REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE Report on the implementation of Regulation (EU) 2020/740 on the labelling of tyres with respect to fuel efficiency and other parameters
Date: 2026-06-24
Institutions: Directorate-General for Energy, European Commission
Subjects: application of EU law, consumer information, energy consumption, energy efficiency, energy saving, labelling, market supervision, motor fuel, pneumatic tyre

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 24.6.2026  COM(2026) 326 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE Report on the implementation of Regulation (EU) 2020/740 on the labelling of tyres with respect to fuel efficiency and other parameters  
 
 
1. 

INTRODUCTION 

1.1. 

Policy and legal context 

Tyres are a critical component of every road vehicle. Tyre rolling resistance directly affects 
the vehicle’s energy consumption. Encouraging the demand for, and the development and 
production of, more efficient tyres can therefore reduce fuel costs, emissions and imports 
of fossil fuels – or increase the range of electric vehicles by reducing the electricity needed 
per driven kilometre. The first formal EU act on efficient tyres was adopted in the wake of 
the  1973  oil  crisis,  recommending  ‘that  the  fitting  of  radial-ply  tyres  on  all  vehicles, 
including heavy goods vehicles, be encouraged’ by Member States (1). 

Fifty years on,  radial tyres have become the default  technology,  but road  transport  still 
accounts for a significant part of total EU final energy consumption (around a quarter), and 
the vast majority of that energy still comes from oil. Meanwhile, innovation in tyre design 
and materials has made further efficiency gains possible. Estimates suggest that replacing 
high  rolling  resistance  tyres  with  low  resistance  ones  could  cut  average  energy 
consumption of passenger cars by some 2% (2). For heavy duty vehicles, rolling resistance 
from  tyres  is  far  more  important,  and  the  potential  for  efficiency  gains  greater:  rolling 
resistance influences energy use up to one third in diesel trucks and over half in a more 
efficient electric ones (3). 

At the same time, another tyre parameter, wet grip, is critical for safety as it determines a 
vehicle’s breaking distance. Wet grip and rolling resistance are competing metrics, and for 
customers deciding on which type of tyre to buy there may be some trade-offs between 
safety and energy performance. To make well-informed purchasing decisions, customers 
should  therefore  have  information  on  both  parameters.  To  this  end,  the  first  EU  Tyre 
Labelling Regulation (TLR hereafter) was adopted in 2009 and revised in 2020. Tyre labels 
provide easy to understand information to stimulate demand for, and competition in the 
supply of, better tyres.  

The TLR’s legal bases are Article 114 and 194 of the Treaty on the Functioning of the 
European Union. The Regulation’s scope covers tyres for passenger vehicles (C1), vans 
and light trucks (C2) and heavy trucks and buses (C3) (4). The TLR works in tandem with 
minimum performance requirements set in other legislation. Type-approval legislation, in 
particular UNECE Regulation 117, establishes the most important minimum performance 
standards for tyres placed on the EU market in terms of rolling resistance, wet grip, noise, 
snow grip and ice grip. Relevant minimum performance standards are also set in UNECE 
Regulations  30  (C1  tyres),  54  (C2,  C3  tyres),  172  (re-treaded  tyres).  While  no  EU 
ecodesign legislation has yet been adopted for tyres, tyres are included in the 2025-2030 
working plan on ecodesign and energy labelling (5). 

(1)  76/494/EEC: Council recommendation of 4 May 1976 on the rational use, through better driving habits, 

of energy consumed by road vehicles, OJ L 140, 28/05/1976 P. 0014 – 0015. 

(2)  Zacharof, N., Fontaras, G., Ciuffo, B., Tsiakmakis, S. et al. Review of in use factors affecting the fuel 

consumption and CO2 emissions of passenger cars; Joint Research Centre, 2016. 

(3)  Hyttinen,  Jukka  et  a.  Effect  of  Ambient  and  Tyre  Temperature  on  Truck  Tyre  Rolling  Resistance, 

International Journal of Automotive Technology, Nov. 2022.  

(4)   Tyres for off-road, construction, agriculture or for two and three-wheeled vehicles are out of scope as 

fuel efficiency or safety aspects would not be relevant. 

(5)   COM(2025) 187 final. 

 
 
 
1.2.  Main changes in the 2020 revision of the Tyre Labelling Regulation 

The key changes introduced by the 2020 revision were to: 

•  align the label style and format with the more familiar energy label; 
• 

reduce the number of performance classes, from seven (A-G) to five (A-E), for 
both rolling resistance (energy efficiency) and wet grip (safety) because more 
stringent UNECE type-approval requirements had banned tyres falling into the 
worst performing classes on the label; 
require registration of every tyre type in the European Product Registry for 
Energy Labelling (‘EPREL’) (6); 
improve customer awareness of the tyre label by strengthening the requirements 
for showing the tyre label to consumers; 

• 

• 

•  empower the Commission to adopt certain changes through delegated acts. 

1.3. 

Scope of this report 

Article 15 of the TLR requires the Commission to carry out an evaluation of the Regulation 
and submit a report to the European Parliament, the Council and the European Economic 
and Social Committee.  The report  is  to assess  ‘how  effectively this Regulation  and the 
delegated acts adopted pursuant thereto have led end-users to choose higher‐performing 
tyres, taking into account the impact … on business, fuel consumption, safety, greenhouse 
gas  emissions,  consumer  awareness  and  market  surveillance  activities.  The  report  shall 
also assess the costs and benefits of mandatory independent third‐party verification of the 
information provided in the tyre label, taking into account experience gained with regard 
to the broader framework provided by Regulation (EC) No 661/2009’. 

This report focuses on the following topics: 

•  consumer awareness, understanding and use; 
•  market evolution; 
•  delegated acts; 
•  market surveillance and enforcement; 
• 
third-party verification and testing; 
• 
test machine alignment; 
• 
issues identified as part of the implementation. 

Some aspects are analysed as part of the Impact Assessment accompanying the omnibus 
simplification  proposal  on  energy-efficient  product  legislation  adopted  in  parallel  with, 
and  informed  by,  this  report  and  the  underlying  analysis.  A  separate  report  on  the 
implementation  of  the  Energy  Labelling  Regulation  (Regulation  (EU)  2017/1369)  is 
adopted in parallel to the present report. 

1.4.  Analytical basis 

This report builds on several sources of data and input including: 

•  a survey of consumers and tyre and vehicle dealers (7); 
•  EPREL data for tyre registrations; 

(6)   https://eprel.ec.europa.eu/. 

(7)   Study on consumer understanding of the EU tyre label applied since 1 May 2021. 

2 

 
 
 
 
• 

• 

input from stakeholders and authorities, including via the work of various 
working groups including the Administrative Cooperation Group (AdCo) for tyre 
labelling (8) and the Expert Group on laboratory alignment for the measurement of 
tyre rolling resistance (9); 
the Information and Communication System for Market Surveillance (ICSMS) 
(10);  

•  other publicly available analyses and resources. 

2.  THE REDESIGNED TYRE LABEL 

A 2018 review study (11) found that the tyre label had not reached its full potential because 
end users were not well aware of its existence and it was not being adequately enforced by 
the MSAs. The study also found that some intrinsic factors were hindering the success of 
the label, such as a misleading performance class subdivision, inaccurate and incomplete 
information and lack of trust in what some respondents considered a self-declaration. 

Figure 1.  Illustration of the original tyre label (2012) and the revised (new) label (2021). 

The updated tyre labelling legislation has applied since 1 May 2021. Figure 1 compares 
the original and the revised label. The new label includes several new features: 

•  Rolling resistance. The lowest classes were rescaled to become D and E. This 

eliminated the empty D class for C1 and C2 tyres (12). The same value range was 
kept for each tyre type; 

•  Wet grip. Label classes were rescaled, and the empty D class was eliminated. 
Blue shaded arrows were added to the wet grip scale (recalling water), to 
distinguish safety aspects from energy. 

(8)   List of administrative cooperation groups. 

(9)  https://ec.europa.eu/transparency/expert-groups-register/screen/expert-

groups/consult?lang=en&groupID=2519. 

(10) ICSMS. 

(11)  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1460-Evaluation-and-

potential-revision-of-the-EU-tyre-labelling-scheme_en. 

(12)  No empty class had been set for C3 tyres that, anyhow, had no obligation to bear a label sticker. 

3 

 
 
 
 
 
•  External rolling noise. The class indication was aligned with other energy labels 
using a letter scale. The sound level was expressed in decibels (as for other 
labelled products) and a pictogram with soundwaves was retained. 

•  Two new pictograms were added, for tyres type-approved for use in severe snow 

and severe ice conditions (13). 

3.  CONSUMER AWARENESS, USE AND UNDERSTANDING OF THE TYRE LABEL 

Consumer understanding of the tyre label was tested through a consumer survey. The main 
findings are summarised below: 

BRAND 
Size 

TYPE 
Class 
Size 

Figure  2.  Consumers  self-reported  understanding  of  the  tyre  label  elements  (baseline  =  all 
respondents (n=4 590). 

As Figure 2 shows, most consumers find the tyre label easy to understand. Only 9 to 18% 
report  difficulty  with  any  specific  element.  A  large  majority,  consider  all  current  label 
elements relevant, particularly wet grip (94%). The majority (78%) felt that the amount of 
information present on the label is appropriate. Other parameters not currently featured on 
the label, such as mileage, were rated as equally or more relevant. Noise and microplastic 
release are viewed as less important or not influencing consumers’ choice (14). 
The survey confirmed the results of a 2019 study  (15) and found  that the label  played a 
meaningful role in guiding the consumers and professional buyers who checked it. About 
80% of both groups stated the label helped them select more efficient or safer tyres. 

Tyre dealers and distributors are familiar with the label and generally view it positively. 
This does not consistently translate into proactive use during sales. Half the interviewed 
salespeople say that they only discuss the label if the consumer prompts them to do so. 
One in  six  discourages customers from  relying on  the label, pointing  out that it is  only 
based on a self-declaration; instead, they base their recommendations on profit margins, 
discounts, incentives, stock availability or customers’ budget. 

(13)  No class rating is indicated for snow and ice grip, as the testing method (braking on a snowy or icy path) 

does not provide sufficiently accurate and repeatable results. 

(14)  This not surprising, confirming that the purchase choice is influenced by aspects that can be translated 

into money savings or increased safety. 

(15)  Study assessing consumer understanding of tyre labels, https://data.europa.eu/doi/10.2833/210444. 

4 

 
 
 
 
 
 
 
 
The tyre label provides easy-to-understand
information about key tyre characteristics

35%

40%

16%

0%

7%

1%

The tyre label provides accurate information about
key tyre characteristics

31%

46%

12%

7%

The tyre label provides reliable information about key
tyre characteristics.

30%

39%

18%

8%

1…

Strongly agree

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Don't know

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Figure 3. Tyre dealers’ and distributors’ perception of the tyre label (baseline = all respondents 
(n=201). 

About  half  of  vehicle  dealers  see  little  value  in  including  tyre  labels  for  all  available 
options  in  vehicle  purchase  offers,  due  to  low  customer  interest  at  the  time  of  sale  or 
because the customer does not have the option to make a selection (16). Consequently, these 
dealers consider the current requirements disproportionately burdensome and suggest that 
a smaller or simplified version of the label should be allowed for use in purchase offers (17). 

The EPREL website is recognised as a valuable source of additional information by the 
consumers, professional buyers, dealers and distributors familiar with it, although actual 
usage appears limited. However, information on some important parameters is currently 
missing in the database (18). Some dealers noted that EPREL simplifies their work, as it 
reduces their reliance on suppliers for information. Some dealers have integrated APIs to 
link their websites directly to EPREL, enabling automatic display of tyre labels and product 
information sheets in the correct language. 

4.  MARKET EVOLUTION 

Technological progress has enabled simultaneous improvements in rolling resistance and 
wet  grip,  while  UNECE  parallel  legislation  has  banned  tyres  that  would  have  been  in 
rolling resistance classes F and G. This trend is continuing and, particularly for C1 tyres, 
UNECE requirements will not allow any new tyre in class E and most of D class to be 
placed on the market. As a result, the current scale offers less differentiation for purchase 
choices and a weaker competitive incentive for manufacturers to innovate. Similarly, for 
noise, all tyres, already since before the Regulation entered into force, have been in classes 
A and B. 

The TLR requires suppliers to register tyres in EPREL before placing them on the market. 
By 2025 EPREL had listed almost 230 000 tyre types: 81% C1, 10% C2 and 9% C3. The 
parameters of those registrations are presented below. 

(16)  With the exception of luxury cars or diplomatic sales, the tyres mounted on the car depend on the tyre 
batch available when the vehicle is assembled at the factory. Some car retailers may agree to exchange 
the wheels, if possible and as an exceptional courtesy to the customer. 

(17)  E.g. just an indication with a class arrow. 

(18)  E.g. currently for C1 tyres, it is not mandatory to indicate which, among the registered tyres, is fabricated 
according to the vehicle OEM specifications, or, for C3 tyres, which are for the drive, steering or free-
rolling axle, or which are for urban or long haul use etc. 

5 

 
 
 
 
4.1.  C1 tyres 

4.1.1. 

Rolling resistance 

Figure 2 shows the estimated C1 tyre average rolling resistance, based on label classes and 
date of placing on the market (19). The dashed line shows the extrapolated business-as-usual 
(BaU) case to 2024 based on the models registered in EPREL from 2015 through 2021, 
with modest progress for new tyre types placed on the market. 

)

N
k
/
N

(
e
c
n
a
t
s

i

s
e
R
g
n

i
l
l

o
R

new tyre label takes effect

 9,4
 9,3
 9,2
 9,1
 9,0
 8,9
 8,8
 8,7
 8,6
 8,5
 8,4

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Figure 4. C1 tyre rolling resistance. 

The average rolling resistance of new tyres placed on the market since 2021 appears to 
have dramatically improved (20). It is estimated that there has been a 5.1% reduction in C1 
tyre rolling resistance since 2021 compared to BaU. 

(19)  Unlike all other product labelling regulations, the TLR does not require the real value of the parameter 

determining the class for rolling resistance and wet grip, but only for the noise. 

(20)  Weighted  percentage  values  for  the  mid-point  label  class  are  used  because  the  Regulation  does  not 
require suppliers to enter the rolling resistance coefficient in EPREL, only the class associated with it. 

6 

 
 
 
 
 
 
4.1.2. 

Wet grip 

 1,44

 1,42

 1,40

 1,38

 1,36

 1,34

 1,32

 1,30

new tyre label takes effect

)

G

(
x
e
d
n

I

p
i
r

G

t
e
W

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Figure 5 shows the estimated average C1 tyre wet grip. Although less  pronounced, wet 
grip performance also appears to have improved compared to BaU for tyres placed on the 
market after 2021 (21). 

 1,44

 1,42

 1,40

 1,38

 1,36

 1,34

 1,32

 1,30

new tyre label takes effect

)

G

(
x
e
d
n

I

p
i
r

G

t
e
W

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Figure 5. C1 tyre wet grip. 

It  is  estimated  that  there  has  been  about  a  2.4%  improvement  in  wet  grip  performance 
compared to BaU. This results in shorter braking distances on a wet road. 

(21)  Based on weighted percentages of the mid-point label class, because suppliers are not required to enter 

the wet grip index in EPREL, only the class associated with it. 

7 

 
 
 
 
 
 
 
 
 
 
 
4.1.3. 

External rolling noise 

Figure 6 shows the estimated average external noise, based on the declared value. Noise 
has increased slightly only until 2018, possibly as a result of the trade-off with wet grip 
(which improved significantly), and of a trend towards larger aspect ratio tyres in new car 
models. There is no discernible divergence from BaU. 

 72,00

 71,50

 71,00

 70,50

 70,00

 69,50

 69,00

new tyre label takes effect

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

)

B
d
(
e
g
a
r
e
v
A

l

i

e
b
c
e
D

i

-
e
s
o
N
g
n

i
l
l

o
R

Figure 6. C1 tyre external rolling noise. 

4.2.  C2 and C3 tyres 

Similar  trends  to  those  for  C1  tyres  were  found  for  C2  and  C3  tyres.  For  C3  tyres,  an 
improvement  in  rolling  resistance  of  about  7.3%  was  found  compared  to  BaU.  Other 
factors may have contributed to the progress shown by the EPREL data. Increased focus 
on  safety  and  the  wider  share  of  electric  vehicles  on  the  roads  may  have  stimulated 
improvements in rolling resistance (22). 

Although rolling resistance, wet grip and noise are conversely interrelated parameters, it is 
possible to improve all three simultaneously. In 2025, several manufacturers offered tyres 
with A-class for all three parameters. 

Share of new models: 

 5 - 10% 

 > 10% 

C1 

Rolling Resistance 

2015 

A 

B 

C 

D 

E 

t
e
W

p
i
r
G

A 

0.0% 

0.5% 

2.0% 

2.3% 

0.0% 

4.8% 

(22)  For trucks, the formula for calculation of fleet CO2 emissions according to EURO IV legislation includes 
the  rolling  resistance  coefficient  of  original  equipment  tyres  (in  diesel  trucks  tyre  rolling  resistance 
contributes 30 to 40% of energy use). In electric trucks the share is higher because of the high electric 
motor efficiency, keeping the energy efficiency focus unchanged. 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
B 

C 

D 

E 

0.0% 

1.9% 

19.8% 

11.6% 

0.7% 

34.0% 

0.0% 

0.5% 

21.0% 

22.5% 

2.5% 

46.6% 

0.0% 

0.1% 

2.6% 

9.6% 

0.7% 

12.9% 

0.0% 

0.0% 

0.2% 

0.8% 

0.7% 

1.7% 

0.0% 

3.0% 

45.7% 

46.7% 

4.6% 

C1 

Rolling Resistance 

2020 

A 

B 

C 

D 

E 

A 

B 

C 

D 

E 

0.7% 

1.7% 

7.5% 

2.9% 

0.0% 

12.8% 

1.4% 

2.4% 

18.9% 

16.4% 

0.9% 

40.0% 

0.1% 

0.7% 

11.2% 

23.6% 

0.5% 

36.1% 

0.0% 

0.2% 

1.4% 

6.6% 

0.5% 

8.7% 

0.0% 

0.3% 

0.7% 

0.3% 

1.2% 

2.4% 

2.2% 

5.3% 

39.6% 

49.8% 

3.2% 

C1 

Rolling Resistance 

2024 

A 

B 

C 

D 

E 

A 

B 

C 

D 

E 

1.1% 

5.1% 

9.5% 

3.6% 

0.0% 

19.4% 

2.2% 

6.6% 

24.9% 

7.7% 

0.6% 

42.1% 

0.3% 

1.3% 

17.6% 

7.5% 

0.4% 

27.2% 

0.2% 

0.6% 

3.7% 

4.9% 

0.5% 

9.9% 

0.0% 

0.1% 

1.1% 

0.1% 

0.1% 

1.4% 

3.9% 

13.8% 

56.8% 

23.9% 

1.6% 

p
i
r
G

t
e
W

p
i
r
G

t
e
W

Figure 7. Evolution of C1 tyre rolling resistance and wet grip. 

Figure 7 illustrates how rolling resistance and wet grip have evolved over the last decade. 
The tables depict the relative proportion of tyre models in 2015, 2020 and 2024 in each 
combination of the parameters. 

Over  this  period,  the  models  placed  on  the  market  shift  toward  the  upper  left  corner, 
simultaneously improving rolling resistance and wet grip. The largest segment moves from 
a combination of D for rolling resistance and C for wet grip in 2015 and 2020 to C and B, 
respectively, in 2024. 

9 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.  DELEGATED ACTS 

Article 13 of the TLR empowers the Commission to adopt delegated acts to: 

introduce new information requirements for retreaded tyres; 
include parameters or information requirements for tyre abrasion and mileage; 

• 
• 
•  adapt other aspects to technological progress. 

5.1.  Retreaded tyres 

Retreaded tyres are worn tyres that are remanufactured with a new tread replacing the worn 
one to give them a second or even third life. Retreading results in a reduction in materials 
and energy used, and related GHG emissions, close to two thirds. In 2022, three industry 
the 
organisations,  ETRMA,  ETRTO,  and  BIPAVER,  submitted  a  proposal 
Commission (23)  to  label  retreaded  C3  tyres.  The  Commission  conducted  a  preliminary 
technical study and started to prepare the analytical basis for a proposal. Stakeholders have 
been consulted, and work is ongoing. 

to 

5.2.  Abrasion and mileage 

As mentioned in chapter 3, and resulting from two consumer surveys in multiple countries, 
an indicator of potential useful service life (or ‘mileage’) of tyres would boost customers 
interest  in  the tyre label: together with  rolling resistance, it is an indicator of economic 
savings, potentially compensating a higher upfront purchase cost of replacement tyres. No 
suitable test method for measuring tyre abrasion and mileage was available until recently, 
thus  the  Commission  have  been  unable  to  take  action  for  introducing  information 
requirements (as from Article 13.3).  

Work is in progress, in the specially constituted UNECE Tyre Abrasion Task Force (TF-
TA) (24) to set abrasion testing methods for C1, C2 and C3 tyres. The C1 UNECE abrasion 
test (25) includes two methodologies: an on-road vehicle convoy method, conducted under 
limited weather and climatic conditions, and an in-door drum method (26). The former test 
covers  8 000 km  on  open  public  roads (27).    Work  for  C2  and  C3  tyres  is  ongoing,  and 
conclusions are expected in 2027 for C2 tyres but later for C3 tyres. 

The  Commission  has  urged  TA-TF  to  develop  a  metric  linked  to  tyre  wear  to  assess 
mileage potential (28) as the activity has focused, so far, solely on setting abrasion minimum 
requirements. In the meantime, a threshold limit for C1 tyres has been set in the Euro 7 
Regulation.  

(23)  The same method would be used as for new tyres. 

(24)  https://wiki.unece.org/pages/viewpage.action?pageId=160694352. 

(25)  GRBP 83, (WP.29/GRBP) Working Party on Noise and Tyres (83rd session) | UNECE, is a subsidiary 

body of the World Forum for Harmonisation of Vehicle Regulations. 

(26)  The quicker, more repeatable and less polluting in-door method, similar to the tests used for measuring 

rolling resistance, saves months to tyre manufacturers introducing new tyre types. 

(27)  25% urban, 25% regional roads and 35% highways, at three temperature levels, between 5 °C and 25 °C. 

The convoy-based test poses repeatability and affordability challenges for MSAs.  

(28)  UNECE Regulation 117 will be amended to include the abrasion thresholds. Data on abrasion levels and 
tread  loss,  thus,  becomes  part  of  the  type-approval  documentation.  If  the  declaration  by  tyre 
manufacturers, via the type-approval documentation on testing results for abrasion would also include 
the tread depth loss, rating mileage may become feasible. 

10 

 
 
 
Table  1.  Schedule  for  mandatory  abrasion  thresholds  according  to  Euro  7  (Regulation  (EU) 
2024/1257). 

Applicable Requirement 

C1 Tyres 

C2 Tyres 

C3 Tyres 

New tyre models from: 

1 July 2028 

1 April 2030 

1 April 2032 

All tyre models from: 

1 July 2030 

1 April 2032 

1 April 2034 

Non-compliant models in market 
until: 

30 June 2032 

31 March 2034 

31 March 2036 

5.3.  Other aspects 

The  labelling  of  retreaded  tyres  would  require  amending  multiple  TLR  annexes.  In 
addition,  the  TLR  also  lacks  clarity  or  detailed  requirements  for  some  respects  (nested 
labels,  public parameters,  compliance  documentation). This  is  source of uncertainty for 
suppliers and both tyres and vehicle dealers and complicates compliance  (29). Alignment 
with the legislation on labelled energy-related products, would solve most of the problems. 

6.  MARKET SURVEILLANCE AND ENFORCEMENT 

Regulation  (EC)  No 765/2008  (30) sets  out  the  procedure  for  compliance  verification  by 
national  market  surveillance  authorities  (MSAs)  for  tyre  labelling  and  for  cross-border 
market  surveillance.  Regulation  (EU)  2019/1020 (31)  on  market  surveillance  and 
compliance of products amended Regulation (EC) No 765/2008, extending its scope and 
aligning definitions and accreditation rules for testing facilities. 

In  addition,  the  TLR  creates  certain  obligations  for  suppliers  (manufacturers,  importers 
and  authorised  representatives)  and  dealers  or  distributors,  including  the  obligation  to 
cooperate  with  MSAs  and  take  immediate  action  in  case  of  non-compliance.  Specific 
requirements are set for internet hosting service providers. 

Tyres are complex, safety-critical products. Assessing tyre quality and compliance requires 
specific  skills  and  expertise.  To  verify  performance,  MSAs  need  specialised,  costly 
equipment and dedicated test grounds or tracks. 

Most  performance  and  compliance  testing  by  MSAs  is  currently  done  on  appliances 
(fridges,  washing  machines,  light  bulbs),  and  very  few  have  specific  expertise  and 
experience on tyres. In many countries, few human and financial resources are allocated 
to  compliance  control,  so  most  perform  only  controls  on  formal  aspects.  Moreover,  in 
about half of Member States, labelling and type-approval competences are split between 

(29)  No small-format label is available for use in tyre catalogues, where about 20 rows on each page describe 
each  tyre,  or    for  vehicle  offers,  where  the  tyre  labels  take  10  times  the  space  used  for  the  vehicle 
description and its options. The lack of indication on which parameters needed to distinguish tyres of 
the same size are to be entered in EPREL hinders the application of the taxonomy or any DNSH criteria. 

(30)  Regulation  (EC)  No 765/2008  setting  out  the  requirements  for  accreditation  and  market  surveillance 

relating to the marketing of products. 

(31)  Regulation (EU) 2019/1020 on market surveillance and compliance of products. 

11 

 
 
 
 
different authorities, with little or no coordination between them, even though the testing 
equipment and procedures used are the same. 

Several Member States do conduct controls, and these show high non-compliance rates. 
Ireland  reported  results  for  36  tyre  models  in  ICSMS (32);  it  found  that  only  33%  were 
compliant in 2024 and 51% in 2025. Germany reported results for 60 tyre models tested; 
it found that  37%  were  compliant in  2023 and 58% in  2024. National  MSAs generally 
conduct market surveillance using a risk-based approach, meaning that the non-compliance 
rates  found  are  not  necessarily  representative  of  market  averages.  Data  from  tests 
performed by the JRC, however, also show very high non-compliance figures. As regards 
tyres entering the EU market, customs controls at the EU external borders remained limited 
and, accordingly, the discovery of non-compliance cases low. 

Under the TLR, Member States are obliged to lay down rules on effective, proportionate 
and dissuasive penalties, as well as establish enforcement mechanisms for infringements 
of the Regulation, and notify the Commission, by 1 May 2021, of those rules. The list of 
penalties notified has been published in the Energy Efficient Products portal (33). 

6.1.  Type approval vs tyre labelling 

Type approval is not performed on every tyre model but only at the level of ‘tyre family’ 
and using the ‘worst-case’ scenario, for each of the regulated parameters. For example, for 
rolling resistance, among the tyres with the same tread pattern but different aspect ratios, 
the one with the lowest load index and largest aspect ratio is considered as the worst-case 
representative tyre. This means that out of 10 or 20 tyres in the same family and with the 
same  tread  design,  only  one  is  tested  for  rolling  resistance,  another  for  wet  grip  and 
possibly another for noise. 

For tyre labelling, every single member of a tyre family is in principle tested, using the 
same testing method. 

This  means  that  compliance  control  and  verification  of  the  class  claimed  on  the  label, 
unless the same as the worst case is indicated, needs a specific testing on the specific tyre 
and cannot rely on the test results of the type approval for the whole family. 

6.2.  EU support to MSAs 

The  Energy  Efficiency  Compliant  Products  4  (EEPLIANT4)  is  an  EU  co-funded 
Concerted  Action  under  the  LIFE  programme,  the  EU’s  funding  instrument  for  the 
environment and climate action. EEPLIANT4 includes a tyres work package under which 
TLR compliance checks will be carried out. Only four MSAs are participating: Cyprus, 
Estonia, the Netherlands, and Portugal, coordinated by PROSAFE (34). 

(32)  Information and Communication System on Market Surveillance. 

(33)  https://energy-efficient-products.ec.europa.eu/national-measures-penalties-and-sanctions-tyres_en. 

(34)  https://prosafe.org/, an MSA coordination consortium. 

12 

 
 
 
Project  

Programme 

Running time 

EU contribution 

MSTyr15 

European Commission’s Horizon 2020 

2016-2019 

€1 854 673 

EEPLIANT4 

LIFE 

2024-2029 

€7 999 999 

Table 3. EU support for the implementation of the Tyre Labelling Regulation and related market 
surveillance 

The Commission also supports MSA activities through: 

• 

•  bi-annual meetings and support to MSAs through the Administrative Cooperation 
(AdCo) Expert Group on Tyres Labelling - Market Surveillance Administrative 
Cooperation; 
the European Product Compliance Network under the Market Surveillance 
Regulation (MSR); 
integration between EPREL and ICSMS; 

• 
•  a ‘safeguard clause’ feature in ICSMS, allowing MSAs to share information on 

products presenting a risk. 

Article 34(4) of the MSR obliges Member States to report in-depth checks on compliance. 
By autumn 2025, the ICSMS database listed 230 in-depth TLR inspections. Figure 8 shows 
the results by Member State. Member States not appearing in the table did not report any 
checks in ICSMS. 

Out of the TLR checks reported, 5 found tyres posing a serious risk and 16 a high risk. 
Correction  measures  included  warnings  (14),  orders  to  withdraw  the  model  from  the 
market (2) and a ban (2). Other measures included changes in EPREL (1) and a change to 
the label (1). Often the correction measure is not reported. 

2020 

2021 

2022 

2023 

2024 

2025 

Spain 

Germany 

Ireland 

Luxembourg 

Croatia 

European 
Union 

Portugal 

Denmark 

90% 

93% 

30% 

37% 

84% 

58% 

33% 

100% 

100% 

50% 

0% 

100% 

0% 

68% 

51% 

0% 

Figure 8. Overview of TLR compliance testing, ICSMS. ‘European Union’ refers to the reports by 
Commission JRC. High percentage (green shading) means models were found to be compliant. 

6.3.  Commission role in market surveillance 

Tyre testing is technically demanding and appears not to be a priority for Member States. 
Insufficient  compliance  information  in  EPREL,  a  large  number  of  models,  high  testing 
costs  (€1 k  to  €10 k  per  unit),  difficulty  to  build  expertise,  lack  of  laboratory  capacity, 
different distribution of responsibilities between national bodies in Member States and lack 

13 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
of coordination contribute to insufficient control, high non-compliance rates and – possibly 
relatedly - distrust by customers and distributors (see the survey findings about perceptions 
of  tyre  labels  as  unreliable  due  to  being  based  on  self-declaration).  Figure  1  shows  the 
surprising rates of non-compliance for the tyres tested by JRC in the years 2021-2024. 

Figure 9: Non-compliance findings by JRC between 2021-2024 (presentation to AdCo meeting, 
1 April 2025, Ispra). 

Stronger involvement by the Commission would be beneficial. Such a strategy is being 
implemented for vehicle safety since 2020. Here, while Member States play a central role 
and conduct surveillance testing, the Commission provides a second layer of control and 
performs independent tests. The Commission is empowered (35) to test vehicles and their 
parts, impose administrative fines directly on manufacturers and order EU-wide recalls (36). 
Tyre type approval is within the scope of the Commission’s competence, but tyre labelling 
falls outside it.  Currently, EU-level testing campaigns are organised to assess compliance 
of tyres sold on the EU market, complementing national controls and filling gaps where 
national capacities may be limited (37). A centralised, coordinated approach, also covering 
labelling, would create synergies and guarantee impartiality, without conflict of interest 
(38). Furthermore, the additional cost of labelling compliance checks would be minimal, as 
they are based on the same tests required by UNECE Regulation 117. 

7.  POSSIBLE THIRD-PARTY VERIFICATION AND TESTING 

The Commission  has sought  to  assess the costs  and benefits  of mandatory independent 
third-party verification of the information provided in the tyre label, taking into account  
the  experience  gained  with  the  broader  framework  provided  by  Regulation  (EC) 
No 661/2009. 

Third-party  verification  can  help  compensate  MSA  deficiencies  in  budget,  labs,  staff, 
coordination and necessary skills. Using third parties could ensure access to state-of-the-
art laboratory equipment and specialised staff. Several labs have already gained experience 
in the broader type-approval framework provided by Regulation (EU) 2019/2144 and are 
also already accredited to conduct all TLR testing activities. However, third-party testing 

(35)  Article 9 of Regulation (EU) 2018/858. 

(36)  A report of activity is available from https://publications.jrc.ec.europa.eu/repository/handle/JRC130606. 

(37)  A report describing the activities carried out by the JRC on tyres are  available at the following link: 

https://publications.jrc.ec.europa.eu/repository/handle/JRC135546. 

(38)  National authorities may be reluctant to enforce compliance/penalties on manufacturers established in 

their territory. 

14 

 
 
 
 
and certification fees can be significant. Table  shows indicative prices for testing for C1 
tyre TLR parameters in laboratories accredited for tyre type-approval legislation. 

Table 4. C1 tyre third-party verification testing costs (per tyre) 

Test Procedure – Tyre Class C1- 

ECE 117 R. Annex 3 – Noise  

ECE 117 R. Annex 5 - Wet Grip  

ECE 117 R. Annex 6 (CR) – Rolling Resistance  

From 

€1 100 

€950 

€650 

ECE 117 R. Annex 7 3PMSF - Snow Performance  

€3 200 

To 

€2 000 

€1 500 

€1 250 

€5 500 

Total for the test procedure: 

€5 900 

€10 250 

Two options exist to mitigate these high third-party verification costs. 

(i)  Random ex post testing, paid for by the public sector. This only appears feasible if 

coordinated at EU level. 

(ii) Systematic mandatory ex ante verification by suppliers, for all declared parameter 
values  in  the  label  if  they  exceed  the  class  equivalent  to  the  ‘worst-case’  as 
documented in type approval certificates (39). This would simply involve disclosure 
of the test reports that manufacturers are supposed to perform in order to claim a 
class better than the ‘worst-case’ as documented in the type-approval certificates 
and which must be uploaded to EPREL. 

8.  TEST MACHINE ALIGNMENT 

The rolling resistance coefficient (RRC) used to assess the energy efficiency class of a tyre 
is measured in a laboratory using a specific machine. Major manufacturers carry out their 
own  RRC  testing.  Some  independent  test  laboratories  also  have  their  own  machines. 
Regular calibration, or realignment, of machines is needed to ensure repeatable, consistent 
measurements. Some non-EU countries rely on a central body to provide this calibration 
service (40). There is no such EU central body. Instead, a ‘virtual reference machine’ and a 
procedure have been put in place, described in Annex V to the TLR.  Every two years, a 
pool of 11 participating laboratories perform a resource-intense ‘round-robin’ process to 
align their machines and provide a reference (41). 

The  Commission  could  develop  an  alternative  to  this  periodical  and  burdensome 
calibration exercise of the pool of different laboratories by establishing a single physical 
reference laboratory one, possibly with a second row of independent laboratories providing 
the service to manufacturers worldwide. The cost of such a laboratory could be covered 
through fees for calibration services. It should be noted that the machines used for RRC 
testing are the same as those used for type approval. Using the same machines ensures that 
the labelling measurements are better aligned with the type-approval measurements and 

(39)  Type  approval  is  at  ‘product  family’  level,  while  tyre  labelling  is  at  tyre-type  level  (each  family 

member). 

(40)  e.g. USA, Korea and Japan. 

(41)  The list of laboratories is published in Commission communication 2012/C 86/03. An update is due in 

2026. 

15 

 
 
 
reduces double testing. 

9. 

ISSUES IDENTIFIED AS PART OF IMPLEMENTATION 

Some issues related to the TLR have been identified during implementation, most of which 
could  be  addressed  by  amending  TLR  annexes.  The  most  pertinent  ones,  along  with 
possible solutions, are outlined below. 

9.1. 

Promotional material, catalogues, vehicle offers 

The TLR provides no detail on the format, size and modalities for the display of labels in 
catalogues, online stores or promotional material or vehicle offers. The only stipulation is 
that the size should be no smaller than 75x100 mm.  This lack of detail has  led to legal 
uncertainty on the one hand and to widespread non-conformity on the other. One practical 
solution, which other energy label delegated acts have provided for in a specific annex, is 
the option to use a simplified, small-format label, in the form of a ‘class arrow with range’, 
possibly combined with a ‘nested display mechanism’ for online pages. Figure 10 provides 
an example of how such an indication might be used for tyres. 

Figure 10. Examples of class arrows as an alternative to displaying the full label (in catalogues, 
lists, vehicle offers on paper or associated with the ‘nested label mechanism in online sales’). 

9.2. 

Insufficient parameters in EPREL to select tyres 

Annex  III  to  the  TLR  lists  the  data  to  be  uploaded  in  EPREL:  the  description  is  very 
generic, and some crucial parameters are not mentioned, thus making the publicly available 
information insufficient for important real-use scenarios (42). Most of the missing parameter 
values may be provided in EPREL but on a voluntary basis. This limits the usability of 
EPREL  for  determining  for  determining  choices,  e.g.    by  fleet  managers  of  the  freight 
transport sector  (43) or, again, selection by vehicle manufacturers for original equipment 
choice (44). Mandatory registration of all parameters relevant for the purchase choice would 
enable such choices by customers and better exploit the label savings potential, by making 
full  use  of  digitalisation  and  EPREL.  Moreover,  identifying  tyres  meeting  the  EU 
taxonomy criteria is not intuitive. A dedicated filter function may remedy this situation. 

9.3. 

Insufficient information to perform compliance checks 

Annex VI to the TLR lists the information for the compliance part of EPREL. The list is 
generic and in practice constitutes a barrier to effective compliance control, particularly in 
those  countries  where  responsibility  for  type  approval  and  tyre  labelling  is  separated. 
Aligning the format of parameters to be provided in EPREL for tyre labelling with that 
used  for  energy  labelling  would  address  this  issue.  The  lack  of  clarity  also  leads  to 

(42)  For example, truck tyres tread design differs depending on whether the tyres are to be mounted, i.e. on 
steering,  traction  or  free-rolling  axle  (the  casing  is  the  same,  overall  performance  may  differ 
significantly). 

(43)  Selection  of  tyres  considering  “axle  position”  or  “mission  profile”  is  crucial,  as  related  to  tread  and 

casing design and, consequently, to rolling resistance, noise or grip performance. 

(44)  Although  each  manufacturer  launches  a  ‘tendering’  mechanism,  the  vehicle  industry  has  clearly 

expressed interest in having a complete market overview, for better tuning requirements. 

16 

 
 
 
 
 
diverging  interpretations  and  a  considerable  burden  on  MSAs,  which  have  to  request 
documentation from the supplier, instead of finding it in EPREL. As every single member 
of  a  tyre  family  must  in  principle  be  tested  unless  the  class  indicated  on  the  label 
corresponds to the ‘worst case’, the availability of test reports would make it possible to 
simplify the compliance control activity, reducing costs and the administrative burden on 
Member States. 

9.4.  Limited separation in performance classes 

Tyre  performance  thresholds  are  set  in  the  UNECE  regulations.  These  are  periodically 
reviewed and updated. Generally, the updated requirements apply first to new tyre types, 
type-approved after entry into force of the limits, and later to existing types. 

Technological  progress  has  permitted  more  stringent  requirements  to  be  set  in  type-
approval legislation, which has banned tyres belonging to the worst classes. However, the 
TLR revision did not include any rescaling or adjustment of classes. As a result, all tyres 
now fit in only three or four rolling resistance and wet grip classes. This reduced range 
decreases  customer  interest  in  the  tyre  label  and  reduces  the  supplier’s  incentive  to 
innovate in order to differentiate their products from those of their competitors. Pending a 
future rescaling, this issue might be mitigated by requiring suppliers to enter in the public 
part of EPREL the RRC and the wet grip index (WGI) measured or estimated to rate the 
class, as is already required for noise (45), allowing professional buyers and other interested 
users to differentiate among products within a class using EPREL. 

10.  CONCLUSION 

The revised TLR has driven measurable improvements in tyre performance, notably a 5.1% 
reduction in rolling resistance and 2.4% improvement in wet grip for C1 tyres since 2021, 
compared to business-as-usual trends. Similar trends were found for C2 and C3 tyres. For 
the latter, the improvement in rolling resistance has been even 7.3%.  The market has thus 
shifted towards higher-performing tyres, with more models now available that achieve top 
(A) ratings across all parameters. 

However,  consumer  awareness  of  and  trust  in  the  label  remain  limited,  partly  due  to 
inconsistent enforcement and reliance on self-declaration. Market surveillance  appeared 
not a priority for Member States, it requires specialised expertise and tools, is difficult to 
carry  out  and,  when  performed,  reveals  high  non-compliance  rates.  This  highlights  the 
need to strengthen coordination, resources and expertise at both national and EU levels. 
While third-party verification and testing could mitigate some of the current shortcomings 
in  market  surveillance,  this  would  come  at  significant  cost.  The  current  test  machine 
alignment  exercise  is  cumbersome  and  the  biannual  exercise  burdensome:  a  single 
reference laboratory, possibly managed by Commission (JRC), may simplify the process 
and  ensure  increased  stability,  with  costs  recovered  by  directly  providing  alignment 
services.  The  machines  could  be  used  for  testing  for  both  the  labelling  and  R.117 
compliance. 

EPREL is a valuable tool, but the lack of mandatory requirements to fill in relevant data 
fields limits its usability for consumers, fleet managers and procurers. Meanwhile, progress 

(45)  Such  RRC  and  WGI  values  are  in  any  case  already  entered  in  EPREL,  but  only  for  the  technical 

documentation and only by some suppliers. 

17 

 
 
 
on abrasion and mileage labelling is delayed by the absence of standardised test methods, 
though ongoing work at UNECE may yield solutions by 2027. 

Finally, the TLR implementation has revealed additional shortcomings, including the lack 
of a ‘nested’ label mechanism definition. Crowding of tyre models in the best 3 classes, 
for rolling resistance and in particular for wet grip and in 2 performance classes for noise 
emissions undermines customer interest in the tyre label. 

The modifications in the omnibus proposal presented in parallel to this report aim to better 
address  some  of  the  different  shortcomings  whilst  also  simplifying  compliance  respect 
where possible, for suppliers and retailers. At the same time, certain issues (such as those 
linked  to  mileage,  abrasion,  re-treading,  testing  machine  alignment  and  testing  for 
compliance  verification)  can  only  be  tackled  when  additional  preparatory  work  has 
progressed. 

18