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 essential parameters - Summary of the impact assessment {COM(2008) 779} {SEC(2008) 2860}
Date: 2008-11-13
Institutions: European Commission
Subjects: ecology, energy policy, environmental protection, labelling, motor fuel, pneumatic tyre, transport policy

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COMMISSION OF THE EUROPEAN 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 essential parameters  

SUMMARY OF THE IMPACT ASSESSMENT 

{COM(2008) 779} 
{SEC(2008) 2860} 

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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 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 for a tyre energy labelling scheme by 2008. The 
aim is to promote vehicle fuel efficiency through market take-up of fuel-efficient tyres1. 

This impact assessment is part of an integrated approach to improve tyre fuel efficiency and 
other  essential  parameters.  This  approach  combines  supply-oriented  measures  by  means  of 
mandatory  standards  (minimum  requirements)  defined  in  the  type-approval  legislation  and 
demand-oriented  measures  by  means  of  labelling.  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 assessment is to assess the opportuneness of supporting dynamic 
improvement  in  tyre  fuel  efficiency  beyond  those  minimum  requirements  through  the 
operation  of  market  forces.  It  would  address  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  improve  different  tyre  attributes  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  rolling  noise  which  can  be  progressively  tightened, 
while  tyre  labelling  gives  information  on  fuel  efficiency  only;  (2)  or  tyre  labelling  covers 
several parameters to give incentives for optimisation of all parameters beyond the minimum 
requirements. The policy options described below reflect these alternatives. 

Policy Options 

•  Option 1: No EU action  = baseline scenario, including  the proposal for a  Regulation on 

the general safety of motor vehicles which sets new minimum requirements for tyres. 

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Also called “Low-Rolling-Resistance Tyres” (LRRTs), see definition in the impact assessment, Box 1. 
See definition in the impact assessment, Box 2. 

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•  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 regarding fuel efficiency and wet grip, with 

minimum requirements on external rolling noise. 

•  Option 4: Multi-criteria labelling scheme for C1 tyres regarding fuel efficiency, wet grip 

and external rolling noise. 

•  Option 5: Extension of the labelling scheme developed 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  professionals  who  want  to  reduce  costs  per  km.  Market 
transformation projection based on past trends and these three drivers 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  failure  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  performance  characteristics  and  compare  the  potential  increased 
purchasing price with fuel savings during 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 transformation 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 the other hand, minimum requirements do not give 
long-term  incentives  for  tyre  producers  to  further  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  efficient  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 wet grip and leave fuel efficiency by the wayside. The safety 
gains of higher wet grip levels going beyond the 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, 

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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). 
See footnote 2. 

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are  also  significant  for  road  safety5;  third,  driving  behaviour  is  the  most  critical  factor  in 
accident causes; and finally, statistics and national 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 braking 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 minimum requirements. Including wet grip in a 
labelling  scheme  would  provide  producers  with  strong  incentives  to  further  optimise  this 
parameter. 

Option 4 demonstrates that there is still a large potential for reduced external rolling noise on 
the market below the minimum requirements. Since traffic noise is a nuisance and source of 
health  problems,  the  inclusion  of  external  rolling  noise  in  a  labelling  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  scheme.  It  is  therefore  recommended  to  take  a 
middle  approach,  which  consists  of  simply  indicating  the  external  rolling  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.  Bilateral  interviews  with 
fleet  managers  show  that  a  labelling  scheme  would  be  instrumental  in  driving  the  market 
towards  more  fuel-efficient  tyres:  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 
tyre  fuel  efficiency 
managers  currently  face  difficulties 
performance; so that without further EU action price and mileage will continue to be the first 
and almost only parameters they take into account in their purchasing decision. 

in  objectively  comparing 

Option  6  discusses  economic  instruments  and  public  procurement  which  could  act  as 
complementary  measures.  Economic  or  market-based  instruments  may  indeed  boost  market 
change by, for example, decreasing levies on fuel-efficient tyres and increasing it on worst-
performing tyres. This would improve price signals by attaching a value to the external costs 
and  benefits.  This  may  be  effective  especially  on  the  fleet  market,  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,  companies  and  public  authorities  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  preferred  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  slower  market  take-up  of  fuel-efficient  tyres 

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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). 

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compared  to  Option  2  (single-criterion  labelling  scheme)  would  be  compensated  by  safety 
gains, while the extension of the labelling scheme to C2 and C3 tyres greatly increases total 
fuel savings. 

Design of the fuel efficiency 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 technological potential for improvement,  

•  the  minimum  requirements  set  in  the  proposal  for  a  Regulation  on  the  general  safety  of 

motor vehicles which will define the lowest classes,  

•  the  production  costs  to  achieve  a  certain  level  of  fuel  efficiency  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-users 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  efficiency  classes  for  C2  and  C3  tyres  in  the 
proposal for a Directive on tyre labelling, followed, 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 crucial 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  two  ways  of  providing  the  information  most 
effectively: 

•  One  is  to  ensure  that  the  labelling  scheme  (in  its  larger  meaning,  which  includes  the 
grading of fuel efficiency and wet grip and the external rolling noise 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  leaflets  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 easy access to the label. Since all of them already use current 
stickers put by the manufacturers on tyres as a working tool to easily select the right brand, 
dimension and load index, it is proposed to include the label and make it clearly visible on 

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those  specific  stickers.  In  compliance  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 country where the tyres are delivered. 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,  since  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 administrative 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 not have the effect of increasing tyre prices either. Low-budget tyres 
will still be provided for sale on the market; the only change is that objective information on 
tyre parameters will be provided to consumers so that competition does not operate on price 
alone. 

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