EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 13.11.2008 
SEC(2008) 2861  
  
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  
  
SUMMARY OF THE IMPACT ASSESSMENT  
{COM(2008) 779} 
{SEC(2008) 2860} 
 
EN 2   EN COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the 
 
Proposal for a Directive of the European Parl iament and of the Council on labelling of 
tyres with respect to fuel efficien cy and other essential parameters 
  
IMPACT ASSESSMENT SUMMARY 
Policy background 
In the Energy Efficiency Action Plan (COM(2006) 545) the European Commission 
committed to consider drawing up a proposal fo r a tyre energy labelling scheme by 2008. The 
aim is to promote vehicle fuel efficiency th rough market take-up of fuel-efficient tyres
1. 
This impact assessment is part of an integrated  approach to improve tyre fuel efficiency and 
other essential parameters. This approach co mbines supply-oriented measures by means of 
mandatory standards (minimum requirements) de fined in the type-app roval legislation and 
demand-oriented measures by means of la belling. The proposal for a Regulation on the 
general safety of motor vehicles (COM(2008)  316) will significantly improve tyre rolling 
resistance (fuel efficiency), wet grip (road  safety) and external  rolling noise (traffic 
noise/health) through the adoption of new minimum requirements regarding those parameters. 
The objective of this impact as sessment is to assess the op portuneness of supporting dynamic 
improvement in tyre fuel efficiency beyond those minimum requirements through the 
operation of market forces. It would addr ess mainly the replacement market, which 
constitutes 78% of the tyre market. 
A tyre is characterised by a number of parameters which are interrelated. Optimising one 
parameter, such as rolling resistance, may have  an adverse impact on another parameter, such 
as wet grip2, whereas optimising wet grip may have an adverse impact on external rolling 
noise. While it is possible to simultaneously im prove different tyre at tributes at higher 
production costs, it is also possible within a given technology to optimise one parameter at no 
additional cost but at the expense of another. 
There are two ways to tackle this issue:  (1) either minimum requirements guarantee a 
satisfactory level of safety and external roll ing noise which can be progressively tightened, 
while tyre labelling gives information on fuel e fficiency only; (2) or tyre labelling covers 
several parameters to give incentives for op timisation of all parameters beyond the minimum 
requirements. The policy options descri bed below reflect these alternatives. 
Policy Options 
• Option 1: No EU action = baseline scenario, in cluding the proposal for a Regulation on 
the general safety of motor vehicles whic h sets new minimum requirements for tyres. 
                                                 
1 Also called “Low-Rolling-Resistan ce Tyres” (LRRTs), see definition in the impact assessment, Box 1. 
2 See definition in the impact assessment, Box 2. 
 
EN 3   EN • Option 2: Single-criterion labelling scheme for C1 tyres3 regarding fuel efficiency, with 
minimum requirements on other parameters  (wet grip and external rolling noise). 
• Option 3:  Dual-labelling scheme for C1 tyres regard ing fuel efficiency and wet grip, with 
minimum requirements on external rolling noise. 
• Option 4:  Multi-criteria labelling scheme for C1 ty res regarding fuel e fficiency, wet grip 
and external rolling noise. 
• Option 5:  Extension of the labelling scheme devel oped for C1 tyres (Option 2, 3 or 4) to 
C2 and C3 tyres4. 
• Option 6: Economic instruments and public procurement. This option does not necessarily 
substitute Options 2 to 5 but could complement them. 
Option 1  highlights the current drivers of improvement  in rolling resistance (RR) relevant for 
fuel efficiency, namely (1) the regulatory pressure put on car producers to reduce car 
emissions, and hence tyre RR; (2) the setting of minimum requirements governing RR in the proposal for a Regulation on the general safety of  motor vehicles; and (3) to a lesser extent, 
demand from road transport sector professiona ls who want to reduce costs per km. Market 
transformation projection based on past trends and these three dr ivers shows that the market 
transformation towards fuel efficient tyres will fail to achieve its full potential without further 
EU action. This is due to a market failur e arising from lack of information, i.e. the 
impossibility for consumers, and most of the time also for larger fleet managers, to objectively assess tyre perfor mance characteristics and compare the potential increased 
purchasing price with fuel savings du ring the in-use phase of the tyres. 
Option 2  illustrates that the impact of a single- criterion labelling scheme regarding fuel 
efficiency is likely to be the most effective in promoting market tran sformation towards fuel 
efficient tyres compared to Options 3 or 4. The information provided on tyre fuel efficiency 
via a grading system will be the easiest for consumers to absorb while minimum requirements on wet grip and external rolling noise will ensure drivers’ safety and reduced traffic noise. One strong argument in favour of relying on minimum requirements  for wet grip is that there 
cannot be compromises on road safety. On th e other hand, minimum requirements do not give 
long-term incentives for tyre producers to fu rther invest in R&D to optimise those tyre 
parameters which are not displayed on the label,  since consumers will not have access to the 
information. 
Option 3  shows that a dual-labelling scheme regarding fuel efficiency and wet grip may slow 
down the market transformation towards fuel e fficient tyres. Since production costs will be 
significantly higher in order to optimise both parameters at the same time (e.g. to achieve an 
"A" grade in both performance characteristics) , consumers are likely to choose a less 
expensive tyre with optimised we t grip and leave fuel efficiency by the wayside. The safety 
gains of higher wet grip levels going beyond th e minimum requirement are difficult to assess. 
First, vehicle-tyre interaction will play an important role in the real on-road braking performance of a tyre; second, other parameters, such as aquaplaning or handling in a curve, 
                                                
 
3 C1, C2 and C3 tyre classes as defined in COM(2008) 316 in general refer respectively to tyres fitted on 
passenger cars, light commercial vehicles and heavy-duty vehicles (see Box 3). 
4 See footnote 2. 
 
EN 4   EN are also significant for road safety5; third, driving behaviour is th e most critical factor in 
accident causes; and finally, statistics and nati onal databases do not make for a solid analysis 
concerning the relation between tyre wet grip  and accident causes. It can be assumed, 
however, with maximum probability that wet grip, i.e. the gain in brak ing distance, can make 
a difference in avoiding an accident. The impact assessment shows, in addition, that there is potential for improving wet grip beyond the mini mum requirements. Including wet grip in a 
labelling scheme would provide producers with strong incentives to fu rther optimise this 
parameter. 
Option 4  demonstrates that there is still a large po tential for reduced external rolling noise on 
the market below the minimum requirements. Sin ce traffic noise is a nuisance and source of 
health problems, the inclusion of external rolling noise in a labe lling scheme may be 
instrumental in promoting low-noise tyres and awareness-raising in compliance with 
Directive 2002/49/EC on environmental noise. The impact assessment shows, however, that 
the real impact on consumer behaviour is questionable, mainly because the standardised tests can only measure external rolling noise and do  not necessarily reflect inside noise, which 
depends on the specific tyre-vehicle/road surface interaction. Neither would the current 
accuracy of tests make for a precise grading sc heme. It is therefore recommended to take a 
middle approach, which consists of simply i ndicating the external ro lling noise measured 
value on the label. 
Option 5  entails the highest fuel-saving potential, since the vehicles of road transport 
companies annually consume and drive more than  passenger cars. Bilate ral interviews with 
fleet managers show that a la belling scheme would be instru mental in driving the market 
towards more fuel-efficient tyre s: a 1kg/t difference for a set of  truck tyres translates, for 
example, into 5% fuel savings (compared to 1.5% for passenger cars on average). Fleet 
managers currently face difficulties in obj ectively comparing tyre fuel efficiency 
performance; so that without further EU action price and mileage will continue to be the first 
and almost only parameters they take in to account in thei r purchasing decision. 
Option 6  discusses economic instruments and pub lic procurement which could act as 
complementary measures. Economic or market-b ased instruments may indeed boost market 
change by, for example, decreasing levies on fu el-efficient tyres and increasing it on worst-
performing tyres. This would improve price sign als by attaching a value to the external costs 
and benefits. This may be eff ective especially on the fleet ma rket, which constitutes up to 
50% of the passenger car market in some Member  States, since fleet owners do not pay fuel 
bills and may therefore be less interested in buying fuel efficient tyres. A labelling scheme could also be instrumental for cities, comp anies and public authori ties in the design of 
proactive purchasing policies. 
Final outcome 
Comparison of the policy options shows that a multi-criteria labelling scheme (Option 4 on 
C1 tyres) should be the prefe rred option extended to C2 and C3 tyres (Option 5). Option 5 
would bring indeed the most benefits, with a potential of 0.56 to 1.51 Mtoe savings per year, 
which is equivalent to removing 0.5 million to 1.3 million passenger cars from EU roads (or 3 
to 8% of new passenger car registration). The sl ower market take-up of fuel-efficient tyres 
                                                
 
5 The lack of testing methods for these parameters does not make it possible to include them in a 
labelling scheme (see Box 2 in the impact assessment). 
 
EN 5   EN compared to Option 2 (single-criterion labell ing scheme) would be compensated by safety 
gains, while the extension of the labelling sche me to C2 and C3 tyres greatly increases total 
fuel savings. 
Design of the fuel effici ency and wet grip classes 
When defining the fuel efficiency and wet grip classes, several factors have be taken into 
account: 
• the state of the art and technologi cal potential for improvement,  
• the minimum requirements set in the proposal for a Regulation on th e general safety of 
motor vehicles which will de fine the lowest classes,  
• the production costs to achieve a certain level of fuel effi ciency or wet grip which – 
compared to the related fuel savings or safety  gain– give a view on the cost-effective levels 
towards which the market can be rationally expected to evolve, 
• the precision of testing methods which may influence the width of the bands,  
• the potential for a proper differentiation among products. The aim of the grading scheme is 
obviously to give incentives both to the end-user s to buy more fuel efficient and safer tyres 
and to the industry to place more fuel efficient and safer tyres on the market. 
The lack of wet grip testing methods for C2  and C3 tyres does not currently enable the 
adoption of a wet grip grading for those tyre classes. Significant fuel saving potential was, 
however, highlighted in these two market segments. The impact assessment therefore 
considers the adoption without delay of fuel e fficiency classes for C2 and C3 tyres in the 
proposal for a Directive on tyre labelling, followe d, if relevant, by the extension of wet grip 
grading to these tyre classes in comitology as  soon as testing methods are adopted (by 2010, 
according to the industry). 
Display of the information 
The display of the labelling scheme will be cruc ial for its success, since most of the time and 
contrary to other product groups such as household appliances, consumers have no access to tyres. The impact assessment highlights tw o ways of providing the information most 
effectively: 
• One is to ensure that the labelling scheme  (in its larger meani ng, which includes the 
grading of fuel efficiency and wet grip and the external rolling noi se measured value but 
not necessarily published in  the same format as on the label)  is available on electronic tools 
and all technical documentation such as leaf lets and catalogues. This will guarantee that 
consumers and end-users will have access to  the information before their purchase 
decision. 
• The second is to ensure that the labelling scheme reaches the dealers. The majority of 
consumers rely on them for their choice of replacement tyres. It is therefore crucial to ensure that all dealers have eas y access to the label. Since a ll of them already use current 
stickers put by the manufacturers on tyres as a wo rking tool to easily se lect the right brand, 
dimension and load index, it is proposed to incl ude the label and make it clearly visible on 
 
EN 6   EN those specific stickers. In co mpliance with the principle of proportionality of costs, the 
information on the label would be provided by means of pictograms so that no translation 
is required in line with the c ountry where the tyres are delive red. Since tyres are produced 
in a few plants for delivery across the entire EU-27, translation of stickers would require 
disproportionate logistics costs. 
Both provisions entail negligible costs, sin ce the communication tools and stickers already 
exist. 
Costs of the proposal 
The impact assessment shows that the costs of the proposal would be marginal apart from the 
usual cost of transposing a directive into national law. The same tests as those defined in the type-approval legislation would be  used to reduce the administra tive burden on industry. Self-
declaration should also decrease  testing costs, which have been estimated at around 0.03 euro 
per tyre in the worst case. 
Labelling tyres should no t have the effect of increasing ty re prices either . Low-budget tyres 
will still be provided for sale on the market; th e only change is that objective information on 
tyre parameters will be provided to consumer s so that competition does not operate on price 
alone.