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 {COM(2008)779} {SEC(2008)2861}
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) 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 essential parameters  

IMPACT ASSESSMENT 

{COM(2008)779} 
{SEC(2008)2861} 

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TABLE OF CONTENTS 

1. 

1.1. 

1.2. 

2. 

2.1. 

2.2. 

2.3. 

2.4. 

2.5. 

2.6. 

2.7. 

3. 

3.1. 

3.2. 

4. 

4.1. 

4.2. 

5. 

Procedural Issues and Consultation of Interested Parties ..................................... 5 

Organisation and Timing ............................................................................................. 5 

Consultation and Expertise .......................................................................................... 5 

Problem Definition ..................................................................................................... 7 

Fuel-efficient Tyres: the Potential................................................................................ 7 

Possible Trade-Offs...................................................................................................... 9 

Underlying Drivers of the Problem.............................................................................. 9 

Impact on Stakeholders .............................................................................................. 11 

Interactions with Type-Approval Legislation ............................................................ 12 

Evolution of the Problem without EU Action............................................................ 12 

Legal Basis for EU Action ......................................................................................... 12 

Objectives.................................................................................................................. 13 

General, Specific and Operational Objectives ........................................................... 13 

Consistency with Other EU Policies .......................................................................... 13 

Policy Options........................................................................................................... 14 

Identified Policy Options ........................................................................................... 14 

Options Discarded at an Early Stage.......................................................................... 15 

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 with Minimum Requirements on Wet Grip 
and External Rolling Noise for C1 Tyres............................................................... 19 

5.2.1.  Minimum Requirements Set for Wet Grip 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-Efficient 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 

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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 Improvement 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 regarding Fuel Efficient Tyres and End-User 

Benefits ...................................................................................................................... 31 

5.4. 

Option 4: Multi-Criteria Labelling Scheme for C1 Tyres regarding RR and Wet 
Grip Extended to External Rolling Noise .............................................................. 32 

5.4.1.  Potential for External Rolling Noise Improvement 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 Labelling 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. 

6.1. 

6.2. 

Comparing the Options ........................................................................................... 42 

Qualitative Assessment .............................................................................................. 42 

Aggregated Cost-and-Benefit Analysis...................................................................... 45 

6.2.1.  C1 Tyres – Options 2, 3 and 4 ................................................................................... 45 

6.2.1.1.  Fuel and CO2 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 CO2 Net Savings ......................................................................................... 52 

6.2.2.2.  Further Costs .............................................................................................................. 53 

6.2.3.  Summary .................................................................................................................... 53 

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7. 

Monitoring and Evaluation ..................................................................................... 58 

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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  

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. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

1.1. 

Organisation and Timing 

In  its  “Energy  Efficiency  Action  Plan”,  the  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 the aim of tabling a proposal before the end of 
the  legislature,  as  announced  in  the  Communication  on  Greening  Transport  (COM(2008) 
433). 

The  impact  assessment  (IA)  work  was  launched  in  January  2008  supported  by  an  Inter-
Service  Steering  group  (ISG)  including  SG,  LS,  ENTR,  ENV,  ECFIN,  SANCO,  RTD.  The 
agreement  of  the  ISG  was  forthcoming  during  all  critical  steps  of  the  impact  assessment, 
namely: design of the IA and policy options at the 7 March meeting, drafting and publication 
of  the  stakeholders’  consultation  working  document,  results  of  the  26  May  workshop  and 
feedback on the preliminary draft IA on 12 June. 

1.2. 

Consultation and Expertise 

An external study was contracted from December 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 this IA. The external study looked at the technical 
background  supporting  the  design  of  a  labelling  scheme,  including  market  structure  and 
cost/benefit analysis. 

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The  opinion  of  stakeholders  was  gathered  consistently  throughout  the  process  through 
bilateral meetings and various consultations, including a dedicated 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 withdrawn 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,  the  tyre  industry  and  car  producers  (see 
minutes  in  Annex  2).  The  working  document  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 highlighted 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  ways:  (1)  extensive  research,  as  part  of  the 
external  study,  on  the  technical  relation  and  possible  trade-offs  between  tyre  parameters, 
and  (2)  consideration  of  additional  policy  options  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 (ENTR 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 performance allows for seven bands and that the 
“A  to  G”  scale  is  already  a  labelling  scheme  well  known  by  consumers  and  makes  for 
better differentiation between products (see Section 5.2.2). 

•  Some stakeholders requested the inclusion of external rolling 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 
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Directorate-General for Enterprise and Industry of the European Commission. 
See http://ec.europa.eu/enterprise/automotive/pagesbackground/safety/consultation/index.htm. 
See http://ec.europa.eu/energy/demand/legislation/under_discussion_en.htm. 

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•  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  definition  of  such  tyres,  though  the 
designation LRRTs is sometimes used for all tyres 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, the terms fuel-efficient tyres or LRRTs will be 
used  in  the  same  way,  and  will  refer  to  tyres  with  rolling  resistance  lower  than  the  average 
level on the market. 

2. 

PROBLEM DEFINITION 

2.1. 

Fuel-efficient Tyres: the Potential 

Against  the  backdrop  of  current  concern  to  reduce  the  environmental  footprint  of  transport, 
the  Commission  is  looking  into  vehicle  components  as  formulated  in  the  new  integrated 
strategy  to  reduce  CO2  emissions  from  passenger  cars  and  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  consumption).  This  share  of  fuel  is  used  to  overcome 
rolling  resistance  (RR)  caused  mainly  by  what  is  called  “hysteretic  loss”  (loss  of  energy 
through  the  heating  and  deformation  of  the  wheels  while  rolling).  There  has  been  constant 
improvement on rolling resistance over the past decades 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 performance characteristics such as safety 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 and 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 CO2 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 

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6 

European  Conference  of  Ministers  of  Transport,  Making  Cars  more  Fuel-Efficient  –  Technology  for 
Real Improvements on the Road, OECD/IEA, 2005, p.44. 
ETRMA is the European Tyre and Rubber Manufacturer Association representing the tyre industry. 
Drive  cycle  refers  to  urban,  extra-urban  or  motorway  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. 

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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  eight  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 CO2 emissions, as 
illustrated by Figure 1. 

Figure 1: Road Transport CO2 Abatement Costs by Policy Options 

Source: Joint Transport Research Centre 20078 

7 

8 

Life  cycle  analysis  shows  in  addition  that  no  adverse  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  CO2  Emissions  from  Passenger 
Cars, TNO, 2006, p. 119. 
http://internationaltransportforum.org/docs/SPnordwijk07.pdf. 

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Studies9 differ on the exact CO2 abatement costs due to the use of fuel efficient tyres, some 
estimating  it  to  be  negative,  others  to  be  at  €73  t/CO2eq  depending  on  the  fuel  price  and 
reduction assumptions in fuel savings due to rolling resistance, but it is very clear, as shown 
in Figure 1 above, that CO2 abatements costs due to the increased 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  conservative  estimates  (€50  per  oil 
barrel); with the recent increases in the fuel price, CO2 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  promotion  of  market  transformation  towards  fuel 
efficient tyres may be in the interest 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  performance  characteristics  has  therefore  been 
included in the analysis. 

Box 2: Wet grip refers to the safety performance of tyres; it reflects the capacity of a tyre to 
brake on a wet road. There are other parameters which are relevant for safety (namely road 
holding  ability,  directional  control,  deceleration  ability  on  wet  and  dry  surfaces  at  higher 
speed  and  aquaplaning  behaviour)  but  existing  testing  methods  make  it  possible  only  to 
measure wet grip. Since the expert group meeting 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  efficient  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  International  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 suppliers in the design phase of a given 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 constitutes 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  Emission  Reductions  in  Various  Sectors,  INFRAS, 
November 2006, p. 111 or [OECD/IEA 2005] and [TNO 2006]. 
UNECE Regulation No 30: 

10 
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:201:0070:0096:EN:PDF. 

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Figure 2 shows the distribution of RR for all tyre classes (see Box 4). 

Box  4:  Tyre  classes  reflect  the  different  market  segment  of  tyres  related  to  the  type  of 
vehicles for which they are designed. They are defined in the proposal for a Regulation on the 
general  safety  of  motor  vehicles  (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 tyre sales). Each class may then be broken down 
into winter and summer tyres, respectively 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

Truck_Summer
Truck_Winter
C-Type Summer
C-Type Winter
Pass_Summer
Pass_Winter

e
g
a
t
n
e
c
r
e
P

45%

40%

35%

30%

25%

20%

15%

10%

5%

0%

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

RRC

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  imports11,  demand  from  specialised  tyre  retailers  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 respectively by as many as 140 and 250 different 
brands.  This  increase  in  competition  obliges  producers  to  work  more  on  product 
differentiation  and  improving  product  quality.  The  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. 

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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  information  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  the  visibility  and  effectiveness  of  a  labelling  scheme  if  it 
were introduced. 

Figure 3: Share of Replacement Market by Point of Sales 

Total (mil)     31.4        25.4       50.9         16.5        28.1        6.0       15.5         5.1         4.1        3.6  

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

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 authorities 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 obtaining a return on their investments in 
R&D  (R&D  is  already  instrumental  in  obtaining  market  share  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  benefits  exceeding  consumer  benefits  due  to 
transport externalities (reduced greenhouse gases (GHG) emissions, health effect from air 
pollution  caused  by  vehicles’  pollutant  emissions  (NOx,  particulate  matter,  etc.)  and 
increased security of supply (from increased fuel efficiency). 

12 

See in-depth description of the tyre market in VTI, Consumer Label for Tyres in Europe, U. Sandberg, 
March 2008. 

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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 framework 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  resistance  (see  Annex  6).  This  proposal  partly 
addresses  the  market  failure  described  above:  new  requirements  on  wet  grip  will  greatly 
improve road safety since they will ban 30% of the worst-performing tyre from the market. 
New  minimum  requirements  on  external  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 transport energy intensity, momentum exists for 
going beyond these minimum requirements. It is proposed to follow an integrated approach in 
order  to  improve  tyre  fuel  efficiency.  While  type-approval  legislation  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  setting  of  minimum  requirements)  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  the  Car  Labelling  Directive  on  the  other: 
minimum  requirements  ban  the  worst-performing  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  proposed  to  follow  the  same  test 
procedures as those defined in the type-approval legislation and its implementing measures. 

2.6. 

Evolution of the Problem without EU Action 

Improvements in RR (relevant for tyre fuel efficiency) have been and will be further driven 
first  by  the  OE  market,  due  to  the  regulatory  pressure  put  on  producers  to  reduce  car 
emissions, and second by the minimum requirements 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 professionals interested in reducing their costs 
per km must also have driven the market towards 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 will make up only 1% of the market and only 
12% will be below 8.5kg/t, even though the technology exists and is cost-effective. 

No  measures  have  been  put  in  place  on  the  replacement 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 Article 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. 

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3. 

OBJECTIVES 

3.1. 

General, Specific and Operational Objectives 

The above problem definition and its drivers lead to the setting of the following objectives. 

•  General Policy Objectives 

–  Reduce  fuel  consumption  and  related  CO2  and  pollutants  emissions  due  to  road 
transport  in  the  framework  of  sustainable  mobility  and  the  fight  against  climate 
change. 

–  Promote  fuel  efficiency,  hence  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 provision 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 consumers, companies and retailers. 

–  This may include performance grading that would be made available to users via 
different  media  (e.g.  electronic,  catalogues,  label)  allowing  fair  and  objective 
comparison between tyres13. 

3.2. 

Consistency with Other EU Policies 

Increased  market  take-up  of  fuel-efficient  tyres,  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 CO2 emissions from passenger cars (COM(2007) 19, see Box 5). 

13 

14 

The  measured  RR  coefficient  is  by  definition  independent  of  vehicle  load.  This  allows  comparison 
across all tyres irrespective of vehicle size. 
TTE, (Energy) Council on 23 November 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  C02  emissions  from  passenger  cars  and  light  commercial  vehicles 
(2007/2119 (INI)), point 32. 

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Box 5: The revised Commission strategy on CO2 from passenger cars and light commercial 
vehicles  is  based  on  an  integrated  approach  to  reach  the  120g/km  CO2  target  by  2012.  It 
includes  a  target  of  130g/km  CO2  achieved  by  means  of  a  legislative  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 additional measures (COM(2007) 19). These additional 
measures  include  the  setting  of  minimum  requirements  on  tyre  rolling  resistance  but  not  a 
labelling  scheme.  The  benefits  of  the  market  take-up  of  LRRTs  beyond  these  legal 
requirements  discussed  in  this  impact  assessment  will  therefore  add  up  to  the  10g/km  CO2 
target. 

Promotion of market transformation towards fuel efficient tyres complies with the Lisbon and 
renewed  Sustainable  Development  Strategy15  as  it  will  encourage  investment  in  R&D, 
provide  for  a  level  playing  field  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 Transport (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 “industrial policy geared towards more sustainable 
consumption  and  production”,  as  further  elaborated  on  in  the  Action  Plan  on  Sustainable 
Consumption and Production and Sustainable Industrial Policy (COM(2008) 397/3). 

Tyre labelling will also play an important part in the objective of “empowering consumers” 
formulated  in  the  EU  Consumer  Policy  Strategy  2007-2013  (COM(2007)  99)  since  it  will 
enable consumers to make an informed and 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 passenger 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  would  also  be  increased  by  the  proposal  for  a 
Regulation on the general safety of motor vehicles (COM(2008) 316) which will make a tyre 
pressure monitoring system mandatory on passenger cars. 

4. 

POLICY 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 scenario, including the adoption of minimum 
requirements governing RR as proposed in COM(2008) 316 and existing incentives for car 
producers  to  fit  their  vehicles  with  fuel  efficient  tyres  in  order  to  reduce  type-approved 
(TA) emissions measured levels. 

•  Option 2: Single-criterion labelling scheme for passenger 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 tyres (C2 tyres) and for trucks 
and buses (C3 tyres). 

•  Option 3: Dual-labelling scheme for C1 tyres regarding fuel efficiency (RR) and wet grip, 
with minimum requirements on external rolling noise, but no labelling for C2 and C3 tyres. 

15 

OJ L 242, 10.9.2002, and Council Document 10917/06 of 26.6.2006. 

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•  Option 4: Multi-criteria labelling scheme for C1 tyres 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 developed 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 discarded 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 scattered market: tyre imports 
now account for 30% of the market, with a 300% growth in imports from Asian countries 
(China, India and South Korea) over the past five years. Consequently, there appear to be 
too many actors on the market for a voluntary agreement 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, consumer organisations are sceptical about the 
value of such voluntary agreements and favour a harmonised labelling scheme16. 

•  Use  existing  regulatory  initiatives:  a  possibility  could  have  been  to  include  tyres  as  an 
implementing measure of a revised Energy Labelling Directive (Directive 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 CO2 bonus scheme for car producers using fuel efficient tyres on the OE 
market: some stakeholders called for a bonus scheme which could reward car producers 
(for instance with a rebate on the CO2 emissions threshold) for using energy-efficient tyres 
or tyres below the worst one used for “type-approval” emission measurements (mandatory 
measurement of emissions to check whether a car complies with the EU standards defined 
in the “type-approval” legislation). A bonus scheme would run the risk of interfering with 
the ongoing co-decision process on the proposed Regulation on CO2 from cars, or with the 
agreed shares of emission reductions under the integrated 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  that  the  inclusion  of  retreaded  tyres  in  a 
labelling scheme would be desirable, in practice it may be impossible to implement. This is 
mainly  due  to  the  interaction  between  tread  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  Products  Directive  (Directive 
2005/32/EC), Consumer interests in Eco-design (of energy-using products), Sylvia Maurer, 2008. 

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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  complies  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 the Ecologo in Canada proved to have a minor 
impact  on  the  tyre  market  and  to  raise  little  interest  from  the  tyre  industry  itself. 
Stakeholders,  including  the  tyre  industry,  asked  for  a  “performance  label”  instead  –  a 
scheme  that  would  enable  objective  comparison  between  products,  such  as  the  banding 
scheme with the A to G scale used for household 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 their tyres. Market surveys show that “long-
lasting  tyres”  constitute  the  most  important  criterion  in  consumers’  purchasing 
decisions. The market is therefore considered to be self-regulating: 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 potential adverse impact on the environment 
of reduced tread wear (which would increase 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 different 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 absence 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 design 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. 

ANALYSIS 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, which puts pressure on motor vehicle producers to 
reduce emissions, (2) type-approval legislation governing tyres and (3) market demand. 

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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)  procedure.  New  future  requirements  for  car  CO2 
emissions18,  and  tax  incentives  to  encourage  the  purchase  of  cars  with  lower  emissions,  are 
putting additional pressure on vehicle producers. This has led them to request 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 CO2 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  about  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  defined  in  Directive  1992/23/EC  and  its  subsequent  amending 
Directives.  They  will  be  replaced  by  the  proposal  for  a  Regulation  on  the  general  safety  of 
motor  vehicles  (COM(2008)  316)  which  lays  down  the  gradual  introduction  of  minimum 
requirements regarding rolling 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  interviews  with  large  fleet  managers  show,  however, 
that  their  knowledge  about  the  relation  between  rolling  resistance  and  fuel  consumption  is 
very  diverse,  with  (i)  some  fleet  managers  aware  of  the  issue  but  complaining  about  the 
difficulty  of  comparing  tyre  RR  performance  and  its  impact  on  fuel  consumption20,  and 

17 

18 

19 

20 

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). 
Proposal for a Regulation setting emission performance standards for new passenger cars as part of the 
Community’s integrated approach to reduce CO2 emissions from light-duty vehicles (COM(2007) 856). 
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. 
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. 

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(ii) fleet  managers  sceptical  or  unaware  of  the  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 state 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  may  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 factors have been evaluated by [EPEC 2008]. For the sake of this 
impact assessment and to facilitate comparison 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  6.5kg/t,  even  though  the 
technology should be available in the years to come. 

Table 1: Market Distribution 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 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

1% 

1% 

1% 

1% 

1% 

1% 

1% 

2% 

2% 

6% 

7% 

8% 

9% 

9% 

11% 

13% 

17% 

17% 

5% 

6% 

7% 

8% 

8% 

12% 

13% 

17% 

17% 

Source: [EPEC 2008] 

16% 

19% 

22% 

27% 

27% 

39% 

47% 

63% 

63% 

29% 

37% 

43% 

54% 

54% 

36% 

25% 

/ 

/ 

Above 
12 

44% 

29% 

19% 

/ 

/ 

/ 

/ 

/ 

/ 

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Table 2: Market Distribution of C2 Tyres (Summer and Winter), Baseline Scenario 

RRC (kg/t) 

Base SOA 
2004 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

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 

0% 

1% 

1% 

1% 

1% 

1% 

1% 

1% 

1% 

5% 

4% 

4% 

6% 

6% 

8% 

10% 

14% 

14% 

18% 

18% 

21% 

27% 

27% 

46% 

58% 

84% 

84% 

36% 

42% 

50% 

66% 

66% 

45% 

30% 

0% 

0% 

41% 

35% 

23% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

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 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

1% 

1% 

1% 

1% 

1% 

2% 

2% 

3% 

3% 

8% 

9% 

9% 

9% 

9% 

13% 

16% 

17% 

19% 

23% 

24% 

24% 

25% 

25% 

36% 

43% 

48% 

51% 

33% 

34% 

35% 

36% 

36% 

30% 

26% 

24% 

22% 

23% 

25% 

26% 

26% 

26% 

19% 

12% 

8% 

6% 

10% 

7% 

4% 

3% 

2% 

0% 

0 

0 

0 

Source: [EPEC 2008] 

5.2. 

Option 2: Labelling Scheme for RR with Minimum Requirements on Wet Grip 
and External Rolling Noise for C1 Tyres 

5.2.1.  Minimum Requirements Set for Wet 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. 

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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 latter 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  reply  during  the  public 
consultation).  This  judgement  seems  to  be  confirmed  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 driven, (4) the precision of testing methods which may limit the width of the 
bands,  and  (5)  the  market  structure  which  may  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  producers,  the  best  tyres  on  the 
market  in  2008  (with  good  wet  grip  performance)  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  already  exists.  Interviews  with  the  tyre  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  the  production  costs  of  such 
innovations.  It  is  likely  that  above  a  certain  level  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,  production  costs  are  related  to  the  performance 
balance achieved (Figure 4). 

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Figure 4: Performance Optimisation and Production Costs 

Notes 
– Relative noise emission: a higher percentage means a higher noise emission (i.e. >100% is worse). 
– Relative deceleration: a higher percentage means a better braking performance (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 wet grip and RR can be achieved, but at higher 
production costs. 

A single-labelling scheme promoting the optimisation of RR while allowing the possibility to 
keep  wet  grip  at  the  minimum  legal  requirement  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, based on extensive surveys by tyre producers under 
the  external  study  [EPEC  2008],  summarises  increased  production  costs  for  a  given  gain  in 
RR.  It  is  also  likely  that  production  costs  will  decrease  over  time  when  fuel  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% 

Dual Labelling (Option 3)  32.2%  22.2% 15.2% 9.6% 

4.6% 

0.0% 

0.0% 

0.0% 

0.0% 

Source: [EPEC 2008] 

The table shows a non-proportional relationship between production costs and RR reduction. 
This  is  due  to  a  rising  marginal  cost  curve  (a  given  gain  in  RR  implies  increasingly  higher 
R&D investments and production costs). 

EN 

21 

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It  is  not  possible  to  quantify  the  exact  market  transformation  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 addition, empirical surveys show 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 competitive, that retail price will largely reflect 
production costs. 

Increased production costs applied to the average 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 calculation 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 

Price premium (€, excl. VAT)  11.3 

9.6 

7.8 

6.6 

4.2 

5.3 

3.4 

2.0 

1.6 

0 

0 

0 

0 

Source: [EPEC 2008] 

5.2.2.3.  Cost-Effectiveness of Fuel-Efficient Tyres – Case Study 

Estimations  of  increased  production  costs  by  tyre  producers  show  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 pay €14 more to buy an A tyre compared to an 
average  tyre  (in  band  F).  So  the  price  increase  for  a  set  of  four  tyres  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 (return on investment) in that case is six 
months. 

This  case  study  shows  that  it  will  be  cost-effective  for  consumers/end-users  to  buy  tyres 
below 7kg/t once they are on the market. It therefore seems reasonable to expect a labelling 
scheme  to  drive  the  whole  market  towards  this  limit  in  the  short  to  medium  term.  New 
technological  improvements  will  make  the  revision  of  the  labelling  scheme  necessary  at  a 
later stage (around 2020 according to interviews with tyre manufacturers). 

5.2.2.4.  Precision of Testing Methods 

It  is  planned  to  base  the  precision  of  testing  methods  on  the  ISO  28580  measuring  method 
which should be adopted in the first half of 2009. 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 

22 

The Transportation Research Board (TRB) in the USA performed several multiple regression analyses 
to see how tyre prices relate to various tyre characteristics 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. 
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 

22 

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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),  favoured  relative  grading  as  against  absolute 
grading. The rationale behind this is to allow consumers to compare products which provide 
similar  functionalities  and  correspond  to  consumers’  needs.  Someone  needing  a  big 
refrigerator  because  he/she  has  a  large  family  will  not  change  his/her  purchasing  decision 
because smaller fridges obviously consume less energy. The same argumentation may well be 
true for tyres, as consumers have a limited choice in the dimension of the tyres they have to 
replace on a given vehicle. 

A  relative  grading  scheme  would  make  sense  only  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  figures  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 household 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 labelling scheme for tyres. 

Taking  into  account  the  abovementioned  elements,  including  the  technological  threshold, 
evaluated  around  6kg/t,  which  provides  the  starting  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 any 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  groups  shows  that  for  the  credibility  of  the  scheme  it  is 
important to have a band A which can be populated 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 implemented 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 
24 

25 

E.g. as part of the public consultation undertaken by ENTR on the Advanced Safety of Motor Vehicles and Tyres. 
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 numbers). If the outcome  were indeed a revision, it is 
proposed for consistency’s sake that the tyre labelling scheme follows the same design. 
Positions expressed in the 5 June 2008 workshop on car labelling. 

EN 

23 

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–  Since  tyres  parameters  are  interrelated,  setting  band  A  at  too  high  a  level  would  imply 
increased  costs  to  maintain  other  parameters  (wet  grip,  external  rolling  noise,  etc.)  at  a 
satisfactory level, so that it may be less 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  requirements  are  less  demanding,  then 
there will be more tyres in band G and the labelling scheme would become more important 
in driving market transformation. Either the requirements are made more stringent (which 
is  unlikely  as  the  average  RR  on  the  market  in  2008  is  around  11.5  kg/t)  then  band  G 
would  become  empty  but  this  would  reflect  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  classes  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  achieve  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 lowest 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 both 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  challenging  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 technologically feasible in the short 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 opting for the higher classes. 

EN 

24 

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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 market in 2008, band A below 8 would not provide 
an  incentive  for  further  innovation.  In  addition,  bands  F  and  G  would  become  empty  in 
2014 – the presumed date of entry into force of the minimum requirements governing RR 
for all tyre types – if the proposal for a Regulation on the general safety of motor vehicles 
(COM(2008) 316) is adopted. 

5.2.4.  Expected Market Transformation and End-User Benefits 

The  table  below,  based  on  the  first  banding  proposal,  summarises  the  expected  market 
transformation and benefits for consumers/end-users due to a single-criterion grading scheme 
(total economic benefits excluding VAT are presented in Section 6). It presents two scenarios, 
a slow and a fast pace of change (i.e. market transformation towards fuel efficient tyres), in 
order to reflect unavoidable uncertainties surrounding the effectiveness of a labelling scheme. 
This  is  confirmed  by  the  experience  with  household  appliances  where  certain  products 
experienced a very fast market transformation 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 

25 

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Table 6: Possible Grading Scheme and Consumer 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 

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 
(€) 

Total fuel 
savings (€)27 

Payback period 
(months)28 

CO2 real world 
savings (g/km) 

56 

38.4 

26.4 

16.8 

8 

280 

224 

168 

112 

56 

6 

5 

5 

4 

4 

13.6 

10.9 

5.4 

2.7 

0 

0 

0 

0 

-8 

-56 

/ 

-2.7 

in 2012 

0% 

1% 

15% 

16% 

23% 

23% 

8.2 

4% 

e
r
a
h
s

t
e
k
r
a

M

in 2020 
(slow 
pace) 

in 2020 
(fast pace) 

in 2020 
(baseline 
scenario) 

4% 

12% 

27% 

36% 

22% 

0% 

0% 

21% 

23% 

27% 

16% 

14% 

0% 

0% 

0% 

2% 

17% 

17% 

63% 

0% 

0% 

Source: [EPEC 2008] 

The  table  illustrates  that  once  the  market  failure  caused  by  lack  of  information  is  removed 
(labelling scheme, Option 2), the market take-up of fuel-efficient tyres is excepted to be faster 
than with no policy intervention (baseline scenario, 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 

28 

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). 
Assuming that the average mileage of a set of tyres before they are worn out (40 000 km) is achieved 
within 2.5 years. 

EN 

26 

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5.3. 

Option 3: Dual-Labelling Scheme for 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 significant drawback of this measure is that it 
will  blur  the  information  given  to  consumers.  Figure  5  below  illustrates  consumer 
preferences. 

Figure 5: Consumer Preferences for Tyre Parameters, 2006 

Source:  (TAAS)  Tyre  Awareness  and  Attitude  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 efficiency to be very important. 
It is difficult to predict the impact on consumers of providing information on both parameters, 
but it is likely, given the above, that consumers will choose safety first and pay less prominent 
attention  to  fuel  efficiency.  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 Regulation 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, Spain, 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 

27 

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Figure 6: Tyre Distribution by Wet grip 

Source: GRRF quoted in [VTI 2008] 

The chart shows that potential indeed exists 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  are  difficult  to  assess.  First,  vehicle-tyre 
interactions  will  play  an  important  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  for  instance  to  running  into  an 
unexpected  traffic  jam  on  the  motorway  and  which  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 research into accident causes including tyres, but results 
are expected only in five years. 

EN 

28 

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Although knowing the shortcomings of the data available, [TÜV 2004]31 nevertheless made 
an estimation of tyre-related accidents. It shows that tyres account for a large share (45%) of 
vehicle accidents due to technical failures (25% of all accidents resulting in personal injury or 
fatalities),  but  for  a  relatively  low  share  in  all  reported  motor  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  value)  and  under-inflation,  and,  second,  that 
accidents more often occur on wet and 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  direct  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 tyre wet grip must also play a non-negligible role in avoiding 
accidents.  As  [TÜV  2004]  points  out:  “It  is  hardly  possible  to  reconstruct  an  accident  to 
establish the case as whether or not a better tyre 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  cases  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 million37,  shows  that  only  a  small  reduction in  road  traffic  casualties  would 
need to be achieved (around 0.01 to 0.02%) to compensate for the economic loss occurred by 
the  implementation  of  a  dual-labelling  scheme  instead  of  a  single-labelling  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, there  are few data on  the state  of the art on wet grip and the 
related  increased  production  costs.  There  seems  to  be  a  consensus  among  the  tyre  industry 
that the state of the art in 2008 is around 160%. 

31 

32 

33 
34 

35 

36 
37 

tyres  and 

June  2004 

related  aspects, 

TÜV  Automotive,  Survey  on  motor  vehicle 
http://ec.europa.eu/enterprise/automotive/projects/report_motor_vehicle_tyres.pdf. 
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 factor in 3% of all recorded accidents. 
Results from [TÜV 2004], confirmed by the [Safety Net Work Package 5 2008]. 
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. 
Tread depth refers to the “sculpture” on tyres to enable 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. 
ibid pp. 33 & 34. 
Cordis Europe and Trawn et al, 2001. 

EN 

29 

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5.3.3.2.  Production Costs of Optimised Wet Grip and RR 

Production costs and the related price premium (the assumption that price 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 

Price premium (€, excl. VAT) 

Source: [EPEC 2008] 

22.6 

15.6 

10.7 

6.7 

5.3.3.3.  Cost-Effectiveness – Case Study 

4.0 

3.2 

0 

0 

0 

0 

Estimates of increased production costs by tyre producers indicate a potential price increase 
for  end-users  of  32%  compared  to  the  average  price  (€87  including  VAT,  €70  excluding 
VAT), which means that a consumer/end-user would have to pay €28 more to buy an A tyre. 
So  the  price  increase  for  a  set  of  four  tyres  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 VAT38 with a payback period (return on investment) 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 current precision of the ISO 23671 test method, 
which currently does not make for bands narrower than 15%, the following banding schemes 
seem feasible. 

Alternative 1: Medium Approach 

A 

Wet 
index 

grip 

above 145 

B 

145 
130 

C 

D 

E 

F 

G 

to 

130 
115 

to 

below 
115 

empty 

empty 

empty 

Comments: This proposal would leave three classes (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  tyres  in  band  D  are  already  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 

30 

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of  adoption  at  UNECE  level  to  be  satisfactory  in  guaranteeing  drivers’  safety  (see  Section 
5.2.1). 

Alternative 2: More Demanding Approach 

A 

Wet grip index  above 

155 

B 

155 
140 

C 

D 

E 

F 

G 

to 

140 
125 

to 

empty 

to 

125 
110 

below 
110 

empty 

Comments: This proposal is reflecting alternative 2 on fuel efficiency grading. Class D empty 
would  allow  for  more  differentiation  between  product  performance  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 regarding 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 last longer without having to amend the 
classes. 

5.3.5.  Expected  Market  Transformation  regarding  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 transformation than in Option 2 (single-criterion 
labelling  scheme  for  tyre  fuel  efficiency),  for  the  reason  presented  in  the  previous  Section: 
consumers are likely to give priority to wet grip over fuel consumption. On the other hand, a 
label  putting  the  emphasis  on  fuel  efficiency  but  still  providing  grading  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 uncertain (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 

31 

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Table 8: Market Transformation and Consumer Benefits per Set of 4 C1 Tyres (Winter 

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 

Total fuel savings (€)39  

280 

224 

168 

112 

Payback period (months)40 

8 

8 

7 

7 

16 

56 

7 

CO2 real world savings 
(g/km) 

13.6 

10.9 

8.2 

5.4 

2.7 

0 

0 

0 

0 

-16 

-56 

0 

-2.7 

in 2012 

0% 

1% 

4% 

15% 

16% 

23% 

23% 

e
r
a
h
s

t
e
k
r
a

M

in 2020 (slow pace) 

3% 

10% 

25% 

38% 

24% 

in 2020 (fast pace) 

10% 

15% 

25% 

25% 

25% 

0% 

0% 

0% 

0% 

in 2020 (baseline 
scenario) 

0% 

2% 

17% 

17% 

63% 

0% 

0% 

and Summer, VAT incl.) for Moving from Band 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 tyres 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 Scheme 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 for further reducing external rolling noise above 
the minimum requirements set out in the proposal for a Regulation on the general safety of 
motor  vehicles  (COM(2008)  316)  (see  Annex  6).  However,  the  cost  implication  of 
optimisation  of  all  three  parameters  (wet  grip/RR/external  rolling  noise)  is  not  well  known, 
the main trade-off lying between wet grip and external 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 Table 8 in the previous Section. 

39 
40 

Assumption: fuel price at 1.28 €/l incl. VAT, see footnote 26. 
See footnote 30. 

EN 

32 

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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  proposed  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 household appliances, something which 
may  not  be  very  straightforward  to  understand  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  low-noise  road  surfaces,  which 
does not exclude the necessity to act on road surfaces, but shows that acting on tyre external 
rolling noise is cost-effective. According to [VTI 2008], reducing 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 342 (with a later depreciation of 1dB per year), while current market research 
shows  no  evident  correlation  between  tyre  prices  and  external  rolling  noise  (also  for  tyres 

41 

42 

See for instance 
http://circa.europa.eu/Public/irc/env/noisedir/library?l=/position_papers/workingpaper_sept2005pdf/_E
N_1.0_&a=d. 
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 

33 

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with  good  wet  grip  performance)43.  In  any  case,  production  costs  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  possible  to  improve  external  rolling  noise  above  the  minimum  requirements 
proposed for 2012/14, the question arises whether its inclusion in a labelling 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  their  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  lower  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 different noise sources 
(inside the car, noise mainly comes from the power 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 and 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 covering external rolling noise, for others it is 
considered insufficient (see minutes of the workshop in Annex 2). 

Empirical  experiments  show  in  addition  a  discrepancy  between  subjective  perceptions  of  a 
noise level and the external rolling noise measured value. Two tyres demonstrating the same 
noise level in the ISO test procedure may be perceived very differently by the human ear, one 
being perceived to be much louder than the other, even though both have the same measured 
noise value. Since each vehicle will also significantly change the inside noise perception of 
the same tyres, a grading scheme for tyre external rolling noise might be considered unreliable 
by consumers and affect its credibility also with regard to the 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 initiated by the tyre industry on low-noise tyres 
may demonstrate that there is a demand for such products, or that they consider that there is a 
potential for it. According to research done in Austria by Fallast et al44, 94% of respondents 
would  be  willing  to  buy  low-noise  tyres  and  70%  of  them  to  pay  a  small  price  premium. 
However,  it  is  not  clear  if  respondents  differentiated  between  interior  and  exterior  rolling 
noise on the one hand, and on the other if they would indeed pay more for less noisy tyres, 
possibly at the expense of wet grip. 

43 

44 

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. 
Quoted in [VTI 2008], pp. 39–41. 

EN 

34 

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•  Effectiveness in Reduced Traffic Noise 

Since  the  aim  of  including  external  rolling  noise  in  a  labelling  scheme  would  be  to  reduce 
traffic noise, one has to consider whether it would be an effective tool for this purpose. Given 
the logarithmic scale of noise, the effect of a grading scheme on traffic noise may be marginal 
as long as high-noise tyres are on the market. 

Example:  If  an  entire  tyre  population  rolls  with  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 decrease to 72.8dB, and so the overall gain is only 
1.2dB which is inaudible for normal ears (at these frequencies 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 traffic noise may be considered significant. A 1dB 
reduction on 74dB has been attributed a value 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 insight into the potential benefits the promotion 
of low-noise tyres may bring. 

Minimum requirements seem the most effective tool for reducing traffic noise levels as they 
ban the loudest tyres. On the other hand, technological improvements are needed for setting 
more ambitious  minimum  requirements, and they 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  further  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 rolling 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  inhabitants,  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 external 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  variation  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  claimed  low-noise  mark  if  they  found  different 
results due to variability of test 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 

46 

47 

CE Delft, Handbook on Estimation of External Costs in the Transport Sector, produced within the study 
on Internalisation Measures and Policies for All External Cost of Transport (IMPACT), February 2008, 
p. 67. 
Cost-Benefit  Analysis  on  Noise-Reducing  Pavements,  VI  report  146,  Schultz  Information,  2005, 
http://www.vejdirektoratet.dk/publikationer/VIrap146/html/entire_publication.htm#Section7.7, p. 20. 
FEHRL, Tyres/Road Noise, May 2006, Volume 1, p. 91. 

EN 

35 

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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 clear that it would provide 
further  incentives  to  innovate  above  the  minimum  requirements  and  contribute  to  raising 
awareness.  The  evaluation  of  Option  4  will  therefore  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 value 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  (single-,  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 Rolling Noise Minimum Requirements 

Minimum requirements for external rolling noise are already laid down regarding C2 and C3 
tyres in the proposal for a Regulation 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  adoption  of  Standard  Reference  Testing  Tyres  for 
these two categories is under way at ISO level48 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 transpose 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  requirements for C2 and  C3 tyres (by  October 2012/16). 
The  adoption  of  a  single-labelling  scheme  for  RR  with  minimum  requirements  for  wet  grip 
and external rolling noise could therefore be possible 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  professionals  who  already  have  all  the  information 
necessary  for  their  purchasing  decision.  A  labelling  scheme  would  therefore  not  bring  any 
added  value.  This  is  objected  to  by  road  transport  companies  themselves,  including  their 
European federation, the International Road Transport Union, and is also contradicted by the 
current state of the market (showing a large range 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  development  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 basis compared to a Standard Reference Testing Tyre 
(SRTT). 

EN 

36 

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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 transformation path as for C1 tyres is assumed. 
This  is  likely,  however,  to  be  a  conservative  assumption  since  fleet  managers  are 
professionals  and  will  have  the  know-how  as  well  as  stronger  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 maintenance costs compared to 80% for fuel. 

Table 9: Possible Grading Scheme and Consumer Benefits in 2012 per Set of 4 C2 Tyres 
(Winter and Summer, VAT incl.) for moving from Band F to any Other Band 

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 

Total fuel savings50 

460 

368 

276 

184 

Payback period51 
(months) 

2.4 

2 

1.8 

1.7 

CO2 g/km savings 

22.5 

Market share in 2004

in 2020 (slow pace) 

0% 

7% 

18 

0% 

24% 

39% 

27% 

13.5 

9 

5% 

18% 

36% 

41% 

In 2020 (fast pace) 

45% 

23% 

21% 

10% 

Baseline scenario in 
2020 

0% 

1% 

14% 

84% 

0% 

Source: [EPEC 2008] 

6.4 

92 

1.5 

4.5 

0 

0 

0 

0 

0% 

0% 

0% 

0% 

0% 

/ 

/ 

/ 

/ 

/ 

/ 

/ 

/ 

49 

For C2 tyres designed to be fitted on vehicles above 3.5t. 

EN 

37 

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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 starting 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 (including tax, assuming that 100% of heavy-duty 
vehicles run on diesel) for an annual mileage of 60 000 km means an €800 saving per year. 
This leads to very significant 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 order to give an indicative estimate of market 
transformation. It could also be possible for C3 tyres to make a distinction between traction 
(drive axle) and normal tyres (steer and trailer axles) as in the 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  displayed  together  with  the  fuel  efficiency  classes.  In  any  case, 
narrower  bandwidth  should  be  defined  for  a  grading  scheme  for  C3  tyres,  pending  on  the 
accuracy of the testing method, in order to reflect the significant impact on fuel savings of a 
given reduction in RR. 

50 
51 
52 

Assumption: fuel price at 1.28 €/l incl. VAT. 
Assumption: 40 000 average total mileage (in km) over 1.8 years. 
See  Annex  5  of  [EPEC  2008],  Section  5.4.,  for  an  estimate  of  price  premium  and  related  payback 
periods. 

EN 

38 

   EN 

 
                                                                                                                                                         
Table 10: Possible Grading Scheme and End-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 

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 

Total fuel savings53 

3780 

2520 

1260 

Payback period54 
(months) 

CO2 g/km savings 

5 

99 

Market share in 2004

1% 

5 

66 

8% 

5 

33 

0 

0 

0 

0 

/ 

/ 

/ 

/ 

/ 

/ 

/ 

/ 

23% 

33% 

23% 

10% 

in 2020 (slow pace) 

11% 

28% 

43% 

14% 

In 2020 (fast pace) 

39% 

35% 

21% 

4% 

3% 

1% 

Baseline scenario in 
2020 

Source: [EPEC 2008] 

3% 

19% 

51% 

22% 

6% 

0% 

0% 

0% 

/ 

/ 

/ 

/ 

/ 

/ 

/ 

/ 

As for C1 tyres, the two tables clearly show that a labelling scheme for C2 and C3 tyres is 
expected  to  speed  up  the  market  take-up  of  fuel-efficient  tyres  compared  to  the  baseline 
scenario. 

5.5.3. 

Inclusion of Wet Grip in a Labelling Scheme for C2 and C3 Tyres 

There are no reliable data, nor endorsed wet grip measurement methods for C2 and C3 tyres, 
that would support the extension of wet grip grading to these tyre 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  may  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 minimum requirements on noise in the proposal for 
a  Regulation  on  the  general  safety  of  motor  vehicles  (COM(2008)  316)  have  been 

53 
54 

Assumption: fuel price at 1.28 €/l incl. VAT, for a mileage of 100 000 km. 
Assumption: 100 000 average total mileage (in km) over 1.6 years (19 months). 

EN 

39 

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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  rolling  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 state of the market in 2007 shows 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 traffic 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 evidence 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 inclusion of a low-noise mark or simply 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 public 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 clean and energy-efficient road transport vehicles 
(COM(2007) 817)). 

55 

OJ C 82, 1.4.2008, pp. 1–33. 

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40 

   EN 

 
 
 
                                                 
The  Action  Plan  on  Sustainable  Consumption  and  Production  and  Sustainable  Industrial 
Policy  (COM(2008)  397/3)  suggests  that  implementing  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) 

(2) 

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). 

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  labelling  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 office equipment; or (2) in Directive 2005/55 
(Article 6) relating to the measures to be taken against the emission of gaseous and particulate 
pollutants from compression ignition engines for use in vehicles, 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-efficient  tyres  and  increasing  it  on  worst-performing  tyres  as  is 
being done in France and the UK in relation to vehicles (indexing taxes to vehicle emissions 
as reported in the car labelling scheme). This would improve price signals 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  market  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 instruments 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  Industrial  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  competition.  It  may  indeed  happen  that  only  a  few 
tyre producers may be able to produce tyres under 7kg/t (or 6.5kg/t depending on the grading 
alternative  chosen),  so  there  may  be  some  concerns  about  free  competition  and  product 
availability in the A band for public procurement procedures. Since fuel savings may not be 
achieved in a stop-and-go driving cycle57, exemptions in public procurement procedures may 
be provided for such specific driving. 

56 

57 

See  Green  Paper  on  market-based  instruments  for  environment  and  related  policy  purposes 
(COM(2007) 140). 
This is mainly due to the fact that RR varies with tyre operating temperature: a cold tyre has on average 
30% more RR. 

EN 

41 

   EN 

 
                                                 
Estimates  of  the  total  number  of  public  procured  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 significant 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. 

COMPARING THE OPTIONS 

6.1. 

Qualitative Assessment 

EN 

42 

   EN 

 
 
Market 
take-up of 
fuel 
efficient 
tyres 

Market 
failure 

R&D 

Option 1 

Option 2 

Option 3 

Option 4 

Option 5 

Option 6 

+ Bans worst tyres from the 
market and progressively 
improves (i.e. decrease) 
average RR 

+ Information on 
RR only (cid:198) faster 
market take-up of 
fuel efficient tyres 

– Does not harness all 
potential benefits from fuel 
efficient tyres 

– Lower market 
take- up of fuel 
efficient tyres 

– Lower 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  

+ Speeds up 
market take-up 

– Matter for 
subsidiarity: better 
dealt with at 
Member State or 
local level 
depending on 
national 
preferences 

– Does not address the 
market failure on the 
replacement market 

+ Improvement on RR 
driven by the OE market 
with spillover effect on the 
replacement market  

– No incentives for 
innovation on the 
replacement market  

+ Removes the market failure caused by lack of information 

+ Strong incentives 
and rewards for 
investment in R&D 

+ Strong incentives 
and rewards for 
investment in R&D 

+ 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 

+ Optimisation of 
wet grip, RR and 
external rolling 
noise at the same 
time 

Safety 

+ Wet grip requirements 
considered satisfactory by all 
stakeholders 

– No incentives for 
improvement of 
wet grip beyond 

+ Incentives to optimise 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 

43 

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 

NA 

Response to 
consumer 
preferences 

+ Simple message 
to consumers, 
raises awareness 

+ Responds to 
consumer interest 
in tyres 

– Does not reflect 
consumer 
preferences (safety 
first) 

– Potential 
difference between 
TA value and real 
on-road 
performance 
because of vehicle/ 
tyre interaction 

+ Noise grading 
may boost 
innovation and 
market take-up of 
low-noise tyres 

+ Noise grading 
would allow public 
authorities to 
promote low-noise 
tyres 

NA 

NA 

– 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 

– Subjective 
perception of noise 
does not always 
reflect the 
measured values 

– No correlation 
between exterior 
and interior noise 
at low frequencies, 

+ Raises awareness 

EN 

44 

EN 

 
  
6.2. 

Aggregated Cost-and-Benefit Analysis 

6.2.1.  C1 Tyres – Options 2, 3 and 4 

6.2.1.1.  Fuel and CO2 Aggregated Net Savings 

The table below summarises aggregated production costs and benefits due to fuel savings and 
CO2  reduction  in  Options  2,  3  and  4  compared  to  the  reference  case  over  the  period  2012-
2020 reported as the net present value (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 “intensity 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 increased production costs due to optimisation of both 
RR,  wet  grip  and  possibly  external  rolling  noise,  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  pressure  to  reduce  the  RR  of  OE  tyres  (Section 
5.1.1.1) and will not significantly change their behaviour 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 confirmed 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 slightly higher than the estimations below. 

In addition, total benefit in Options 3 and 4 (multi-criteria labelling) 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  instance,  a  €5.5  billion 
benefit should be added per one dB reduction per year at EU-27 level (see Section 5.4.2). The 
exact  benefits  due  to  traffic  noise  reduction  were  not  calculated  in  the  framework  of  this 
impact  assessment,  as  they  will  depend  on  each  road  and  city,  and  the  number  of  persons 
exposed to noise58. 

58 

See  calculation  method  proposed  in  the  technical  annex  to  the  strategy  on  internalisation  of  external 
costs of transport (COM(2008) 435). 

EN 

45 

   EN 

 
                                                 
Table 12: Cumulated Impact of Energy Labelling of C1 Summer and Winter Tyres on 
the EU Economy, NPV of Costs and Savings, 2012-2020, 2008 Prices (VAT excl.) 

Additional 
Tyre Costs 

Fuel Cost 
Savings 

Net Cost 
Savings 

(€m, NPV) 

(€m, NPV)

(€m, NPV)

CO2 
Savings 

(mill. 
tonnes) 

CO2 
Savings 

Total EU 
Benefit 

(€m NPV) 

(€m NPV) 

Slow  Fast  Slow  Fast  Slow Fast  Slow Fast  Slow  Fast  Slow  Fast

Pace of 
Change 

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  based  on  unit  cost  and  cost  savings  and 
estimates of market transformation, values exclude VAT and tax, discount rate of 4% 
and fuel price at €75/bbl, i.e. 0.61 €/l excl. tax and 1.28 €/l incl. tax. 

Cumulated CO2 savings translated into g/km would mean between 1.2 (slow pace of change) 
and 4.1 CO2 g/km (fast pace) under the single-labelling scheme (Option 2) and between 1 to 
2.6  CO2  g/km  under  the  multi-criteria  labelling  scheme  (Options  3  and  4),  which  can  be 
considered  significant  as  it  represents  almost  one  fifth  of  the  10g/km  CO2  savings  target  by 
2012 formulated in the new integrated strategy to reduce GHG emissions from passenger cars 
(COM(2007) 19). 

Conclusion  1:  The  table  clearly  shows  that  net  benefits  in  terms  of  CO2  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 average annual benefit depending on 
fuel prices. The fuel price scenarios are consistent with the energy 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 

46 

   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 price (at €50/bbl) increased production costs may not 
be  compensated  by  fuel  savings  (if  VAT  excluded)  in  Options  3  and  4.  This  is,  however, 
unlikely to happen given recent trends in fuel prices. 

An estimation of CO2 abatement costs was also made taking into account different fuel prices 
(Table 14). 

Table 14: CO2 Abatement Costs (Average Annual) in €/tonne 

Scenario 1 (€50/bbl) 

Scenario 2 (€75/bbl) 

Scenario 3 (€100/bbl) 

Pace of Change 

Slow 

Option 2 

Options 3 and 4 

–59 

47 

Fast 

–55 

50 

Slow 

–138 

–33 

Fast 

–135 

–29 

Slow 

–211 

–112 

Fast 

–207 

–109 

Source:  [EPEC  2008]  Note:  excludes  the  economic  value  of  the  environmental 
benefits of C02 emissions reduction. 

CO2 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 relatively 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_environment_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_environment_energy&root=Yearlies_new_
environment_energy/H/H2/H21/ebc25360. 

EN 

47 

   EN 

 
 
 
 
                                                 
 
Intensity of the Measure 

The  benefits  from  the  introduction  of  a  labelling  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). Under 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  tyre  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 appropriate 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 additional transposition costs in Member States of 
about  €4.04  million.  Assuming  the  regulatory  costs  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 then establish implementing measures under the 
comitology procedure for adaptation to technological changes. 

Monitoring  costs  will  depend  on  the  type  of  test  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 preparation for a grading scheme (see Annex 3 for further details). 
The costs of testing rolling resistance are summarised in Table 15 based on ETRMA input. 

EN 

48 

   EN 

 
Table 15: Costs of Rolling Resistance Testing for C1/C2 Tyres 

Number of Tests per 
Year 

Average Cost 
per Test 

Total Annual Cost 

tests 
Reference  Case 
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 

Additional  costs  of  grading 
compared  to  reference  case 
(see Box 6) 

annualised fixed cost 
of €0.3m 

€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  (TA)  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 discussions on the measuring procedure 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 necessary to measure the worst tyre by a simple pass/no pass test to 
demonstrate the compliance with the minimum requirement of all the others. This procedure 
has  the  advantage  of  reducing  the  number  of  tests  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 scheme will therefore imply a greater number of 
tests and hence higher costs than in the reference case (minimum standards). 

The table shows that annual testing costs for rolling resistance are approximately €1m (costs 
of  grading  minus  costs  for  TA  testing,  which  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,  assuming  that  a  labelling  scheme  with  1kg/t 
bandwidth implies more tests, the 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  after  agreement  by  the  tyre  industry  aimed  at 
decreasing the standard deviation of testing methods 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 

49 

   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 

Grading for C1 tyres 

1 100 

Grading for C2 and C3 tyres 

Additional  cost  of  grading 
compared  to  reference  case 
(see Box 7) 

€2 000 
(600~3 800) 

€0.7m 

€2 311 
(800~4 017) 

€2.5m  plus 
(annualised) of €0.7m 

fixed  cost 

€0.4m 

€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 wet 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 equally 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 significant impact. 

External Rolling Noise 

Giving information on external rolling noise is likely to entail only marginal extra costs given 
that it has to be measured already according to the TA legislation 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 sale 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.  Possible  measures  and  related  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 burden of properly managing a database 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 

50 

   EN 

 
 
 
 
 
 
Table 17: Costs of the Display 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 

Stickers on tyres tread 

Marginal 

(cid:198) will add only one line on 
existing advertising tools and 
can be easily included in 
existing communication 
practices) 

€10m per year, i.e. €0.04 per 
tyre sold (C1/C2), according to 
ETRMA estimates 

Moulding on tyre sidewall 

€13 per mould if implemented 
for new tyre types only (see 
Box 6) 

Mandatory display of the 
information on tyre grading 
(class) with the bill provided to 
the consumers or end-users 

Mandatory display of the 
information on tyre grading on 
catalogues and advertising for 
distance selling 

Marginal 

Marginal 

Would convey the 
information to 
consumers and retailers 
before sale 

- Would contribute to the 
visibility of varying tyre 
performance in RR and 
to awareness-raising 

- Especially adapted to 
tyre dealer shops (see 
Figure 3) 

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 

Allows for greater 
transparency of the tyre 
grading 

Will be essential in 
reaching consumers/end-
users before their 
purchase decision 

Conclusion 3: The real added value of moulding the information on the tyre sidewall is 
uncertain  –  the  information  may  be  too  difficult  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  significant  impact  on  the  import  of  tyres,  though 
import  tyres  were  found  most  of  the  time  to  have  low  RR  but  unsatisfactory  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 proportion of low-income consumers will continue to buy 
budget  tyres  (accounting  for  21%  of  the  total  passenger  car  replacement  market)  with  or 

EN 

51 

   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  labelling  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 the chemical industry as 
they are produced with silica instead of carbon black. Since silica and carbon black are both 
produced in Europe61, it is likely to have no significant impact on external trade. 

6.2.2.  C2 and C3 Tyres – Option 5 

6.2.2.1.  Fuel and CO2 Net Savings 

Table  18  summarises  total  fuel  and  CO2  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 Costs and Savings, 2012-2020, 2008 prices (VAT 
excl.) 

Additional 
Tyre Costs 

Fuel Cost 
Savings 

Net Cost 
Savings 

(€m, NPV) 

(€m, NPV) 

(€m, NPV)

CO2 
Savings 

(mill. 
tonnes) 

CO2 
Savings 

Total EU 
Benefit 

(€m NPV) 

(€m NPV)

Pace of Change  Slow Fast  Slow Fast  Slow Fast  Slow Fast Slow  Fast  Slow Fast

Single 
Labelling C2 

Single 
Labelling C3 

159 

314 

636

1 202 476

888 

4 

7 

69 

130  545  1 018

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  CO2  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 

52 

   EN 

 
 
                                                 
Sensitivity Analysis 

Table 19: Impact of Energy Labelling of C2 Tyres on the EU Economy, Average Annual 
Benefit, 2012-2020, 2008 prices (sensitivity 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) 
Single Labelling (C3) 

32 
40 

57 
115 

52 
85 

93 
254 

71 
130 

129 
393 

+/–38% 
+/–53% 

+/–39% 
+/–55% 

Source: [EPEC 2008] 

Table 20: CO2 Abatement Cost (Average Annual) 

Scenario 1 
(€50/bbl) 
(€/t CO2) 

Scenario 2 
(€75/bbl) 
(€/t CO2) 

Scenario 3 (€100/bbl) 
(€/t CO2) 

Pace of Change 
Single Labelling (C2) 
Single Labelling (C3) 

Slow 
–107 
–44 

Fast 
–105 
–39 

Slow 
–183 
–120 

Fast 
–181 
–115 

Slow 
–259 
–196 

Fast 
–257 
–191 

Source: [EPEC 2008] 

CO2 abatement costs are found to be negative in all fuel price scenarios. 

6.2.2.2.  Further Costs 

Administrative  costs  and  monitoring  costs  should  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 for 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 cost of display of the labelling scheme can 
therefore be considered marginal. 

6.2.3. 

Summary 

•  Impact on customers: Customers will benefit from a labelling scheme as they will have 
the  opportunity  to  objectively  compare  tyres  and  make  an  informed  choice.  Since  fuel 
savings  exceed  the  related  increase  in  production  costs,  they  will  make  increasing  net 
savings the higher the grading of the tyres they buy. The impact assessment shows that a 
multi-criteria  labelling  scheme  (Options  3  and  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 quantify 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 competition and increase pressure towards better-

EN 

53 

   EN 

 
 
 
performing  tyres.  A  labelling  scheme  will  imply  higher  costs  due  to  testing,  stickers  and 
display of the labelling scheme via advertising tools. Producers are likely to pass on these 
costs  to  customers,  which  per  tyre  sale  remain  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 C1, C2 and C3 on the EU Economy, Average 
Annual Benefit, 2012-2020, 2008 Prices (Oil Price Scenario 2) 

Total Annual Average EU Net Benefit (€m) 

Vehicle Type 

C1 – Option 2 (Single labelling) 

C1– Option 3 and 4 (Multi-criteria labelling) 

C2 – Option 5 (Dual Labelling RR/noise) 

C3 – Option 5 (Dual Labelling RR/noise) 

Total Option 5 

Source: [EPEC 2008] 

Slow 

115 

11 

52 

85 

226 

Fast 

376 

18 

93 

254 

591 

Options  3  and  4,  multi-criteria  labelling  scheme  for  C1  tyres  makes  for  a  slower  annual 
benefit  than  Option  2  because  of  higher  production  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 

Tyre class 
C1 (labelling RR) 

C1 (multi-criteria label)  260 

Slow  Fast  Slow
0.3 
326  1 104
0.24 
694 

C2 (labelling RR) 
C3 (labelling RR) 
Total (Option 5) 

99 
226 
585 

0.1 
181 
0.22 
701 
1576  0.56 

Fast 
1.02 
0.64 

0.18 
0.69 
1.51 

Slow 
253 420 
202 114 

36 000 
14 504 
252 620 

Fast 
858 210 
539 490 

65 818 
44 987 
650 295 

Share of new 
vehicle 
registrations in 
Europe (2006) 

Slow 
2% 
1% 

2% 
3% 

Fast 
6% 
4% 

3% 
10% 

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 

54 

   EN 

 
 
 
 
 
Figure 9: Fuel Cost Savings (€m) for the  EU Economy for the Labelling 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  greater  in  Option  2  (single-criterion  labelling 
scheme)  than  in  Options  3  and  4  due  to  faster  market  transformation,  however  Options  3 
and/or 4 might be the preferred option due to safety gains (see Section 6.1). In any case, the 
impact  assessment  clearly  shows  that  Option  5,  extension  to  C2  and  C3  tyres,  provides  the 
most significant benefits. 

EN 

55 

   EN 

 
 
 
•  Impact on society (health – safety and external rolling noise – and 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 average annual fuel savings 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 labelling scheme for tyre fuel efficiency 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 even in the most conservative scenario. In total 
for Option 5, CO2 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 compared to the initial policy objectives defined 
in Section 3. 

Legend 

Very Positive 

Positive 

Slightly Positive 

+++ 

++ 

+ 

Negligible 
Impact 

or  No 

0 

Slightly Negative 

Negative 

- 

- - 

Very Negative 

- - - 

62 

It is also worth emphasising that life cycle analysis shows that LRRTs 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  black  carbon  by  silica will  reduce  the  environmental 
impact of tyres because carbon black, which is produced from fossil fuel, has a higher CO2 footprint. 

EN 

56 

   EN 

 
 
                                                 
Table 23: Summary Assessment of Policy Options 

General policy objective 

Specific objective 

Reduce 
CO2 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 

Option 1 

Option 2 

+ 

++ 

Option 3 

+ 

+ 

++ 

+ 

Option 4 

+ 
same as 
Option 3 

+ 
same as 
Option 3 

0 

++ 

+++ 

+++ 

-- 

++ 

+ 

- 

++ 

+ 

+ 
same as Option 
3 

+ 
same as Option 
3 

0 

0 

+++ 
exceeds 
objective 

+ 
depends on 
national 
preferences and 
feasibility 

Option 5 

+++ 

+++ 

+++ 

++ 

Option 6 

+ 

+ 

EN 

++ will speed up
market 
transformation 

57 

++ 

+ 

+++ 

+ 

Operational 
objective 

Provide easy-to-
understand 
information to 
consumers/ 
overcome market 
failure 

Administrative 
burden 

-- 

+++ 

++ 

++ 

++ 

+ 

0 

- 

-- 

-- 

-- 

--- 

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  testing  methods  (problem  with  test  track 
variation) and the subjective weight given to traffic noise reduction. 

7. 

MONITORING AND EVALUATION 

The  main  monitoring  element  will  be  the  tests  carried  out  for  new  product  grading. 
Monitoring of the effects should be done via market 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  towards  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  Member  States.  The  main  issues  for  a  possible 
revision of the proposed labelling scheme are: 

–  Appropriateness  of  an  absolute  grading  scheme  –  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  than  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  following  market  evolution,  etc.)  could  be 
implemented through comitology. 

Taking into account the time necessary for collecting, analysing and complementing the data 
and  experience  related  to  implementation  of  the  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 Technical 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: 
the general safety of motor vehicles (COM(2008) 316) 

Minimum  Requirements  on  Tyre  defined  in  the  Proposal  for  a  Regulation  on 

EN 

58 

   EN 

 
Annex 1: Minutes of the Technical 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 group meeting on tyre labelling – 21 April 2008 

Attendees:  Johannes-Josef  BAUMHÖFER  (Continental),  Alix  CHAMBRIS  (DG  TREN), 
Fazilet  CINARALP  (ETRMA),  Georges  DIMITRI  (Michelin),  Simone  FALCIONI 
(Bridgestone), Bernd HARTMANN (Continental), Stefan KÖPEEN (Good Year), Jean-Paul 
LAMBOTTE (Good Year), Christophe PENANT (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 for 26 May. The discussion was divided into two 
parts: one on rolling resistance and tread wear, the other on wet grip. 

1. Working document on absolute versus relative grading and tread wear 

-see original working document in annex A below  

1.1  Assessing  the  relevancy  of  a  relative  grading  scheme  for  rolling  resistance  versus 
absolute grading (questions 1 to 3) 

A  relative  grading  scheme  would  make  sense  only  if  there  is  a  proven  correlation  between 
rolling  resistance  coefficient  (RRC)  and  other  parameters  such  as  external  diameter  (OD) 
and/or load index (LI). 

The tyre industry position was that there was indeed a correlation for C1 and C2 tyres but that 
it was too weak to justify a relative grading scheme, 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 grading scheme, with all 
data  provided  showing  the  existence  of  a  correlation  even  if  the  regression  coefficient  (R2) 
was low. In addition more accurate measurement 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  improve  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 larger for smaller tyres. 

•  It would guarantee that consumers will find A tyres in all tyre dimensions. 

EN 

59 

   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 methods would not allow a satisfactory information 
scheme for tread wear (Q5): there was agreement 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  would  be  too  high  for  a  labelling  scheme  to  be 
cost-effective on this specific tyre parameter. 

Figures showed no trade-off between RR and tread wear on C1 tyres, 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  that  tread  wear  was  a 
parameter consumers could clearly assess when 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 minimum requirement set for 2012 according to UNECE 
Regulation 117 and the draft proposal 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 performances on wet grip were wide enough for a 
banding  scheme  for  both  C1  and  C2  tyres  provided  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 grip 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  estimations  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  the  trucks,  but  no  serious  study  underpinned  this 
statement for the time being. 

EN 

60 

   EN 

 
2.2.  Assessing  the  correlation  between  wet  grip  performance  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-holding  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  group,  there  was  no  risk  in  communicating  to 
consumers just the wet grip safety parameter (Q4). 

The widening of a grading of wet grip to include other safety parameters should in any case 
be based on a specific impact assessment, 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 results of the work going on within the new ISO 
28580, an agreement was found within the ISO working 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 width should be defined for the grading scheme. 

The question of the width of the bands remained open as long as no evidence was provided on 
the  real  increase  in  costs  for  more  accurate  tests.  It  was  clear  that  the  success  of  a  banding 
scheme was directly linked to the differentiation 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 relative 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  may 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 directly 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 are 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 

61 

   EN 

 
                                                 
•  The  following  graph  from  Dominique  Aimon  (Michelin)  presentation  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 allow unfair comparison between tyres with no 
small tyres performing in the A grade and no bigger tyres in the G grade.  

)
t
/
g
k
(

T
R
R

/

15,0

14,0

13,0

12,0

11,0

10,0

9,0

8,0

7,0

6,0

5,0

P metric STH

Data based on rolling resistance measurements of Original 
Equipment and replacement tires from Europe North America and

STH

LET1

LET2

ULET1

ULET2

SULET

REG STH

Standard 
tires

LET1 

LET2

ULET1

ULET2

SULET
650 

700 

750 

800 

850 

Diameter (mm)

550 

600 

Source: Dominique Aimon (Michelin), Supporting the development of Low Energy 
Tires, 
7,  
http://www.iea.org/dbtw-wpd/Textbase/work/2005/EnerEffTyre/aimon2.pdf  

slide 

Bruce Lambillotte (Smithers Scientific Services) presentation seems to confirm this statement 
(slide  33,  see  link  bellow)  but  shows  that  load  index  may  also  be  a  relevant  factor  for 
differentiation (slide 35).  

Source:  Bruce  Lambillotte,  Task  4  Rolling  Resistance  Testing:  California  Energy 
Commission's  Fuel  Efficient  Tire  Program,  Workshop  on  the  Fuel  Efficient  Tire 
Program, 
07/12/2007, 
http://www.energy.ca.gov/transportation/tire_efficiency/documents/2007-12-
07_workshop/presentations/Lambilotte_Bruce_Task%204%20Rolling%20Resistanc
e%20Testing.pdf 

Scientific 

Services, 

Smithers 

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 testing methods with a confidence interval of ±0.5 
kg/t  compared  to  ±0.75  kg/t  will  influence  the  strength  of  correlation  (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 question of the design of a relative grading scheme arises.  

EN 

62 

   EN 

 
 
 
Dominique  Aimon  in  its  presentation  proposes  apparently  a  simple  formula  to  allow  for  a 
relative grading. See slide 6: RR threshold= 0.0000212 (OD x OD) – 0.041 OD +27.7  

Q3:  Do  you  suggest  an  alternative?  Can  you  agree  on  a  formula  or  a  simple  way  to  define 
tyres categories (for example by car sizes) for a relative grading scheme?  

3. Trade off between rolling resistance and tread wear 

Given  the  fact  that  it  is  technically  possible  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  addition  show  that  wear  (i.e.  "long  lasting  tyre")  is  the  most 
important criteria in consumers purchasing decision.  

Taking  into  account  however  that  no  testing  methods  are  currently  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 share in the long run. The market could in this 
case be considered as self regulating. 

Q4:  Do  you  agree  with  this  argumentation,  i.e.  that  the  market  is  self-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  labelling  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  tyres  will  be  mandatory  by  2012/14.  This  will 
guarantee that improvement on improvements on rolling resistance will not deteriorate safety 
bellow this minimum requirement which was considered within the UN-ECE working group 
as  sufficient  (at  that  time  experts  considered  that  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 scheme 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  rationale  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 relevant 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 minimum requirement set for wet grip)?  

EN 

63 

   EN 

 
2. Labelling tyres on wet grip 

A  possibility  to  address  this  risk  is  the  inclusion  of  a  grading  on  tyre  safety  performances 
together  with  a  grading  on  rolling  resistance.  Considering  that  the  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 possible 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 introduced such as for rolling resistance there should 
be sufficient differentiation on the market between 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 also 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 bellow) 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 

64 

   EN 

 
 
Q2.1: Is the range of tyre performances on wet grip wide enough for a banding scheme, e.g. 4 
or 7 bands (also in a given tyre dimension relevant for consumer)?  

Q2.2:  Could  a  parallel  grading  on  wet  grip  help  avoiding  overall  deterioration  of  the  safety 
performance of tyres under the influence of improved RR? 

2.2.  Communicating  on  tyre  wet  grip  performance:  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  ability,  directional  control,  deceleration  ability  on  wet  and  dry 
surfaces and aquaplaning behaviours. 

Q3:  What  is  the  correlation  of  the  tyres  performance  on  wet  grip  with  the  other  safety 
parameters?  

Q4: Is there a risk to convey misleading information to consumers when communicating on 
the sole wet grip performance as a safety parameter? 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  mandatory  from  2012  (date  of  implementation  of 
minimum  requirements  on  wet  grip)  as  set  in  the  draft  proposal  for  a  regulation  on  general 

EN 

65 

   EN 

 
 
safety of motor vehicles, will be those defined 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  certification  methods  accurate  enough  for  a  banding 
scheme? 

Q5.2: What is reasonably achievable within the ISO working group? To what extent can the 
standard deviation of the existing tests be reduced?  

Testing  tyres  to  comply  with  a  minimum  requirement  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 the adoption of SRRT for C2 and C3 tyres?  

EN 

66 

   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 

FINAL MINUTES of the 

Stakeholder Workshop on tyre labelling – 26.05.08 

Brussels, 09.06.08 
TREN/D3/AC D(2008) 

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 initiative 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  the  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  CO2  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 the 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  consumption  between  the  best-  and  the  worst-performing 
tyre of 10% (a 10% reduction in RR meant on average 2% fuel savings). LRRTs were cost 
effective but their development tended to be hampered by lack of consumer information, and 
thus a market failure. Various studies had identified a fuel savings potential due to the market 
take-up of LRRTs of approximately 3%, leading to a saving of 100 billion euros from 2008-
2030 and a C02 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 would 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 

65 

EN 

Europe  Economics,  Impact  assessment  study  on  a  possible  extension,  tightening  or  simplification  of 
labelling  of  household  appliances,  2007, 
Framework  Directive 92/75 EEC  on 
http://ec.europa.eu/energy/demand/legislation/doc/2008_02_22/2008_consultation_energy_labelling_ap
pendix2_en.pdf 

energy 

67 

   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 stakeholders’ views on the possible introduction of 
an  energy  labelling  scheme  for  tyres  allowing  for  improvements  of  tyre  performances 
above  the  minimum  requirements  set  in  the  abovementioned  package.  Special  emphasis 
was given on possible trade-off between the optimisation 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 
on 
consultation 
replies 

that 
http://ec.europa.eu/energy/demand/legislation/under_discussion_en.htm.  Written 
had been downloaded onto the same webpage. 

published 

April 

2008 

was 

for 

on 

28 

Yes  No 

Q1: Do you agree that a grading on rolling resistance, for C1/C2  and C3 
tyres, being made available to end users 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  which  would  provide  end-users  with  an  objective 
comparison  between 
in  promoting  market 
tyre  performances  would  be  effective 
transformation  towards  LRRTs.  The  Netherlands  had  experienced  a  very  good  feedback  on 
their  programme  on  “safe,  silent  and  climate-friendly  tyres66”  which  proved  the  momentum 
for policy action on this issue. The programme included the testing of a great number of tyres, 
with publication of the measured value and a wider awareness-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  information  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  Sandberg  from  VTI  also  pointed 
out that some big and medium fleet companies had contacted him to ask whether a transparent 
and objective grading scheme existed, which proved an interest in the development of such a 
scheme  on  their  part.  T&E  and  the  Dutch  government  highlighted  that  public  authorities 
would  benefit  from  a  grading  scheme  and  could  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  2004  state  of  the  market  provided  by  ETRMA 
(showing a difference in RRC of up to 100%) seemed also to confirm that the market might 
not be functioning that well. The range in RR tyre performance of C3 tyres would be much 
narrower if road transport companies were well informed – knowing that “costs per km” was 
one of the first parameters they wanted to optimise. 

66 

http://www.destilleband.nl. 

EN 

68 

   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 proposals for the introduction of rolling resistance 
testing into the relevant UNECE tyre regulation (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 those 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 defined more strictly so as to have a small range 
of  tyre  performance  inside  one  family).  First  figures  provided  by  ETRMA  estimated  these 
extra costs for C1 tyres at 0.006cent per tyre on average, but this would be further developed 
in the impact assessment. 

Conditions noted as being necessary for the success of an energy labelling scheme in fostering 
market transformation towards LRRT included: 

•  Simplicity of information provided to end users. 

•  Transparency of data, which could 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 costly) 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 available (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 investigate this point. 

–  More  bands  allowed  for  better  differentiation  amongst  products  and  a  stronger 
message towards consumers (DG TREN experience from other labelled products). 

–  No tyres in band A (T&E) in order to provide incentives for further innovations, 
with  a  different  point  of  view  raised  by  DG  TREN  (experience  with  other 
products showed that the credibility of the label increased 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 precision of measuring methods (feasibility) and 
the potential for market transformation. 

EN 

69 

   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  the  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 implementation of a grading scheme but should be 
improved in the long run. This needed to be further 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). 

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)? 

Yes  No 

(X?)  X 

The  2004  state  of  the  market  provided  by  ETRMA  showed  a  difference  in  average  rolling 
resistance  between  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). These contrasting results might be the consequence of different designs of winter tyres: 
tyres for Scandinavian countries are made to roll on ice and snow, in other countries they are 
made to roll on mud and wet road, with different techniques and tread patterns used in both 
cases.  According  to  VTI,  this  difference  was  too  small  and  the  results  too  contradictory  to 
justify  a  different  grading  scheme.  Norway  suggested  including  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 take 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  resistance  and  wet  grip  in  a  given  technology  was 
confirmed by all stakeholders, even though evidence indicated that it was technically feasible 
to  improve  all  tyre  performance  characteristics  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 characteristics (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  for  wet  grip  in  the  labelling 
scheme together with rolling resistance. 

At  present,  only  information  on  wet  grip  could  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 setting minimum requirements governing wet grip 
for C1 tyres (in order to avoid lower external rolling noise being achieved while decreasing 
wet grip). According to a technical experts’ meeting, which took place on 21 April, there was 

EN 

70 

   EN 

 
 
 
 
a good correlation between tyre performance regarding wet grip and other parameters relevant 
for  safety  such  as  aquaplaning,  handling  in  curves,  dry  grip  and  wet  grip  at  higher  speeds. 
Stakeholders  did  not  contest  this  outcome,  but  highlighted  the  necessity  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). 

Q4: Should a grading on wet grip also include C3 tyres? 

Yes  No 

X 

X 

The possibility of including C3 tyres in a wet grip grading would depend 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 information 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 Q1, second paragraph). According to the German 
Ministry  for  Transport,  the  inclusion  of  C3  tyres  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. 

Q5:  Is  the  display  of  the  measured  noise  value  in  a  labelling  scheme 
technically feasible and understandable for consumers? Do you think that it 
would  have  any  significant  effect  on  the  market  below  the  minimum 
requirements set for external rolling noise? 

Yes  No 

X 

X 

This  question  was  controversial,  with  one  side  heavily  in  favour  of  introducing  external 
rolling  noise  into  the  labelling  scheme  and  the  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 (German Ministry for Transport). 

Considering the opposition of the tyre industry to a banding scheme for tyre external rolling 
noise, T&E proposed a low-noise mark for tyres 3dB below the  minimum requirement (see 
proposal  in  Annex  2).  M+P/T&E/the  Netherlands/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 noise should be also 
included in order to give incentives for optimisation of all three parameters (RR, wet grip 
and external rolling noise). 

EN 

71 

   EN 

 
 
 
•  Information  to  be  provided  under  the  labelling  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  valuable  information  to  end-users. 
There appeared to be a good correlation around 1 000 Hz (>70%) but a weak correlation at 
low  frequencies  (“because  it  is  masked  by  other  noise  sources  like  drive  line  or  tyre 
induced vibrations”), thus giving an overall moderate correlation (about 25%) (M+P). 

•  Transparency of data on external 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  standard  deviation,  the  best  tyres  within  the 
same  family  would  be  at  maximum  0.5dB  below.  So  the  proposal  to  adopt  a  low-noise 
label for tyres 3dB below the minimum requirement 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 possibility to produce tyres with external 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 marketing 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 willing 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  environmental  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  contest  the  claimed  low-noise  mark  if  they 
found different measured values due to variability of test tracks. 

EN 

72 

   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. 

Q6:  Do  you  consider  that  some  of  the  issues  raised  in  the  preceding 
questions should be considered for retreaded tyres? 

Yes  No 

(X)  X 

Though the majority of stakeholders agreed that in theory retreaded tyres should be included 
in  the  labelling  scheme,  there  was  currently  insufficient  knowledge  for  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 that five retread companies applied voluntarily for the Nordic 
Swan logo, but only for a limited number of tyre dimensions (ETRMA). 

BIPAVER  representing  the  independent  tyre  retread  industry,  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  between  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  treads,  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 

X? 

Q7: Do you think that a grading scheme could be used by car manufacturers 
to  offer  better  performing  tyres  to  their  consumers?  Do  you  think  that  car 
manufacturers  can  take  advantage  in  their  marketing  strategy  from  a  tyre 
labelling scheme? 

Q8: Should the grading of OE tyres (tyres originally fitted to new vehicles) 
be made available on catalogues and advertising tools on cars? 

Q9:  What  will  be  the  likely  impact  of  the  worst  tyre  principle  defined  for 
emissions measurement, on average rolling resistance of OE tyres? Is there 
a need to encourage car manufacturers to offer tyres with improved rolling 
resistance compared with the ‘worst case’ tyre used for the mandatory tyre-
approval measurement? 

As  no  representatives  from  the  car  industry  were  present,  these  questions  were  not  tackled. 
The  only  written  reply  received  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  influence  consumers  when  they  replaced  their  tyres.  58%  of 
consumers replaced their tyres with the same ones as the OE tyres, according to one member 
company survey by ETRMA (other consumer surveys show a share of around 20%). 

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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 between endorsement labels such as the Nordic 
Swan (declaring that a specific product complied 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 (Directive 1992/75/EC) showed the effectiveness 
of performance labelling in pushing market transformation towards energy-efficient products; 
this would be the type of label favoured by DG TREN for tyres. 

On the question raised by the German delegation whether the grading scheme would be static 
or dynamic, the Chair replied that this depended on the speed of technological change in one 
product.  The  discussion  about  dynamic  and  static  labelling  schemes  was  being  addressed 
within  the  revision  of  the  abovementioned  Directive  on  household  appliances,  a  labelling 
scheme for tyres would certainly follow the outcome. 

There was a wide consensus on the mandatory display of the labelling scheme in catalogues, 
communication tools and on the internet. Disagreement 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 language constraints (tyres were produced in one 
production centre for export in all EU Member States and third countries). 

Availability  of  measured  values/grading  was  recalled  by  VTI  and  T&E  asking  for  a  public 
database, with reservations on costs and complexity of implementation (updates, liability of 
information, etc.) expressed by DG TREN and the German delegation. The Chair suggested 
also giving the information on tyre grading on the bill provided to the consumers or end-users 
so as to ensure reliability and transparency 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 Environment) but faced strong opposition as regards the 
costs/benefits  of  this  measure  (ETRMA/BIPAVER/German  Ministry  for  Transport).  No 
figures could be given, however, on both sides. Eurocities noted that moulding information on 
tyre  performance  on  the  side  wall  may  be  instrumental  for  those  cities  wishing  to  restrict 
worst-performing  cars’  access  to  the  city  centre  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  Dutch  delegation  proposed  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 that 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. 

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See  also  on  this  matter  the  answers  to  Q1  on  conditions  to  be  met  for  the  success  of  a 
labelling scheme regarding RR. 

Q12: Do you think that the 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 public procurement of replacement tyres, 
fiscal incentives…)? 

Yes  No 

X 

X 

Incentive schemes through public procurement procedures had (1) already been 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 demanding than those defined 
in  the  ENERGY  STAR  programme  when  purchasing  office  equipment,  or  (2)  were  being 
considered such as in the revision of the energy 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  labelling  scheme  would  be  instrumental  for  cities, 
companies  and  public  authorities  in  the  design  of  proactive  purchasing  policy  or  fiscal 
incentives. 

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Annex A: List of participants 

EU Member States 
Germany, Ministry for the Environment and Ministry for Transport 
Spain,  University  Institute  for  Automobile  Research  in  the  name  of  the  Spanish  Interior 
Ministry, Road Traffic Directorate 
The Netherlands, Ministry for the Environment and Ministry for Transport 

EFTA Member Countries 
Norway, Public Road Administration 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 Retreader organisation) 
ETRMA (Goodyear, Bridgestone, Michelin, 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 Department of the Flemish Government 
PSA Peugeot Citroën 
WDK (Wirtschaftsverband der deutschen Kautschukindustrie) 
IRU (International Road Transport Union) 
Rhodia 

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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 property 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),  load  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  outside  diameter  are  found  in  the 
third factor67. 

Empirical correlation: Empirical measurements show a correlation between OD or LI and RR, 
but  its  significance  varies  among  tyre  producers  Some  figures  provided  by  tyre  producers 
show  a  regression  coefficient  (relevant  to  prove  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 still 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 grading scheme: The proven correlation between OD or 
LI means that an absolute grading scheme (horizontal lines on a graph showing RR and OD) 
will favour larger tyres and discriminate smaller ones. It will be easier for larger tyres to reach 
the upper bands due to their size advantage, there 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 either scenario may be neutral: a relative grading scheme will 
put more pressure on bigger tyres where absolute fuel savings and CO2 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 grading scheme but with no 
unanimity of its members. Given the uncertainties on this issue, it is suggested 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 label but just the grading. 

67 

68 

LI and OD are interrelated as bigger cars need bigger tyres (higher OD) but are also heavier and hence 
need higher LI. 
In this case – correlation measured in only one tyre line – the high regression coefficient is due to the 
fact that factor 2 (property of the material) does not enter into play. 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 performance of the tyre (as each parameter is integrated). 

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Annex 4: Sample of Labelling Scheme 

•  Existing labelling scheme used on household appliances 

•  Proposal for a low-noise label by T&E 

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Annex 5: Economic Data Relevant for the Impact Assessment 

Market data 

Table 1: The EU Market for Tyres Sold for Original Equipment (OE) and as 
Replacements (million) 

2007 Share (%) 
by Vehicle 
Type 

2007 Share (%) 
of Total Tyre 
Sales 

Market Segment 

2005 

2006 

2007 

PC replacement – EU production 

PC replacement – Imports 

Total PC replacement 

PC OE – EU production 

PC OE – Imports 

Total PC OE 

181 

43 

224 

61 

1 

62 

189 

45 

235 

64 

0 

64 

182 

48 

231 

63 

2 

65 

61% 

16% 

78% 

21% 

1% 

22% 

TOTAL Passenger Car (PC) 

286 

299 

296 

100% 

LT replacement – EU production 

LT replacement – Imports 

Total LT replacement 

LT OE – EU production 

LT OE – Imports 

Total LT OE 

TOTAL Light Truck (LT) 

TBs replacement – EU production 

TBs replacement – Imports 

Total TBs replacement 

TBs OE – EU production 

TBs OE – Imports 

Total TBs OE 

TOTAL Trucks & Buses (TBs) 

All Vehicle Tyre Sales in EU 

Total replacement sales 

Total OE sales 

15 

4 

19 

7 

1 

7 

26 

11 

4 

15 

0 

0 

0 

0 

312 

258 

69 

15 

4 

19 

7 

1 

8 

27 

11 

5 

16 

2 

0 

2 

18 

344 

270 

74 

16 

4 

20 

7 

1 

8 

28 

11 

5 

16 

2 

0 

2 

18 

342 

267 

75 

57% 

14% 

71% 

25% 

4% 

29% 

100% 

61% 

28% 

89% 

11% 

0% 

11% 

100% 

53% 

14% 

68% 

18% 

1% 

19% 

87% 

5% 

1% 

6% 

2% 

0% 

2% 

8% 

3% 

1% 

5% 

1% 

0% 

1% 

5% 

100% 

78% 

22% 

Source: Europool (courtesy ETRMA), ACEA 
PC – passenger cars, LT – light transport vehicles, TBs – trucks and buses 

Tyres  sold  in  the  replacement  market  for  passenger  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. 

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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 

Winter 

70%

30%

69%

31%

74%

26%

70% 

30% 

 Source: 
PC – passenger cars, LT – Light transport vehicles, TBs – Trucks and buses 

ETRMA), 

(courtesy 

Europool 

ACEA 

Table 3: Projected EU Market for Replacement Tyres C1, C2 and C3 (millions), 
including imports 

C3-TBs
Summer Winter

Vehicle

C1-Passenger cars

C2-CV/LT

Type of Tyre Summer Winter
            166            65 
            165            71 
            170            73 
            174            74 
            178            76 
            182            78 
            187            80 
            191            82 
            195            84 
            200            86 
            205            88 
            210            90 
            215            92 
            220            94 

2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020

Total

Total

Summer Winter

Total
         231             14              6             20               12               4            16 
         236             14              6             20               12               4            17 
         242             14              7             21               13               4            17 
         248             15              7             22               13               5            18 
         254             15              7             22               13               5            18 
         260             16              7             23               14               5            18 
         266 
            14               5            19 
          23 
         273             16              7             24               14               5            19 
         279             17              7             24               15               5            20 
         286 
            15               5            20 
          25 
         293             17              8             25               15               5            21 
         300             18              8             26               16               6            21 
         307 
            16               6            22 
          27 
         314             19              8             27               17               6            22 

          16 

          18 

          17 

           7 

           8 

           8 

Source: Europool (Courtesy ETRMA), ACEA and DG TREN Pocket Book 

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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) 

C2 

10.5kg/t 

(new TT) 

10.5kg/t 
(existing TT) 

C3 

8kg/t 

(new TT) 

10.5kg/t 

(new TT) 

9kg/t 

(new TT) 

8kg/t 

(existing TT) 

6.5kg/t (new TT) 

10.5kg/t 

(existing TT) 

9kg/t (existing TT) 

6.5kg/t 

(existing TT) 

Box 7: A distinction is made between new tyre type (TT), i.e. a new production line or brand 
which has to pass through the type-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  between  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, this is why no estimation is given for C3 tyres. 

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Minimum Requirements for External rolling noise by 2012/16 (COM(2008) 316, Annex 
1, Part C) 

Tyre class 

Nominal section 
width (mm) 

Minimum 
requirements 
in dB(A) 

C1 A 

C1 B 

C1 C 

C1 D 

C1 E 

≤ 185 

> 185 ≤ 215 

> 215 ≤ 245 

> 245 ≤ 275 

> 275 

70 

71 

71 

72 

74 

Tyre class  Nominal section width (mm) 

Minimum 
requirements in dB(A) 

C2 

C3 

Normal 

Traction tyres 

Normal 

Traction tyres 

71 

72 

72 

74 

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