jean-Paul 
LAMBOTTE (Good Year), Christophe PE NANT (Michelin), Adarsh VARMA (GHK) 
An expert group meeting took place on 21 April to reply to technical questions in preparation 
for the workshop on tyre labelling scheduled fo r 26 May. The discussion was divided into two 
parts: one on rolling resistance a nd tread wear, the other on wet grip. 
1. Working document on absolute vers us relative grading and tread wear 
-see original working document in annex A below  
1.1 Assessing the relevancy of a relative grad ing scheme for rolling resistance versus 
absolute grading (questions 1 to 3) 
A relative grading scheme would make sense onl y if there is a proven correlation between 
rolling resistance coefficient (RRC) and other pa rameters such as external diameter (OD) 
and/or load index (LI). 
The tyre industry position was that there was in deed a correlation for C1 and C2 tyres but that 
it was too weak to justify a relative grading sc heme, with some disagreement from one of the 
tyre manufacturers (answer to Q1). For C3 tyres, no correlation could be found between RRC 
and OD or LI. 
The discussions could not provide enough evidence against a relative grad ing scheme, with all 
data provided showing the existence of a correla tion even if the regression coefficient (R2) 
was low. In addition more accurate measurem ent for RR would increase the significance of 
correlations between RRC and OD or LI (Q2). 
A relative grading scheme would have two advantages: 
• It would provide equal incentives to impr ove RRC for all tyre dimensions. As the RRC 
decreases when the tyre external diameter or  load index increases, an absolute grading 
scheme would make it easier for bigger tyres to  be better graded, so that the incentives for 
upgrading products would be la rger for smaller tyres. 
• It would guarantee that consumers will find A tyres in all tyre dimensions. 
 
EN 60   EN The advantage of an absolute grading scheme was the simplicity of the scheme. 
It was agreed that the tyre industry would work on the design of a relative grading scheme for 
C1 and C2 tyres to enable a proposal to be made before the workshop due on 26 May (Q3 ). 
1.2. Assessing the trade-off between RR and tread wear (questions 4 –6) 
The tyre industry agreed unanimously that the market was self-regulating as regards tread 
wear, so that it was not necessary  to provide information on tread wear in a labelling scheme 
(Q4). In addition to this, existing testing met hods would not allow a satisfactory information 
scheme for tread wear (Q5): there was agreemen t that the only testing method available, the 
one defined in the US UTQG (Uniform Tyre  Quality Grading System), was totally 
unsatisfactory, and that the costs of testing w ould be too high for a labelling scheme to be 
cost-effective on this specific tyre parameter. 
Figures showed no trade-off betwee n RR and tread wear on C1 tyre s, but one on C2 tyres, and 
a clear trade-off between wet grip and tread wear  for both C1 and C2 tyres. As a grading of 
wet grip may be introduced, an adverse effect on tread wear could not  be excluded, but the 
industry still believed that, for the time being, no further measure was necessary as no tyre 
manufacturer would take the risk of losing market share, knowing th at tread wear was a 
parameter consumers could clearly assess wh en they have to replace them (Q6). 
2. Working document on tyre safety and wet grip grading 
-see original working document in annex B below  
2.1. Assessing the relevance and feasibility of a grading on wet grip (questions 1 to 2.2 
and 5 to 7) 
Tyre experts were unanimous about the fact that  a grading scheme of RR alone would have an 
adverse effect on wet grip above the minimu m requirement set for 2012 according to UNECE 
Regulation 117 and the draft propos al on the general safety of motor vehicles. The objective 
of the labelling scheme should therefore be to  give incentives for optimisation of both RR and 
wet grip (Q1 and Q2.2). 
The experts agreed that the range of tyre pe rformances on wet grip were wide enough for a 
banding scheme for both C1 and C2 tyres pr ovided tests method would allow for enough 
accuracy for a significant number of bands (minimum 15% band width, if not 10%) (Q2.1). 
There was agreement that the accuracy of wet gr ip testing methods could be improved in the 
next 1.5 years within the existing ISO 23671 test for C1 tyres to allow for a grading scheme 
for wet grip  (Q5.1 and 5.2). This would take the form of a testing method defined within the 
profession (a revised ISO method  on wet grip would take at least three years.) No test 
methods were currently available on wet grip for C2 tyres as an SRTT still needed to be 
adopted at ISO level, but it should be a priority  to adopt a wet grip grading for C2 tyres as 
soon as it became available. 
No figures could be provided on the extra costs of  additional testing due to the introduction of 
a grading scheme. ETRTO would send cost es timations to GHK in the framework of the 
impact assessment study before 30 April (Q6). 
The tyre industry believed that no wet grip grading was necessary for C3 tyres as wet grip 
varied too much according to the load of th e trucks, but no serious  study underpinned this 
statement for the time being. 
 
EN 61   EN 2.2. Assessing the correlation between wet grip performan ce and other tyre safety 
performance (questions 3 & 4) 
Figures showed a good correlation between wet grip performance and other tyre safety 
performance characteristics, namely road-holdi ng ability, directional control, deceleration 
ability on wet and dry surfaces at higher speed and aquaplaning behaviour, with one industry thinking that there may be an adverse relation between wet grip and adherence (dry grip) and 
handling (Q3). According to the expert gr oup, there was no risk in communicating to 
consumers just the wet grip safety parameter (Q4). 
The widening of a grading of wet grip to incl ude other safety parameters should in any case 
be based on a specific impact asse ssment, the tyre industry said. 
3. Other issues discussed 
It was agreed that ETRTO would send estimations of the extra costs of testing necessary for a 
grading scheme regarding RR to GHK as input to their study before 30 April.  
Representatives from ETRTO presented the resu lts of the work going on within the new ISO 
28580, an agreement was found within the ISO work ing group – against the position of one of 
its members – on the use of two tyres for the alignment of testing machines which were considered to be sufficient. Knowing that this result would imply less accurate testing results, 
some of the experts concluded that a 1,5kg/t wi dth should be defined for the grading scheme. 
The question of the width of the bands remain ed open as long as no evidence was provided on 
the real increase in costs for mo re accurate tests. It was clear that the success of a banding 
scheme was directly linked to the differentiati on it provided to consumers regarding products. 
Annex A: Working Document on rolling resistance and tread wear 
Working document –expert group meeting on rolling resistance / absolute versus 
relative grading and tread wear -21st of April 2008 
The European Commission has consistently, within the existing labelling directive on 
household appliances, favoured rela tive versus absolute grading63. The rationale behind is to 
allow consumers to compare products which are relevant to them. A person needing to buy a 
big fridge because it has a big family will not change its purchasing decision because smaller fridges obviously consume less energy. The same ma y well be true for tyres as a consumer 
has little choice in the dimension of  the tyres he wants to replace.  
The aim of the expert meeting is to assess the relevancy of this logic for tyres.  
Given the possibility of a trade off between rolling resistance and tread wear, the expert group 
will also be asked to consider this  question in the last section.  
1. Distribution of RRC according to tyre categories 
A public contribution made by Michelin at the IEA in November 2005 gives clear evidence 
that the performance of a tyre in regards RRC is dire ctly linked with its size  (in this case it is 
diameter). This assumption seems to be validated by the Smithers study made in California. Those are the only figures which ar e available for the time being.  
                                                
 
63 For tyres, a relative grading would mean a grading within a particular class of tyre consistent with 
consumer choice largely based on tyre size dimensions as opposed to absolute grading across the whole 
tyre output. 
 
EN 62   EN • The following graph from Domini que Aimon (Michelin) presenta tion clearly shows that 
bigger tyres demonstrate a mean RRC lower than smaller tyres. An absolute grading in that 
case (horizontal bands on the graph) would a llow unfair comparison between tyres with no 
small tyres performing in the A grade and no bigger tyres in the G grade.  
 
Source: Dominique Aimon (Michelin), Suppo rting the development of Low Energy 
Tires, slide 7,  
http://www.iea.org/dbtw-wpd/Textbase /work/2005/EnerEffTyre/aimon2.pdf   
Bruce Lambillotte (Smithers Scientific Services) presentation seems to confirm this statement 
(slide 33, see link bellow) but s hows that load index may also  be a relevant factor for 
differentiation (slide 35).  
Source: Bruce Lambillotte, Task 4 Rolling Re sistance Testing: California Energy 
Commission's Fuel Efficient Tire Program , Workshop on the Fuel Efficient Tire 
Program, Smithers Scientific Services, 07/12/2007, http://www.energy.ca.gov/transportati on/tire_efficiency/documents/2007-12-
07_workshop/presentations/Lambilotte_Bruce_Task%204%20Rolling%20Resistanc
e%20Testing.pdf  
Q1: Do you agree with these assumptions?  
Apparently, the relationship between RR and tyre outside diameter (OD) is a function of the 
accuracy of the RR tests. An accuracy of testin g methods with a confidence interval of ±0.5 
kg/t compared to ±0.75 kg/t will  influence the strength of corr elation (size and direction) 
between RR and tyre diameter. 
Q2: How might a more accurate measurement for RR effect the currently estimated 
correlations between RRC and OD? 
2. Relative grading 
If there is an agreement on the variation of RRC according to tyre categories (diameter, LI or 
another parameter), then the que stion of the design of a rela tive grading scheme arises.  ULET2ULET1LET1 Standard 
tires
SULETLET2P metric STH
5,06,07,08,09,010,011,012,013,014,015,0
550 600 650 700 750 800 850 
Diameter (mm)R/RT (kg/t)STH
LET1
LET2
ULET1
ULET2
SULET
REG STHData based on rolling resistance measurements of Original 
Equipment and replacement tires from Europe North America and
 
EN 63   EN Dominique Aimon in its presentation proposes a pparently a simple fo rmula to allow for a 
relative grading. See slide 6: RR thre shold= 0.0000212 (OD x OD) – 0.041 OD +27.7  
Q3: Do you suggest an alternative? Can you agr ee on a formula or a simple way to define 
tyres categories (for example by car si zes) for a relative grading scheme?  
3. Trade off between rolling resistance and tread wear 
Given the fact that it is technically possibl e to reduce rolling resistance at wear costs, a 
grading on rolling resistance alone may have an adverse effect on wear which if significant may even offset the environmental benefit of market transformation towards rolling 
resistance. Market surveys in a ddition show that wear (i.e. "l ong lasting tyre") is the most 
important criteria in consumers purchasing decision.  
Taking into account however that  no testing methods are curren tly available on  tread wear 
and that they may be very costly, it has been argued, that tread wear should not be included on 
a labelling scheme. The rationale behind is that no tyre manufacturer would take the risk to 
decrease the lifetime of a tyre -as he knows that consumers will notice it, even few years after 
the purchasing decision- and hence lose market sh are in the long run. The market could in this 
case be considered as self regulating. 
Q4: Do you agree with this argumentation, i.e. th at the market is sel f-regulating as regards 
tread wear?  
Q5: What are the testing methods available or feasible on tread wear and at which costs? 
Q6: Do you have any suggestion on how to avoid negative effect of promoting low rolling 
resistance tyres on tread wear?  
Annex B: Working Document on wet grip 
Working document –expert group meeting on tyre safety / wet grip grading -21st of 
April 2008  
Given the possibility of a trade off between rolling resistance and safety performances of 
tyres, the tyre industry has requested a labell ing scheme that includes both wet grip and 
rolling resistance. The expert group is to assess the relevance and feasibility of this approach.  
1. Assessing the effect of a grading on rolling resistance on tyre safety performances  
The draft proposal for a Regulation on general safety of motor vehicles foresees that 
minimum requirements on wet grip for C1 tyre s will be mandatory by 2012/14. This will 
guarantee that improvement on improvements on ro lling resistance will not  deteriorate safety 
bellow this minimum requirement which was co nsidered within the UN-ECE working group 
as sufficient (at that time experts considered th at there were no need to increase the safety 
performances of tyres, but only to avoid their deterioration). 
It has been argued however that a grading sche me on rolling resistance could have a negative 
impact on tyre safety performances given the high range of improvement possible above this minimum requirement for wet grip. The rationa le is that a grading scheme on rolling 
resistance alone could push tyre manufacturers to  optimize this parameter at the cost of other 
tyre performances in the absence of releva nt information being given to consumers.  
Q1: Do you agree with this statement, i.e. that  improved rolling resistance alone may have an 
adverse effect on safety (above the mini mum requirement set for wet grip)?  
 
EN 64   EN 2. Labelling tyres on wet grip 
A possibility to address this risk is the incl usion of a grading on tyre safety performances 
together with a grading on rolling resistance.  Considering that th e only testing method 
available today regarding tyre safety performances is on wet grip, a labelling scheme could 
address only wet grip in a first stage, with possi ble improvements/revisions at a later stage, if 
proved appropriate. 
2.1. Feasibility of a banding scheme on wet grip 
For a banding scheme on wet grip to be introdu ced such as for rolling resistance there should 
be sufficient differentiation on the market betwee n products performances on that criterion. It 
is generally agreed that tyre performances  on wet grip vary between 110% and 160% on the 
wet grip index (see al so graph bellow).  
 
However these figures do not show the range of performance in a given tyre dimension . 
Consumers having little choice in the dimension of the tyre they need to replace, there should 
be a sufficient wide range of tyre performances on wet grip for a given tyre dimension. The figures from TÜV (see graph bello w) show a small difference in  wet grip index for a given 
tyre dimension (20% in average). Only 106 tyres have been tested though, a state of the art of 
the market may show a very different picture .  
 
EN 65   EN 
 
Q2.1: Is the range of tyre performances on we t grip wide enough for a banding scheme, e.g. 4 
or 7 bands (also in a given tyre di mension relevant for consumer)?  
Q2.2: Could a parallel grading on wet grip help avoiding overall deterioration of the safety 
performance of tyres under th e influence of improved RR? 
2.2. Communicating on tyre wet grip performa nce: assessing the risks and potential 
benefits 
Giving information to consumers on tyre safety performance implies a strong responsibility of 
tyre manufacturers which may be subject to liability.  
Therefore the question arises as to  the correlation of the wet grip  index with other tyre safety 
performances: road holding abil ity, directional control, dece leration ability on wet and dry 
surfaces and aquaplaning behaviours. 
Q3: What is the correlation of the tyres pe rformance on wet grip with the other safety 
parameters?  
Q4: Is there a risk to convey misleading in formation to consumers when communicating on 
the sole wet grip performance as a safety paramete r? Is the risk marginal or significant, taking 
into account that currently  other parameters are not (and cannot be) regulated? 
3. Design and costs of a labelling scheme: 
The tests on wet grip, which will be mandato ry from 2012 (date of implementation of 
minimum requirements on wet grip) as set in th e draft proposal for a regulation on general 
 
EN 66   EN safety of motor vehicles, will be those defi ned in the UN-ECE regulation 117 (i.e. ISO 23671) 
by tyre type. The ISO working group has started to review this existing testing method in 
order to reduce its tolerances so as to allow for a grading scheme on wet grip.  
Q5.1: Are the current testing and certifi cation methods accurate enough for a banding 
scheme? 
Q5.2: What is reasonably achievable within th e ISO working group? To what extent can the 
standard deviation of the existing tests be reduced?  
Testing tyres to comply with a minimum requi rement on wet grip implies to test only the 
worst tyre of a given family such as for noise. A grading scheme will imply additional tests as no tyre manufacturers will want to have better performing tyre being graded with the same 
value of the worst tyre of the same family.  
Q6: What will be the extra-costs of these additional tests for tyre manufacturers?  
The tests currently cover C1 tyres only as no  Standard Reference Testing Tyre has been 
adopted yet for C2 and C3 tyres.  
Q7: What is the time table foreseen for th e adoption of SRRT for C2 and C3 tyres?  
 
EN 67   EN Annex 2: Minutes of the Workshop – 26 May 
 EUROPEAN COMMISSION 
DIRECTORATE-GENERAL FOR ENERGY AND TRANSPORT 
 
DIRECTORATE D – New and Renewable Energy Sources, Energy Efficiency & Innovation 
Energy efficiency of products & Intelligent Energy – Europe  
DIRECTORATE E – Inland Transport 
Road Safety  
 
Brussels, 09.06.08 
TREN/D3/AC D(2008) 
FINAL MINUTES of the 
Stakeholder Workshop on tyre labelling – 26.05.08 
Centre Albert Borschette (CCAB), Brussels 
Participants: see Annex A 
The Chair opened the meeting by highlighting that  the Workshop was part of the consultation 
process started under the impact assessment for a possible legislative ini tiative for a labelling 
scheme for tyres. He gave a brief overview of the context within which the impact assessment 
on tyre labelling was taking place. Further improvements needed to be achieved on transport fuel efficiency if the EU were to reach th e post-Kyoto target and a sustainable transport 
pattern. The promotion of Low- Rolling-Resistance Tyres (LRRTs) had been identified in the 
Integrated Strategy to reduce CO
2 emissions from passenger cars and light-duty vehicles 
(COM(2007) 19) and in the Energy Efficiency  Action Plan (COM(2006)  545) as one of the 
operational policy tools for reaching th e 20% energy savings potential by 2020. 
Technological improvements allowed the reduction of rolling resistance (RR) by up to 50% 
which meant a difference in fuel consumpti on between the best- a nd the worst-performing 
tyre of 10% (a 10% reduction in RR meant on average 2% fuel savings). LRRTs were cost 
effective but their deve lopment tended to be hampered by la ck of consumer information, and 
thus a market failure. Various studies had identif ied a fuel savings potential due to the market 
take-up of LRRTs of approximately 3%, lead ing to a saving of 100 billion euros from 2008-
2030 and a C0 2 emissions reduction of 600 million tonnes6465. 
The Chair recalled that the Commission had adopted a proposal for a Regulation on the 
general safety of motor vehicles on Friday  23 May (COM(2008) 316). The proposal set out 
requirements for the type approval of tyres, including: 
• Minimum requirements governing RR which woul d ban the worst-performing tyres from 
the market in a two-step approach in 2012/14 and 2016/18 for C1 and C2 tyres 
(respectively passenger cars and light-duty commercial vehicles) and 2012/16, 2016/20 for 
C3 tyres (heavy commercial vehicles). 
• Maximum external rolling noise minimum requirements for 2012/2016. 
                                                 
64 Europe Economics, Impact assessment study on a possible extension, tightening or simplification of 
Framework Directive 92/75 EEC on energy labelling of household appliances , 2007, 
http://ec.europa.eu/energy/demand/legislation/doc/2008_02_22/2008_consultation_energy_labelling_ap
pendix2_en.pdf  
65  
 
EN 68   EN • Minimum requirements regarding wet grip of  C1 tyres for 2012/14 (transposal of UNECE 
Regulation 117). 
• The aim of the workshop was to gather stak eholders’ views on the possible introduction of 
an energy labelling scheme for tyres allowi ng for improvements of tyre performances 
above the minimum requirements set in the abovementioned package. Special emphasis 
was given on possible trade-off between the opt imisation of RR and other parameters such 
as wet grip (relevant for safety ) and external rolling noise (RN). 
• The meeting was structured according to the questions discussed in  the working document 
that was published for consu ltation on 28 April 2008 on 
http://ec.europa.eu/energy/demand /legislation/under_discussion_en.htm . Written replies 
had been downloaded onto the same webpage. 
 Yes No 
Q1: Do you agree that a grading on ro lling resistance, for C1/C2 and C3 
tyres, being made available to end us ers and retailers, would be effective in 
fostering market transformation towards LRRT? What conditions would need to be met (e.g. simplicity of markings, transparency of data)? X  
All parties agreed that a grading scheme whic h would provide end-users with an objective 
comparison between tyre performances w ould be effective in promoting market 
transformation towards LRRTs. The Netherland s had experienced a very good feedback on 
their programme on “safe, sile nt and climate-friendly tyres66” which proved the momentum 
for policy action on this issue. The programme included the testin g of a great number of tyres, 
with publication of the measured value and a wider awarene ss-raising campaign. 
There was divergence of views on  the categories of tyres to be included in the labelling 
scheme with, on the one hand some stakeholders  against the inclusion of C3 tyres (ETRMA/ 
German Ministry for Transport/BIPAVER) on the grounds that road transport companies 
already had thorough informati on on the RR of their fleet, and on the other hand other 
stakeholders opposing this statement. FNTR, the French Federation of Road Transport, 
argued that its members would benefit from a harmonised labelling scheme and it would 
allow them to use potential “A grading” (i.e. the use of LRRTs) in their Corporate Social Responsibility Strategies and outside communication. Ulf Sandbe rg from VTI also pointed 
out that some big and medium fleet companies had contacted him to as k whether a transparent 
and objective grading scheme exis ted, which proved an interest in  the development of such a 
scheme on their part. T&E and the Dutch gove rnment highlighted th at public authorities 
would benefit from a grading scheme and coul d use it in their public procurement policies 
including C3 tyres (e.g. for buses). 
The range in RR tyre performance for C3 tyres which had emerged from the Dutch 
measurement programme and reflected the 200 4 state of the market provided by ETRMA 
(showing a difference in RRC of up to 100%) seem ed also to confirm that the market might 
not be functioning that well. The range in RR ty re performance of C3 tyres would be much 
narrower if road transport companies were we ll informed – knowing that “costs per km” was 
one of the first parameters they wanted to optimise. 
                                                
 
66 http://www.destilleband.nl . 
 
EN 69   EN A question on the costs of RR measurement according to ISO 28580 was put forward by the 
German Ministry for Transport with the concern that not all tyres should be tested. DG TREN 
reinsured that a similar approach  could be taken as for testing of external rolling noise where 
only the worst tyre of a given family was to be  measured. Tyre families for rolling resistance, 
however, had not yet been defined and would be  the subject of discussion at the Geneva 
GRRF working group in September when propos als for the introduction of rolling resistance 
testing into the relevant UNECE tyre regulati on (either Regulations 30 and 54 or Regulation 
117) would be considered. Once agreed, it was intended that the implementing measures of 
the proposal for a Regulation on the general safety of motor vehicles (COM(2008) 316) 
would refer to the revised UNECE Regulation( s). DG TREN would work together with DG 
ENTR in this framework. In the meantime cost estimations would be made within the external 
study on tyre labelling contracted with EPEC  (GHK/TNO). For a grading scheme though, it 
was likely that more tests would need to be done  in comparison to thos e necessary to ensure 
compliance with a minimum requirement, as tyre producers would want to grade their tyres at 
the best possible level (families might also be defi ned more strictly so as to have a small range 
of tyre performance inside one family). First figures pr ovided by ETRMA estimated these 
extra costs for C1 tyres at 0.006cent per tyre on average, but this woul d be further developed 
in the impact assessment. 
Conditions noted as being necessary for the succe ss of an energy labelling scheme in fostering 
market transformation towards LRRT included: 
• Simplicity of information provided to end users. 
• Transparency of data, which coul d be achieved in different ways: 
– Public database advocated by T&E and VTI but engendering reservations from 
DG TREN (past experience showed that databases are extremely complex to 
update, subject to liability, and cost ly) and Germany (no budget for this). 
– Display of the measured value on the label (T&E/VTI) but which might not be 
understandable by consumers (ETRMA). 
– Mandatory display of  the measured value/class on technical documentation, tariffs 
and/or websites made publicly av ailable (suggested by DG TREN). 
• Design of the banding scheme: 
– Minimum bandwidth of 1kg/t (VTI/T &E) – opposed by ETRMA on the ground 
that the precision of testing methods did not allow for bandwidth below 1.5kg/t. 
DG TREN would further i nvestigate this point. 
– More bands allowed for better differe ntiation amongst products and a stronger 
message towards consumers (DG TREN expe rience from other labelled products). 
– No tyres in band A (T&E) in order to pr ovide incentives for further innovations, 
with a different point of view rais ed by DG TREN (experience with other 
products showed that the cr edibility of the label incr eased when consumers could 
see that there were products in band A). 
– The Chair highlighted that the design of a possible banding scheme would depend 
on the outcome of analysis of the precisi on of measuring methods  (feasibility) and 
the potential for market transformation. 
 
EN 70   EN • Good correlation between “indoor” measurements (according to the future ISO 28580) and 
in-use performance of tyres (in “real-world” conditions). 
– VTI highlighted a problem arising from th e difference in tyre grading measured 
according to the future ISO testing method and on actual road surface: for 50% of 
“real-world” measurements, the grading would be different to the ISO “indoor” 
tests. This should not delay the implemen tation of a grading scheme but should be 
improved in the long run. This  needed to be fu rther investigated in the framework 
of the impact assessment, as experts from the ISO working group on rolling resistance seemed to disagree with this statement. 
A request was made to introduce the labelling scheme by 2010 (T&E). 
 Yes No 
Q2: Is there a need to adopt different grading schemes on rolling resistance  for 
winter (M+S) and summer tyres (assuming that suitable criteria to distinguish 
the two categories can be agreed)? (X?) X 
The 2004 state of the market provided by ETRMA showed a difference in average rolling 
resistance between winter and summer tyre s of +1kg/t (winter ty res 1kg/t above summer 
tyres) while VTI and M+P found the opposite resu lts (winter tyres 1kg /t less than summer 
tyres). These contrasting results might be the consequence of diff erent designs of winter tyres: 
tyres for Scandinavian countries are made to ro ll on ice and snow, in other countries they are 
made to roll on mud and wet road, with differe nt techniques and tread patterns used in both 
cases. According to VTI, this difference was to o small and the results too contradictory to 
justify a different grading sc heme. Norway suggested includ ing only summer tyres in the 
labelling scheme given the fact that under winter  conditions other factors such as snow or ice 
influenced RR; however this would ta ke out 28% of the EU tyre market. 
 Yes No 
Q3: Are you in favour of a grading of both rolling resistance and wet grip 
for C1 and C2 tyres? If not, why ? X  
The possible trade-off between rolling resist ance and wet grip in a given technology was 
confirmed by all stakeholders, even though eviden ce indicated that it was technically feasible 
to improve all tyre performance characteristic s at the same time – results of the Dutch 
measurement programme, for instance, found tyres performing very well on rolling resistance 
and excellent on other tyre performance characte ristics (for example, one tyre performed 6dB 
lower than the current external rolling noise  minimum requirement and 140% on the wet grip 
index). 
With the objective of avoiding improved rolling resistance being achieved at the expense of 
safety, all respondents supported the inclusion of a grading fo r wet grip in the labelling 
scheme together with rolling resistance. 
At present, only information on wet grip coul d be provided to consumers because it is the 
only safety parameter on which there exists an agreed testing method (ISO 23671) which is 
also the basis of UNECE Regulation 117 sett ing minimum requirements governing wet grip 
for C1 tyres (in order to avoid lower external  rolling noise being achie ved while decreasing 
wet grip). According to a tec hnical experts’ meeting, which t ook place on 21 April, there was 
 
EN 71   EN a good correlation between tyre perf ormance regarding wet grip a nd other parameters relevant 
for safety such as aquaplaning, handling in cu rves, dry grip and wet grip at higher speeds. 
Stakeholders did not contest this outcome, but  highlighted the necessi ty in the long run to 
refine testing methods in order to incorporate other safety parameters (VTI) and to inform 
consumers that tyre safety performance also depended on end-users (e.g. regular control and 
replacement of worn-out tyres) (VTI/BIPAVER). 
 Yes No 
Q4: Should a grading on wet grip also include C3 tyres? X X 
The possibility of including C3 tyres in a wet grip grading would depe nd on the speed of the 
work at UNECE level in adopting a Standard Reference Testing Tyre (SRTT) in the C3 
category (the same was valid for C2 tyres). According to the 21 April technical expert meeting, the SRTT should be adopted by 2010. DG ENTR recalled that it intended to make 
minimum requirements governing wet grip for C3 tyres mandatory in an implementing measure of the proposal for a Regulation on the general safety of motor vehicles (COM(2008) 
316) as soon as Regulation 117 had been extended  to cover C2 and C3 wet grip requirements. 
For some stakeholders (ETRMA, German Ministry of Transport) the inclusion of C3 tyres in 
a wet grip grading was not necessary for the same reasons as for RR: professional road 
transport operators already had thorough informa tion on tyre performance and did not need an 
additional labelling scheme. This was opposed by the other half of the respondents (same 
discussion and divides as in the answer to Q 1, second paragraph). According to the German 
Ministry for Transport, the inclusion of C3 ty res in a wet grip grading would not be useful 
since the results on the ISO 23671 wet grip index did not reflect  real-world performance of 
tyres. 
 Yes No 
Q5: Is the display of the measured noise value in a labelling scheme 
technically feasible and understandable fo r consumers? Do you think that it 
would have any significant effect on the market below the minimum requirements set for ex ternal rolling noise? X X 
This question was controversial, with one si de heavily in favour of introducing external 
rolling noise into the labelling scheme and th e other side opposing it. Some were neutral, 
arguing that if wet grip were included in the labelling scheme then there would be no reason 
not to include noise as well (G erman Ministry for Transport). 
Considering the opposition of the ty re industry to a banding sche me for tyre external rolling 
noise, T&E proposed a low-noise mark for tyre s 3dB below the minimum requirement (see 
proposal in Annex 2). M+P/T&E/the Netherla nds/VTI/Eurocities/NW/German Ministry for 
the Environment supported the inclusion of a low-noise label. Arguments in favour of the 
inclusion of external rolling noise included: 
• Trade-off between optimisation of noise and of  wet grip and external  rolling noise in a 
given technology. If wet grip were  to be included on the label, then nois e should be also 
included in order to give incentives for optimisation of all three parameters (RR, wet grip and external rolling noise). 
 
EN 72   EN • Information to be provided under the la belling scheme would reflect exterior  noise 
measured according to the ISO 13325 method but  as correlation between exterior and 
interior noise was “sufficient” , this would still give valuab le information to end-users. 
There appeared to be a good correlation around 1 000 Hz (>70%) but a we ak correlation at 
low frequencies (“because it is masked by ot her noise sources like drive line or tyre 
induced vibrations”), thus gi ving an overall moderate co rrelation (about 25%) (M+P). 
• Transparency of data on extern al rolling noise would greatly facilitate the implementation 
of public policies against traffic noise, and be useful for public procurement and fleet 
owners (NL/ Eurocities/Norwegian delegation). 
• Standard deviation within a tyre family was estimated at 0.5dB according to research made 
by M+P. In other words, only the worst tyres were measured  according to the current 
testing protocol, but given the established st andard deviation, the best tyres within the 
same family would be at maximum 0.5dB belo w. So the proposal to adopt a low-noise 
label for tyres 3dB below the minimum requireme nt would entail no extra costs as external 
rolling noise by tyre family had already to be  measured in the type-approval procedure. 
• Minimum requirements on noise in the proposal for a Regulation on the general safety of 
motor vehicles (COM(2008) 316) had been downgraded in comparison to the initial 
proposal put forward in the FEHRL study for C2  and C3 tyres, and the implementation 
date postponed to 2016 for existing tyre types. This made the benefits of including external 
rolling noise in a labelling scheme more  important and necessary (VTI/NL/T&E). 
• Considering the technical possibi lity to produce tyres with exte rnal rolling noise far below 
the minimum requirements, it was necessary to give that information to end-users 
(NL/NW/VTI/T&E). 
• Consumer survey and tyre industry marketi ng campaign on low-noise tyres demonstrated 
that there was a demand for low-noise tyres.  According to research done in Austria by 
Fallast et al, 94% of respondents would be w illing to buy low-noise tyres and 70% of them 
to pay a small price premium (T&E/VTI). 
• External rolling noise abatement costs due to  technical improvement of tyres was much 
less important than improvement  of road surfaces (VTI). 
• Including external rolling noise on the label would increase consumer awareness on this 
issue (German Ministry for the Environment). 
ETRMA/PSA/SP/UK/WDK resisted the inclusion of  external rolling noise in the labelling 
scheme on the following grounds: 
• Little priority given by consumers to the e nvironmental performance characteristics of 
tyres when making their purchasing decision (German Ministry for Transport/ETRMA). 
• Problem due to variability of test tracks  estimated at 5dB (ETRMA). Specialised 
magazines or consumer organisations could c ontest the claimed low-noise mark if they 
found different measured values due to variability of test tracks. 
 
EN 73   EN • No correlation between exterior and interior noise (ETRMA/VTI) for low frequencies 
coming from other noise sources which depend much more on the design characteristics of 
the vehicle. 
 Yes No 
Q6: Do you consider that some of the issues raised in the preceding 
questions should be consider ed for retreaded tyres? (X) X 
Though the majority of stakeholde rs agreed that in theory retreaded tyres should be included 
in the labelling scheme, there was currently insufficient knowledge fo r designing concrete 
policy actions and the issue deserved a focused background study (FNTR/T&E). VTI 
highlighted, however, the potential interest of retread companies themselves as the Scandinavian experience shows th at five retread companies applied voluntarily for the Nordic 
Swan logo, but only for a limited number  of tyre dimensions (ETRMA). 
BIPAVER representing the i ndependent tyre retread indu stry, supported by the German 
Ministry for Transport and ETRMA, said that the introduction of a labelling scheme for 
retreaded tyres was not feasible in practice: due to interaction betw een tread and carcasses, 
each individual retreaded tyre would have to be  tested. “With 100 brands of tyres, and more 
than 80 brands of pre-cured and hot-cured trea ds, that makes a matrix of more than 8 000 
varieties in one size alone”. BIPAVER suggested as an alternative the adoption of a Code of 
Conduct by the retread industry. 
 Yes No 
Q7: Do you think that a grading scheme could be used by car manufacturers 
to offer better performing tyres to thei r consumers? Do you think that car 
manufacturers can take advantage in thei r marketing strategy from a tyre 
labelling scheme ? 
Q8: Should the grading of OE tyres (tyres  originally fitted to new vehicles) 
be made available on catalogue s and advertising tools on cars? 
Q9: What will be the likely impact of the worst tyre principle defined for 
emissions measurement, on average rolli ng resistance of OE tyres? Is there 
a need to encourage car manufacturers to offer tyres with improved rolling resistance compared with the ‘worst ca se’ tyre used for the mandatory tyre-
approval measurement? X?  
As no representatives from the car industry were present, these questions  were not tackled. 
The only written reply receiv ed came from PSA answering positively to the first two 
questions (Q8 and Q9) and with an interest in being able to provide consumers with objective 
information on OE tyres. 
It was, however, underlined that  the choice of tyres fitted on new vehicles by car producers 
was crucial since it might in fluence consumers when they replaced their tyres. 58% of 
consumers replaced their tyres with the same on es as the OE tyres, according to one member 
company survey by ETRMA (other consumer surveys show a share of around 20%). 
 
EN 74   EN Q10: How do you suggest the information on tyres should be provided (how, to whom 
and when)? 
Q11: What should be the role of the retailers?  
The Chair began by recalling the difference betw een endorsement labels such as the Nordic 
Swan (declaring that a specific product complie d with high-quality criteria) and performance 
labels which provided the grading of a product compared to others. Experience from the 
labelling Directive on household appliances (D irective 1992/75/EC) showed the effectiveness 
of performance labelling in pushing market tr ansformation towards energy-efficient products; 
this would be the type of label favoured by DG TREN for tyres. 
On the question raised by the German delegatio n whether the grading sc heme would be static 
or dynamic, the Chair replied that this depende d on the speed of technological change in one 
product. The discussion about dynamic and st atic labelling schemes was being addressed 
within the revision of the abovementioned Di rective on household ap pliances, a labelling 
scheme for tyres would certainly follow the outcome. 
There was a wide consensus on the mandatory disp lay of the labelling scheme in catalogues, 
communication tools and on the internet. Disagr eement emerged, however, on the necessity or 
not of displaying the label on a sticker on tyres. According to the tyre industry, this would not 
prove effective as (1) consumers most of the time do not see the tyres, and (2) would be 
complex and costly to implement because of la nguage constraints (tyres were produced in one 
production centre for export in all EU Member States and third countries). 
Availability of measured va lues/grading was recalled by VT I and T&E asking for a public 
database, with reservations on costs and complexity of implem entation (updates, liability of 
information, etc.) expressed by DG TREN and the German delegation. The Chair suggested 
also giving the information on tyre grading on th e bill provided to the consumers or end-users 
so as to ensure reliability and transparen cy of the information given to end-users. 
Some stakeholders asked for the information to be moulded into tyre side walls (Eurocities/ 
VTI/T&E/German Ministry for the Environmen t) but faced strong opposition as regards the 
costs/benefits of this measure (ETRMA/BIP AVER/German Ministry for Transport). No 
figures could be given, however, on both sides. Eu rocities noted that moulding information on 
tyre performance on the side wall may be instru mental for those cities wishing to restrict 
worst-performing cars’ access to the city centr e which could include tyres (such as in 
London). 
On the design of a labelling scheme, several proposals were put forward, see Annex 2 for 
T&E and Annex 3 for ETRMA proposals. The Du tch delegation propos ed a three-colour 
system (green, orange and red) used for each tyre performance, green reflecting the best 
performance and red the worst. It was agreed th at the braking distances in metres should not 
be displayed to consumers as it may lead to misunderstanding and only reflected braking 
distances in strict conditions (at 80km/h speed  with road surface friction of between 0.6 and 
0.8 according to ISO 23671) and would differ from one vehicle to  another (German 
delegation). DG TREN, Unit E3 on Road Safety, also pointed out that the reference to the 
testing methods used to rank tyres should be explicitly mentioned on the label. 
 
EN 75   EN See also on this matte r the answers to Q1 on conditions to be met for the success of a 
labelling scheme regarding RR. 
 Yes No 
Q12: Do you think that th e labelling scheme should be associated with other 
types of measures designed to accelerate the market take up of LRRT (e.g. specific criteria or guidelines for pub lic procurement of replacement tyres, 
fiscal incentives…)? X X 
Incentive schemes through public procurement proce dures had (1) already b een put in place in 
the Regulation on a Community energy-efficiency  labelling programme for office equipment 
(Regulation (EC) No 106/2008) which required EU institutions and central Member State 
government authorities to use energy-efficiency criteria no less demandi ng than those defined 
in the ENERGY STAR programme when purchas ing office equipment, or (2) were being 
considered such as in the revision of the en ergy labelling Directive on household appliances 
(Directive 92/75/EC) (input by the Chair). 
According to the Netherlands and T&E, this could be a possibility to explore for tyres. In any case, the majority argued that a label ling scheme would be instrumental for cities, 
companies and public authorities in the design  of proactive purchasing policy or fiscal 
incentives.  
 
EN 76   EN Annex A: List of participants 
EU Member States 
Germany, Ministry for the Environm ent and Ministry for Transport 
Spain, University Institute for Automobile Res earch in the name of the Spanish Interior 
Ministry, Road Tr affic Directorate 
The Netherlands, Ministry for the Envi ronment and Ministry for Transport  
EFTA Member Countries 
Norway, Public Road Administra tion and Pollution Control Authority  
NGOs, European organisations and research centres 
Eurocities 
GHK M+P T&E VTI 
Consumer/road transport organisations 
ANEC 
Test-Aankoop 
FNTR (Fédération Nationale des Transporteurs Routiers (FR))  
Industry 
BIPAVER (Independent Re treader organisation) 
ETRMA (Goodyear, Bridgestone, Mich elin, Pirelli, Continental) 
ORGALIME  
European Commission  
DG TREN (D3/E3), DG ENTR (F1)  
Additional written comments received: 
United Kingdom, Department for Transport 
Environment, Nature and Energy De partment of the Flemish Government 
PSA Peugeot Citroën WDK (Wirtschaftsverband der de utschen Kautschukindustrie) 
IRU (International Road Transport Union) Rhodia  
 
EN 77   EN Annex 3: Relative versus Absolute Grading  
Physics behind RR: Variation in RR, i.e. the dissipation of energy, is a function of three 
factors: (1) volume, (2) loss pr operty of the compounds (textile fabrics) and (3) deformation 
of the tyre material (visco-elasticity) which depends itself on three factors: inflation pressure, tyre geometry (i.e. outside diameter (OD), lo ad index (LI), aspect ratio, and width) and 
compound. The loss property of the material is  the main factor which may influence RR 
through the use of silica instead  of black carbon. LI and outs ide diameter are found in the 
third factor
67. 
Empirical correlation: Empirical measurements show a correlation between OD or LI and RR, 
but its significance varies among tyre producer s Some figures provided by tyre producers 
show a regression coefficient (relevant to pr ove the significance of the correlation) R² of 
between 0.6 and 0.8 in a given tyre line (which means that up to 60% to 80% of RR variation 
can be explained with the OD or LI68). Others show a regression coefficient of around 0.2 in 
all tyre lines on the OE market, which is st ill significant, and around 0.02 on the replacement 
market all tyre lines included. This shows that the correlation will vary across tyre 
populations. 
Impact of a relative versus absolute gradi ng scheme: The proven correlation between OD or 
LI means that an absolute grading scheme (horizontal lines on a gr aph showing RR and OD) 
will favour larger tyres and discriminate smaller one s. It will be easier for larger tyres to reach 
the upper bands due to their size advantage, ther e may be a risk on the contrary that no small 
tyres (low OD) are found in the A class. A relative grading scheme would give equal 
incentives for all tyre dimensions. 
The environmental impact of eith er scenario may be neutral: a relative grading scheme will 
put more pressure on bigger tyres where absolute fuel savings and CO 2 reduction are bigger 
(2% fuel saving on a high-consuming car is more  important than on a small one). But an 
absolute grading scheme will put more pressure on smaller tyres, which constitute the majority of the tyre market. 
The tyre industry itself took a position in favour  of an absolute grad ing scheme but with no 
unanimity of its members. Given the uncertainties on this issue, it is sugge sted to start with an 
absolute scheme and to see at a later stage if a relative grading scheme  would be justified. In 
any case a relative grading scheme would have no impact on consumers if the measured value 
is not displayed on the labe l but just the grading. 
                                                
 
67 LI and OD are interrelated as bigger cars need bigg er tyres (higher OD) but are also heavier and hence 
need higher LI. 
68 In this case – correlation measured in only one tyre  line – the high regression coefficient is due to the 
fact that factor 2 (propert y of the material) does not enter into pl ay. R² is not equal to 1 because some 
tyre dimensions will be adapted to the specific need of a given car producer (on the OE market) and will 
change therefore the overall pe rformance of the tyre (as each parameter is integrated). 
 
EN 78   EN Annex 4: Sample of Labelling Scheme 
• Existing labelling scheme used on household appliances 
 
• Proposal for a low-noise label by T&E 

 
EN 79   EN Annex 5: Economic Data Relevan t for the Impact Assessment 
Market data 
Table 1: The EU Market for Tyres Sold for Original Equipment (OE) and as 
Replacements (million) 
Market Segment 2005 2006 2007 2007 Share (%) 
by Vehicle 
Type 2007 Share (%) 
of Total Tyre 
Sales 
PC replacement – EU production 181 189 182 61% 53% 
PC replacement – Imports 43 45 48 16% 14% 
Total PC replacement 224 235 231 78% 68% 
PC OE – EU production 61 64 63 21% 18% 
PC OE – Imports 1 0 2 1% 1% 
Total PC OE 62 64 65 22% 19% 
TOTAL Passenger Car (PC) 286 299 296 100% 87% 
LT replacement – EU production 15 15 16 57% 5% 
LT replacement – Imports 4 4 4 14% 1% 
Total LT replacement 19 19 20 71% 6% 
LT OE – EU production 7 7 7 25% 2% 
LT OE – Imports 1 1 1 4% 0% 
Total LT OE 7 8 8 29% 2% 
TOTAL Light Truck (LT) 26 27 28 100% 8% 
TBs replacement – EU production 11 11 11 61% 3% 
TBs replacement – Imports 4 5 5 28% 1% 
Total TBs replacement 15 16 16 89% 5% 
TBs OE – EU production 0 2 2 11% 1% 
TBs OE – Imports 0 0 0 0% 0% 
Total TBs OE 0 2 2 11% 1% 
TOTAL Trucks & Buses (TBs) 0 18 18 100% 5% 
All Vehicle Tyre Sales in EU 312 344 342   100% 
Total replacement sales 258 270 267  78% 
Total OE sales 69 74 75  22% 
Source: Europool (courtesy ETRMA), ACEA  
PC – passenger cars, LT – light transpor t vehicles, TBs – trucks and buses 
Tyres sold in the replacement market for pa ssenger cars can be broken down by price into 
premium, mid-range and budget segments, accounting for 54%, 25% and 21% of the total 
passenger car replacement market respectively. 
 
EN 80   EN Table 2: Replacement Market Share of Winter and Summer Tyres by Tyre Class 
Market Share C1 (PC) C2 
(CV/LT) C3 
(TB) All Tyres 
Summer 70% 69% 74% 70% 
Winter 30% 31% 26% 30% 
 Source: Europool (cour tesy ETRMA), ACEA 
PC – passenger cars, LT – Light transpor t vehicles, TBs – Trucks and buses 
Table 3: Projected EU Market for Repla cement Tyres C1, C2 and C3 (millions), 
including imports 
Vehicle
Type of T yre Summe rWinter Total Summe rWinter Total Summe rWinter Total
2007             166           65          231            14             6            20              12              4           16 
2008             165           71          236            14             6            20              12              4           17 
2009             170           73          242            14             7            21              13              4           17 
2010             174           74          248            15             7            22              13              5           18 
2011             178           76          254            15             7            22              13              5           18 
2012             182           78          260            16             7            23              14              5           18 
2013             187           80          266           16            7           23             14              5           19  
2014             191           82          273            16             7            24              14              5           19 
2015             195           84          279            17             7            24              15              5           20 
2016             200           86          286           17            8           25             15              5           20  
2017             205           88          293            17             8            25              15              5           21 
2018             210           90          300            18             8            26              16              6           21 
2019             215           92          307           18            8           27             16              6           22  
2020             220           94          314            19             8            27              17              6           22 C1-Passenger cars C2-CV/LT C3-TBs
 
Source: Europool (Courtesy ETRMA),  ACEA and DG TREN Pocket Book 
 
EN 81   EN Annex 6: Minimum Requirements governing Tyres defined in the Proposal for a 
Regulation on the general safety  of motor vehicles (COM(2008)316) 
Minimum Requirements for Rolling Resistance  (COM(2008) 316, Annex 1, Part B) – see 
Box 7 for further explanation 
 Oct 2012 Oct 2014 Oct 2016 Oct 2018 Oct 2020 
C1 
 12kg/t 
(new TT) 12kg/t 
(existing TT) 10.5kg/t 
(new TT) 10.5kg/t 
(existing TT)  
C2 
 10.5kg/t 
(new TT) 10.5kg/t 
(existing TT) 9kg/t 
(new TT) 9kg/t (existing TT)  
C3 
 8kg/t 
(new TT)  8kg/t 
(existing TT) 6.5kg/t (new TT)  6.5kg/t 
(existing TT) 
 
Box 7: A distinction is made between new tyre type  (TT), i.e. a new pr oduction line or brand 
which has to pass through the t ype-approval procedure, and the existing tyre type  which has 
already been type-approved before  the date of entry into force of the new requirements. Since 
the product life cycle of tyres lasts maximum be tween 6 to 8 years for C1 tyres (usually 
between 3 and 4 years) and 8 to 10 years for C2 tyres69, a time lag is set down for the existing 
tyre type to comply with the requirements. 
Minimum Requirements for Wet Grip for C1 Tyres by 2012/14 (COM(2008) 316, Annex 
1, Part A) 
Category of use Wet grip index (G) 
Snow tyre with a speed symbol (“Q”  or below minus “H”) indicating a 
maximum permissible speed not greater than 160 km/h ≥ 0.9 
Snow tyre with a speed symbol (“R”  and above, plus “H”) indicating a 
maximum permissible speed greater than 160 km/h ≥ 1.0 
Normal (road type) tyre ≥ 1.1 
                                                 
69 Figures from FEHRL, Tyres/Road Noise , May 2006, Volume 1, p. 34. It is difficult to tell what the 
product life cycle of C3 tyres is, as it is a highly specialised market segment with some specific tyres 
which may be produced lasting up to 15 years, th is is why no estimation is given for C3 tyres. 
 
EN 82   EN Minimum Requirements for External roll ing noise by 2012/16 (COM(2008) 316, Annex 
1, Part C) 
Tyre class Nominal section 
width (mm) Minimum 
requirements in dB(A) 
C1 A ≤ 185 70 
C1 B > 185 ≤ 215 71 
C1 C > 215 ≤ 245 71 
C1 D > 245 ≤ 275 72 
C1 E > 275 74 
 
Tyre class Nominal sec tion width (mm) Minimum 
requirements in dB(A) 
Normal 71 C2 
Traction tyres 72 
Normal 72 C3 
Traction tyres 74