REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Assessment of the need to review Regulation (EC) No 1222/2009 of the European Parliament and the Council on the labelling of tyres with respect to fuel efficiency and other essential parameters
Date: 2017-11-08
Institutions: Directorate-General for Energy, European Commission
Subjects: consumer information, energy consumption, energy saving, labelling, motor fuel, pneumatic tyre, road safety

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.11.2017  COM(2017) 658 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL  Assessment of the need to review Regulation (EC) No 1222/2009 of the European Parliament and the Council on the labelling of tyres with respect to fuel efficiency and other essential parameters   
 
 
1. 

INTRODUCTION 

This  report  presents  the  results  of  the  assessment  of  the  need  to  review  Regulation  (EC) 
No 1222/20091 of the European Parliament and of the Council of 25 November 2009 on the 
labelling  of  tyres  with  respect  to  fuel  efficiency  and  other  essential  parameters  ('the  Tyre 
Labelling Regulation'). As required by Article 14 of the Regulation, the review focused on: 

 

 

the effectiveness of the label in terms of end-user awareness, in particular whether the 
provisions of Article 4(1)(b) are as effective as those of Article 4(1)(a) in contributing 
to the objectives of the Regulation; 

the  information  on  tyre  parameters  provided  by  distributors  (dealers)  and  vehicle 
suppliers to end-users; 

  whether the labelling scheme should be extended to include re-treaded tyres; 

  whether new tyre parameters, such as mileage, should be introduced. 

Other relevant issues were also addressed. These include the possibility of adapting the grip 
grading  of tyres  primarily designed to  perform  better than a normal tyre in  ice and/or snow 
conditions, in accordance with Article 11(b) of the Regulation; the possibility of setting up a 
registration database; and the need to reinforce market surveillance activities. 
A specific study2 was undertaken to support the review of the Regulation. 

2. 

TYRES LABELLING LEGISLATION 

The Tyre Labelling Regulation was adopted as part of efforts to promote sustainable mobility 
in the EU. 
The  Regulation  covers  tyres  for  passenger  cars  (C1  tyres3),  light  commercial  vehicles  (C2 
tyres)  and  heavy-duty  vehicles  (C3  tyres).  Re-treaded  tyres,  studded  tyres  and  tyres  for  a 
number of specific applications, such as racing and spare tyres, are exempted.  

The Regulation includes three interrelated performance parameters: fuel efficiency (based on 
rolling resistance), wet grip and external rolling noise. The Regulation defines classes for all 
three parameters. 

The fuel efficiency of tyres is defined in terms of the Rolling Resistance Coefficient (RRC). 
The fuel efficiency is shown on the label as a coloured scale from A to G, with the best fuel 
efficiency class (class A) having the lowest RRC. 

The  safety  performance  of  tyres  is  described  by  the  wet  grip,  i.e.  the  capacity  of  a  tyre  to 
brake on a wet road. The wet grip class is determined based on the wet grip index according 
to an A-G scale, with the best classes having the highest wet grip index values. 

External rolling noise refers to the noise of the tyres experienced by a bystander, i.e. outside 
the  car.  It  is  measured  in  decibels  (dB).  The  external  rolling  noise  class  is  depicted  on  the 
label by between one and three black 'sound waves'. 

1 OJ L 342, 22.12.2009, p. 46. 
2 Review study on the Regulation (EC) No 1222/2009 on the labelling of tyres (Viegand Maagøe A/S, March 2016) 
3  C1,  C2,  C3  tyres  are  legal  terms  defined  in  Regulation  (EC)  No  661/2009.  They  refer  to  tyres  designed  primarily  for 
passenger cars, light commercial vehicles and heavy-duty vehicles. 

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The level of performance for these three parameters on the label is declared by manufacturers 
with no third party verification. 

For  C1  and  C2  tyres,  the  classes  are  shown  on  a  label  or  a  sticker  (a  label  with  a  space  to 
show the brand name). For all three tyre types, the information on fuel efficiency class, wet 
grip  class,  external  rolling  noise  class  and  the  measured  noise  value  is  provided  in  the 
technical promotional material, including on suppliers’ websites. 

The Tyre Labelling Regulation's main objective is to make road transport more economically 
and environmentally efficient, as well as safer, by promoting fuel-efficient and safe tyres with 
low external rolling noise. It also aims to provide greater information to consumers, through a 
standard  label,  to  influence  purchasing  decisions.  Fuel  efficiency  is  highly  relevant  to  the 
EU's concerns about the security of its energy supply, its dependence on energy imports and 
the need to address climate change.  

With the transport sector accounting for one third of EU energy consumption, increasing the 
fuel efficiency of road transport plays an important role in addressing these challenges. Tyres 
account  for  20-30  %  of  a  vehicle's  fuel  consumption,  due  to  their  rolling  resistance. 
Decreasing  rolling  resistance  is  therefore  important  to  increase  fuel  efficiency  and  reduce 
greenhouse  gas  emissions.  Improved  wet  grip  performance  of  tyres  will  result  in  fewer 
accidents and reduce the number of people killed and injured. Noise from roads is causing the 
second most dangerous environmental health burden after particulate matter. Using only tyres 
with the best external rolling noise class in the EU can reduce noise-related health impacts. 

3. 

SCOPE OF THE ANALYSIS 

The analysis covered whether potential  remains, since the application of the Tyre  Labelling 
Regulation,  to  improve  the  tyre  performance  parameters  on  fuel  efficiency,  wet  grip  and 
external noise. 

The examination covered the implementation and enforcement provisions of the Regulation in 
the  EU  since  its  application  date  in  November  2012.  The  investigation  included  also  the 

2 

 
 
public  procurement  requirements  included  in  the  Energy  Efficiency  Directive  2012/27/EU4 
and referring to the Tyre Labelling Regulation. 

The analysis took into consideration, as sources of inspiration, the relevant provisions in the 
Energy Labelling Directive 2010/30/EU5 as revised by the Energy Labelling Regulation (EU) 
2017/1369 of the European Parliament and of the Council6. 

The  investigation  also  took  into  account  the  relevant  provisions  of  the  Type  Approval 
Regulation  (EC)  661/20097  for  tyres.  This  is  designed  to  exclude  from  the  market  products 
that  perform  least  well  on  the  same  parameters  (rolling  resistance,  wet  grip  and  external 
noise). 

In particular, the analysis focused on the following issues: 

1. 

2. 

3. 

4. 

5. 

6. 

the  extent  to  which  the  average  market  performance  has  improved  since  the 
Regulation started to apply; 

the effectiveness of the label in terms of end-user awareness and of improving energy 
efficiency, wet grip and noise impact; 

the  clarity  and  accuracy  of  the  information  on  tyre  parameters  provided  by  vehicle 
suppliers and distributors to end-users; improvement of pre-sale information, including 
the visibility of the label; 

the  exemption  of  certain  types  of  tyres  (re-treaded  and  studded  tyres)  from  the 
labelling scheme; 

the non-inclusion of other tyre parameters, such as mileage and abrasion; 

the non-adaptation of the grip grading system to tyres primarily designed to perform 
better in ice and/or snow conditions; 

7. 

the creation of a registration database; 

8.  market surveillance and enforcement. 

4.  RESULTS 

4.1. 

 Market development 

The  Tyre  Labelling  Regulation  applied  since  November  2012.  For  'fuel  efficiency'  and  'wet 
grip', the market showed between 2013 and 2015 a positive trend towards better performing 
tyres, partly due to the impact of the label. This trend was less pronounced for 'external rolling 
noise' however. 

Both average fuel efficiency and wet grip improved from 2013 to 2015 for all tyre types. 

For the best energy efficiency classes (A and B), market penetration is still very low (<1 % 
for all tyre types). This indicates that large potential for improvement still exists. 

On wet grip performance, the market share of class B is high for all tyre types (above 40 %) 
and satisfactory for class A (around 15 %). 

4 Article 6 and Annex III. 
5 Directive 2010/30/EU (OJ L 153, 18.6.2010, p. 1). 
6 Regulation (EU) 2017/1369 (OJ L 198, 28.7.2017, p.1). 
7 Regulation (EC) No 661/2009 (OJ L 200, 31.7.2009, p. 1). 

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For  external  rolling  noise  there  was  no  real  improvement  from  2013  to  2015,  mainly  as 
industry  has  put  more  focus  on  improving  the  other  parameters.  This  is  because  external 
rolling  noise  is  the  parameter  rated  least  important  for  end-users,  as  shown  by  the  survey 
carried out as part of the study to support the review. 

Moreover,  less  than  0.5  %  of  the  tyres  placed  on  the  market  are  labelled  A  for  both  fuel 
efficiency and wet grip due to the higher costs and the technical trade-off between these two 
parameters. 
The  impact  of  the  labelling  scheme  by  2020  has  been  estimated  at  35  PJ8  (or  0.8  Mtoe9) 
annually with corresponding CO2 emission savings of 2.5 Mton per year10. 

4.2.  User awareness and understanding of the label 

The consumer survey carried out as part of the study to support the review showed that more 
than half of car owners were not aware of the tyre label. 

Additionally,  end-users  of  C2  and  C3  tyres  and  some  end-users  of  C1  tyres  often  do  not 
purchase tyres directly but as part of leasing contracts and fleet solutions. 

Awareness  campaigns  could  include  a  reference  to  the  fuel  savings  calculator  on  the  EU 
Commission’s website11 that lets end-users calculate their potential fuel savings from tyres.  

Another awareness-raising issue concerns the public procurement requirements in the Energy 
Efficiency  Directive  2012/27/EU, though this was not  specifically pointed to  by the survey. 
To promote the use of energy-efficient tyres, it is  important  that Member States  ensure  that 
their central governments are aware of the requirement to purchase tyres in the highest fuel-
efficiency class. They should also include this aspect in their tenders for service contracts in 
accordance with the requirement in Annex III of the Energy Efficiency Directive 2012/27/EU. 

The  survey  also  showed  continuous  progress  in  user  awareness  and  understanding  of  the 
label. 

Consumers’  comprehension  of  the  tyre  label  is  generally  good.  When  shown  the  label, 
consumers were able to understand the information given even though they were not familiar 
with it beforehand. The respondents rated the pictogram on external rolling noise as the least 
easy  to  understand  (60  %  rate  of  understanding),  while  wet  grip  was  rated  the  easiest  to 
understand (81 %) and the fuel efficiency parameter in between (73 %). 

The survey showed that safety is the prevailing concern for consumers when purchasing tyres. 
Most consumers therefore find wet grip the most important of the labelling parameters. Even 
when non-labelling parameters (such as price and brand) are also considered, wet grip is still 
the most important, followed by price. 

Industry,  dealers  and  consumer  organisations  recommend  organising  campaigns  promoting 
the label to increase consumers’ knowledge of it and explain its meaning. The target groups 
should  be  end-users  in  the  C1,  C2  and  C3  tyre  segments.  However,  awareness  campaigns 
targeting  end-users  of  C1  tyres  are  the  most  important  because  they  constitute  the  largest 
share of tyre sales.  

8 PJ or Peta Joule : 1015 Joule. 
9 Mtoe: million tons of oil equivalent. 
10 Based on the stock model set up for the study to support the review of the Tyres Labelling Regulation. 
11. Calculator: Savings are based on the energy efficiency performance of the tyre and on the number of kilometres the set of 
tyres can run. 

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The awareness campaigns could be run at national level by Member State authorities, at EU 
level  by  the  Commission,  or  both.  It  would  be  an  advantage  to  include  tyre  suppliers  and 
distributors  in  the  campaigns  in  order  to  reach  end-users  more  effectively.  Some  Member 
States  have  already  facilitated  awareness  campaigns  about  the  tyre  label  or  plan  to  do  so. 
Experiences and recommendations from these campaigns should be taken into account. 

4.3. 

 Accuracy of information, improvement of pre-sale information 

In general, consumers find the label useful and clear. A large share of consumers has high or 
medium  confidence  in  the  information  the  label  provides.  Many  consumers  indicated  that 
more market control and more sanctions for non-compliance would increase their confidence. 
This is also in accordance with the answers from both tyre suppliers and dealer associations, 
who also requested more market surveillance. 

Regarding the accuracy of the information, it is necessary to mention that several consumer 
organisations  have  expressed  some  concerns  of  the  EU  tyre  label.  They  claim  that  the  EU 
label  overstates  tyre  performance  and  that  the  values  are  different  from  their  tests.  They  do 
not specify whether this difference applies to all three parameters, however, or only to one or 
two.  They  also  criticise  the  fact  that  the  EU  tyre  label  is  derived  from  a  'self-declaration' 
process, so without third party certification.  

Additionally,  many  consumers  request  more  information  in  the  form  of  independent  testing 
by consumer associations or authorities, or a public database showing the tyre data from the 
labelling scheme. 

Most consumers buy tyres in tyre shops or car workshops but only around one third of them 
saw the tyres on display before their most recent purchase. Furthermore, market surveillance 
authorities (MSAs) carrying out shop inspections have observed that only a few tyre models 
are  on  display  at  the  point  of  sale  while  the  rest  are  placed  in  the  stock.  This  implies  that 
consumers  often  do  not  see  the  tyre,  and  hence  not  the  label  either,  before  purchasing  it. 
Moreover,  since  tyre  performance  deteriorates  with  ageing,  even  on  the  shelf,  it  could  be 
considered  to  inform  the  consumer  on  the  manufacturing  date,  for  instance  in  the  product 
information sheet, providing also indications on the average performance degradation that can 
be expected. 

These  practices  are  not  compatible  with  Article  5(2)  of  the  Regulation,  under  which 
distributors must provide end-users with information about the label performance parameters 
when tyres offered for sale are not visible to the end-user. Therefore, it could be considered to 
extend  and  clarify  these  provisions  to  ensure  that  the  label  information  is  provided  before 
sale. 

Vehicle suppliers and distributors should be obliged to provide tyre labelling information for 
the tyre type(s) to be fitted on the vehicle. This should include situations where the end-user is 
not  offered  a  choice  between  different  tyres  to  be  fitted  on  a  vehicle  offered  for  sale.  The 
information could be included in the technical promotional material given to the end-user, for 
example. 

At the point of sale, the tyre label can be shown either as a printed label in proximity to the 
tyre or as a sticker on the tyre. Most of the consumers consider the sticker on the tread of the 
tyre to be the most visible. However, the relevance of how the label is shown is undermined 
by the fact that most of the tyres are not on display. 

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The  share  of  tyre  purchases  on  the  internet  is  increasing,  as  the  survey  shows.  It  is  thus 
becoming  increasingly  important  to  show  the  label  and  the  relevant  information  when  tyres 
are offered for sale online. 

4.4. 

 Non coverage of certain types of tyres (re-treaded and studded tyres) 

Re-treaded tyres 

Tyre re-treading is a process used to extend the life of used tyres. When a tyre is re-treaded, 
the worn-out tread is replaced with a new one. This replacement can be repeated as long as 
the integrity of the tyre casing is guaranteed. Re-treading results in both energy and material 
savings. 

The performance of re-treaded tyres is determined by the combination of casing, tread and the 
re-treading process applied. The major challenge of including re-treaded tyres in the labelling 
scheme is  the necessity to  establish the three  label performance parameters (fuel  efficiency, 
wet grip and external rolling noise) for each combination. Since re-treaded tyres are produced 
in  small  series,  the  cost  of  testing  each  combination  would  make  the  re-treading  business 
economically unfeasible, in particular for small and medium-sized business. 

The measurement methods and tools for calculating the label performance parameters for re-
treaded C3 tyres are under development.  

A thorough assessment of these methods and tools should be undertaken before considering 
whether  to  include  re-treaded  C3  tyres  in  the  scope  of  the  Tyre  Labelling  Regulation.  The 
assessment work should involve all relevant stakeholders such as the tyre industry, re-treading 
companies, MSAs and relevant non-governmental organisations. 

Studded tyres 

Studded tyres are primarily used in Finland, Sweden and Norway, where they constitute 12 % 
of the tyre market (compared to 0.25 % in the rest of the EU). In many Member States, the 
use  of  studded  tyres  is  prohibited  and  in  most  others  their  use  is  restricted  to  the  winter 
months. The small market share limits the fuel saving potential from including studded tyres 
in the labelling scheme. Furthermore, the main environmental issue arising from studded tyre 
use is the particle pollution from road wear. This has led the Nordic countries to regulate the 
tyre design to limit this impact. 

Testing rolling resistance and wet grip for studded tyres is not possible with the current test 
standards. In both the rolling resistance and the wet grip test, there is a limited roughness of 
the  surface  (road  or  machine  drums)  allowed.  Using  studs  on  these  surfaces  during  the  test 
would damage them to such an extent that the surfaces would no longer comply with the test 
standards. 

4.5. 

 Mileage and abrasion 

Mileage 

The environmental and economic impact of increasing tyre mileage depends solely on how it 
will affect the rolling resistance. If increased mileage is obtained at the expense of increased 
rolling  resistance,  the  impacts  will  most  likely  be  negative  due  to  an  increase  in  the  fuel 
consumed in the use phase. Additionally there is also a risk that wet grip might be weakened. 

6 

 
Mileage is an important parameter for end-users but its inclusion is not feasible for the time 
being  as  there  is  no  reliable,  accurate  and  reproducible  standardised  test  method  for 
identifying the number of kilometres achievable by the tyres. Such a method would be needed 
to be developed to provide consumers with this important information though it is recognised 
that  mileage  measured  using  a  standardised  test  method  can  deviate  significantly  from  the 
mileage experienced by consumers in real life. If this happens, there is a risk that consumers 
would lose confidence in the label. 

Whereas mileage is directly related to the tread wear in use of the tyre (which can depend on 
tyre  pressure,  road  surface,  load  and  driving  style),  tyres  also  degrade  with  age  or  through 
exposure to sunlight (UV), heat, rain, etc. Hence, the durability of tyres is also dependent on 
exposure  to,  and  the  severity  of,  the  climate  in  which  they  are  used,  which  is  however  true 
also for other parameters reported in the label, such as fuel economy. 

Therefore, consumers  should be made aware of the potential  causes of these  deviations and 
the  way  to  reduce  them  (better  inflation  control,  driving  style  etc.)  to  maintain  their 
confidence in the label. 

The  Uniform  Tire  Quality  Grading  (UTQG)  standards  provide  the  only  standardised  test 
method, which applies only to C1 tyres. The test method requires tyres to be driven for a total 
of  7  200  miles  (11  600  km),  which  makes  it  very  costly  (a  more  economic  lab-test 
methodology  could  be  considered).  The  mileage  measured  will  deviate  from  the  mileage 
experienced  in  real  life  by  the  end-user,  since  external  factors  such  as  tyre  pressure,  road 
surface, load and driving style have a strong influence on tyre wear and mileage. 

The industry and MSAs all agree that it is not possible to measure mileage with the accuracy 
required for labelling, and MSAs do not consider it possible to perform market surveillance 
on such a requirement. Furthermore, the tyre industry, MSAs and tyre organisations all agree 
that introducing mileage as a parameter in the tyre labelling scheme would be very costly and 
would  not  help  the  consumers  choose  better  tyres.  However,  this  issue,  which  is  strictly 
related to abrasion could be further investigated in a future revision of the Regulation. 

Abrasion 

Abrasion,  which  is  the  removal  of  materials  from  the  tyre  when  it  interacts  with  the  road 
surface, is  related to  tyre mileage. The  materials removed, called Tyre Road  Wear Particles 
(TRWP), contribute to particulate pollution of the air. As other air pollution sources, such as 
vehicle emissions, are being regulated, the relative importance of TRWP is likely to increase. 
However,  the  contribution  of  TRWP  to  air  pollution  and  to  microplastic  pollution  of  the 
oceans is still uncertain, and a standardised measurement method has not yet been developed. 
A  number  of  recent  studies  point  to  tyres  as  a  potentially  important  source  of  microplastic 
pollution of the oceans12.  

As with mileage, abrasion depends largely on external factors (i.e. tyre pressure, road surface, 
load, driving styles, etc.). The tyre labelling scheme might not necessarily be appropriate for 
regulating  emissions  of  TRWP.  However,  this  issue  could  be  further  explored  in  a  future 
revision  of  the  Regulation.  This  should  take  into  account  the  growing  concerns  about  air 
pollution  and  microplastics  in  the  oceans  and  the  consequences  for  the  environment  and 
human health.  

12 Study on primary microplastic-pollution, p. 31 and study on marine litter sources p. 365. 

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The chemical content of tyre materials, which is important for the health effects of TRWP, is 
already regulated through the REACH Regulation13.  

In addition, it appears relevant to mention that this issue could also be explored under the type 
approval legislation for tyres14. 

4.6. 

 Snow and ice grip 

In the tyre labelling scheme, the wet grip index is used as a measure of safety. However, this 
carries  a  risk  of  misleading  consumers  purchasing  tyres  for  winter  conditions,  since  tyres 
designed  to  perform  better  on  snow  and  ice  often  have  a  poorer  wet  grip  than  standard 
summer15  tyres.  The  inclusion  of  snow  and  ice  performance  in  the  labelling  scheme  would 
address a safety concern and would provide more complete information to consumers, which 
could ultimately lead to increased confidence in the label, especially in Nordic regions. In this 
context, it could also be considered to inform the consumer about the importance of the age of 
the tyre, as performance of tyres at low temperatures strongly degrades with age. 

The term ‘snow tyre’ is defined in Regulation (EC) 661/2009 and in UNECE Regulation 117 
as 'a tyre whose tread pattern, tread compound or structure is primarily designed to achieve in 
snow conditions a performance better than that of a normal tyre with regard to its ability to 
initiate or maintain vehicle motion'. Such tyres can be labelled with the 'M+S' marking, which 
is a manufacturer self-declaration for tyres supposed to better perform on mud and/or snow. 
However, there are currently no further requirements or tyre performance tests needed for the 
'M+S' marking. 

The term ‘severe snow tyre’ is also defined in UNECE Regulation 117 as 'a snow tyre whose 
tread pattern, tread compound or structure is specifically designed to be used in severe snow 
conditions' and that fulfils certain requirements in order to use the 3-PMSF (3 Peak Mountain 
Snow Flake) marking on the sidewall of the tyre. These tyres are also known as 'winter tyres' 
and are mandatory in various Member States under winter conditions.  

Both  the  terms  'snow  tyre'  and  'severe  snow  tyre'  apply  to  tyre  types  C1,  C2,  and  C3  alike. 
Another  category  of  tyres  for  winter  conditions  is  'Nordic  winter  tyres',  which  are  non-
studded tyres designed for ice and wet ice conditions. There is currently no legal definition of 
Nordic  winter  tyres,  but  an  ISO  standard  for  an  ice  performance  test  similar  to  the  snow 
performance test used for severe snow tyres is currently being prepared and is expected to be 
ready in the course of 2017. The ice performance test applies only to C1 tyres. 

For snow grip performance, the 3-PMSF test and marking is the most suitable solution since it 
is  already  widely  used  by  the  tyre  industry  and  thus  would  have  low  implementation  costs. 
This additional information compensates for the usually poor middle-range wet grip score on 
the EU label. 

For 'Nordic winter tyres' (i.e. ice conditions tyres), the expected ISO standard, in combination 
with  a  threshold  value  and  a  corresponding  pictogram,  could  likewise  be  a  useful  solution. 
These tyres often have the lowest wet grip values on the label. 

13 Regulation (EC) No 1907/2006 REACH (OJ L 396, 30.12.2006, p. 1). 
14 Regulation (EC) No 661/2009 (OJ L 200, 31.7.2009, p. 1). 
15 'Summer tyre' does not correspond to a legal definition of a specific product. It refers to a normal tyre to be used preferably 
under non-severe wintry weather conditions. For information, there are 'all-season tyres' which also does not correspond to a 
legal  definition  and  which  are  tyres  that  can  be  used  under  both  summer  and  winter  conditions  according  to  the 
manufacturer's declaration. They are generally marked 'M+S' but do not necessarily respond to an approved 3-PMSF (3 Peak 
Mountain Snow Flake) certification as the legally defined 'severe snow tyre'. All these different terms of tyres ('summer' and 
'all-season') correspond to the manufacturer's declaration with no further requirements or tyre performance tests. 

8 

 
                                                            
In both cases (snow and ice conditions tyres), the additional information, if any, on the label 
should apply only to tyres certified by a third party against the standard test procedure. This is 
necessary to maintain and reinforce consumer confidence in the label.  

4.7.  Registration database 

The review study investigated the appropriateness of setting up a registration database for tyre 
labels and related technical documentation at EU level to improve enforcement. The analysis 
found  that  this  could  be  useful  to  provide  market  information  for  policy  decisions  and 
facilitate market surveillance, and it could serve as a tool for consumer information. It could 
also be a good instrument to obtain more transparency regarding test methods and conditions 
used  by  suppliers,  which  according  to  some  MSAs  is  currently  lacking.  For  end-users,  a 
registration database could provide pre-sale information on the labelling parameters.  

Any  possible  database  would  have  to  be  complementary  to  the  existing  Information  and 
Communication System for Market Surveillance  (ICSMS)16 database which covers products 
in circulation in the EU which are not in conformity with the EU product legislation, as well 
as  the  database  to  be  established  under  the  revised  Energy  Labelling  Regulation  (EU) 
2017/1369.  The  reflection  on  a  possible  registration  database  for  tyres  will  benefit  from 
experience with the future energy labelling database.  

4.8. 

 Market surveillance and enforcement 

Market  surveillance  activities  vary  between  Member  States,  which  are  responsible  for 
conducting  the  surveillance.  The  prevailing  type  of  market  surveillance  is  'point  of  sale' 
inspections. Some authorities have inspected technical documentation but only very few have 
performed  laboratory  tests  to  verify  the  label  values.  According  to  MSAs,  high  cost  and  an 
insufficient number of accredited test facilities are the greatest barriers to laboratory testing of 
tyres. 

The low level of market surveillance undermines consumer confidence and has given retailers 
the impression that tyre labelling is a low priority for the authorities. 
Most Member States see the EU co-funded joint action test programme on tyres labelling17 as 
an opportunity to start performing laboratory tests on tyres. The purpose of the joint action is 
both to obtain more test data and to develop best practices for market surveillance testing.  

the  same 

Some of the tyre tests conducted by MSAs show that the results could diverge from the label 
values,  even  when 
test 
tracks/laboratories, without it being possible to identify exactly whether the issue is equal for 
all three parameters or only for some of them. The same issue has been reported by numerous 
car  magazines  and  consumer  organisations  performing  tests.  Without  being  able to  quantify 
the various causes, MSAs believe a large part of this issue might be due to: 

tested  on  different  accredited 

tyre  model  was 

 

 

 

the measurement method itself (in particular for wet grip); 

the different conditions under which the tests were conducted; 

incorrect application of the test methods; and 

16  This  is  a  cross-EU  database  owned  by  the  European  Commission  for  archiving  and  exchanging  information  between 
Member States and Commission on issues relating to enforcement activities. 
17 EC Market Surveillance project MSTyr15, funded under Horizon 2020 to improve the enforcement of the Tyre Labelling 
Regulation  (EC)  1222/2009  with  more  effective  market  surveillance  authorities  (training,  guidelines,  etc.).  See 
www.mstyr15.eu. 

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  a lack of transparency in the conditions used for the tests and for calculating the label 

values. 

The experience accumulated so far by the industry and the MSAs on wet grip test standards 
indicates  an  opportunity  to  further  improve  the  accuracy  of  the  test  method.  This  could  be 
achieved,  for  example,  by  reviewing  the  set  of  test  conditions  ranges  and/or  of  the 
mathematical  formulas  which  allow  the  results  to  be  aligned  when  the  tests  are  performed 
under different conditions, for example due to different test locations or at different periods of 
the  year.  This  is  an  important  aspect  to  be  addressed  in  the  future  given  that  safety  is  the 
prevailing concern among consumers when purchasing tyres. On noise and rolling resistance 
tests, the situation is less sensitive. For measuring the rolling resistance of tyres (which gives 
indication  of  the  fuel  efficiency),  a  network  of  'reference  laboratories'18  has  been  set  up  to 
optimise  the  accuracy  and  reproducibility  of  the  results  through  a  procedure  to  align  the 
testing machines.  

The  Tyre  Labelling  Regulation  itself  does  not  include  detailed  provisions  on  market 
surveillance  and  enforcement.  Instead,  the  Regulation  refers  to  the  provisions in  Regulation 
(EC)  765/200819,  which  includes  the  general  rules  on  market  surveillance  and  controls  of 
products entering the EU market. This is different from the EU Energy Labelling Regulation 
(EU)  2017/1369,  which  does  include  more  detailed  provisions  on  market  surveillance,  in 
addition  to  those  included  in  Regulation  (EC)  765/2008.  In  addition,  the  implementing 
measures  under  the  Energy  Labelling  Regulation  must  include  a  detailed  description  of  the 
content  of  the  technical  documentation  to  be  required  by  MSAs  for  market  surveillance 
purposes. 

Even  though  the  enforcement  provisions  are  less  detailed  in  the  Tyre  Labelling  Regulation, 
MSAs  in  general  do  not  report  a  lack  of  empowerment  to  make  inspections  and  apply 
sanctions regarding the tyre labelling scheme.  

MSAs  and  consumer  organisations  are  more  concerned  about  testing  costs,  unclear  test 
methods and inaccurate test results. 

5.  CONCLUSIONS 

The review study highlighted  potential for simplification, and increased effectiveness of the 
current  legislation.  In  particular,  a  large  potential  for  further  fuel  savings  exists,  and  road 
safety and rolling noise aspects could also be further improved. . 

The  review  study  -  and  the  underlying  interviews  with  tyre  suppliers,  distributors  (dealers) 
market  surveillance  authorities,  consumer  organisations  and  environmental  NGOs  -  has 
pointed to a number of issues that could improve the Regulation and its implementation. 

There  is  scope  for  improving  the  clarity,  accuracy,  reliability  and  representativeness  of  the 
label  and  for  better  enforcement  by  Member  States.  For  example,  this  could  be  done  by 
refining measurement tests, reinforcing market surveillance and considering other options. 

There is a lack of awareness of the label amongst end-users and there are several other aspects 
that could deliver considerable energy savings while avoiding a disproportionate increase of 
the costs and complexity of the scheme. 

18 Commission communication 2012/C 86/03 
19 Regulation (EC) No 765/2008 (OJ L 218, 13.8.2008, p. 30). 

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The potential impact is substantial. Addressing the issues identified in this report could drive 
the  market  towards  better-performing  tyres.  If  by  2030,  all  tyre  types  were  to  reach  fuel 
efficiency  class  B  (instead  of  class  C,  as  currently  predicted),  the  potential  energy  savings 
could be at the level of 256 PJ (or 6.1 Mtoe) annually in 2030, corresponding to 18.6 Mton 
CO2 emission savings per year. 

The Commission will investigate further the issues addressed in this report and may propose a 
revised Tyre Labelling Regulation in due course. 

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