The European Commission DG ENER (Directorate-General for Energy) has entered into a contract with Viegand Maagøe to support the impact assessment study for the development of a label for retreaded C3 tyres commonly found on trucks and buses. 

Background

Tyre labelling according to Regulation 2020/740 [1] enables customers to make informed choices based on clear indications about the fuel/energy efficiency (rolling resistance), wet grip and other important supplementary information. Tyre labelling can make a significant contribution to fuel/energy savings, while at the same time promoting innovation and investments into the development and marketing of better-quality tyres. By harmonising related requirements at Union level, tyre labelling also benefits manufacturers, industry and the Union economy overall.

 

The energy label for new tyres set out in the Regulation cover fuel/energy efficiency, safety and noise performance and grip on snow and ice capability apply from 1 May 2021. New C3 tyres (commonly used on trucks and buses) must also be labelled. 

 

The label follows the well-known colour-coded classification system used for appliances such as dishwashers and refrigerators, albeit with only 5 different classes available for rolling resistance and for wet grip, and 3 classes for external rolling noise. Rolling resistance is an indicator of the tyre’s energy efficiency, showing potential benefits in terms of lower fuel consumption and extending the distance that can be covered by vehicles between refuelling or charging points, while the wet grip measurement is an important measure of safety. Improvements in the performance of these aspects can affect other performance parameters. For this reason, the performance of both classes is displayed in the label with equivalent visibility. Noise may be affected as well.

 

Re-treaded tyres constitute an important part of the market for C3 tyres. The re-treading of tyres extends their lifespan and contributes to circular economy objectives, such as waste reduction. Applying labelling requirements to such tyres would bring substantial energy and material savings, contributing to the expansion of the circular economy.

 

According to article 13.2 of Regulation 2020/740, Commission shall adopt delegated acts in accordance with Article 14 in order to supplement this Regulation by introducing new information requirements for retreaded tyres in the Annexes, provided that a suitable test method is available.

 

A delegated act to supplement the Regulation in respect to labelling of re-treaded tyres could not be proposed by 26 June 2022, as required in article 13.2 of Regulation 2020/740, given the lack of a suitable available test method. Work to address this barrier has progressed, initiated by an industry proposal submitted in October 2022 for the labelling of re-treaded C3 (truck/bus) tyres [2]. In response to that proposal, the Commission launched a study by an independent laboratory specialised in homologation testing of vehicles and components to assess the validity and feasibility of the industry proposal. The findings of this independent study are going to inform this impact assessment.

 

Scope

This study will assist the Commission in the development of a proposal on the labelling of a limited number of sizes of re-treaded C3 tyres (i.e., commonly used by buses and trucks). According to preliminary estimates from the preparatory study, the label will cover a subset of C3 tyre sizes tyres that represent about 90% of re-treaded tyre sales in the EU-27.

 

Methodology

The principal output from this study will be a report on which the Commission can conduct its impact assessment. The study is designed around three key tasks:

  • Task 1: Information gathering
  • Task 2: Problem definition
  • Task 3: Impact assessment

While conducting this work, the study team will follow the Better Regulation Guidelines [3] and Better Regulation Toolbox [4].

 

Task 1: Information gathering

The Study Team will gather information from researching technical and industry literature, conference proceedings and presentations, trade journals and other sources.  The Team will also gather input from stakeholders and other experts on retreaded tyres and the tyre market.
 
Task 2: Problem definition
The study team will identify key problems related to the labelling of re-treaded tyres, highlighting the problem drivers and consequences. For each problem, the causality chain will be described. As much as possible, this problem definition will be based on measurable and quantifiable parameters. The better regulation framework will be used as methodological reference.
 
Task 3: Impact assessment
In consultation with the Commission, the study team will develop policy options that address the problems and deficiencies identified. These options will be sufficiently diverse to cover different levels of ambition and leave room for political choice.
 
The impacts of each policy option will be assessed in line with the Better Regulation guidelines. The study team will provide the results of the scenario calculations made for each policy option, including the baseline. In support of this work, the study team will compile and analyse comments received during the consultation phases and individual consultations with stakeholders.
 
The study team will draft a report - following the Better Regulation format - that summarises the results of the previous tasks and serves as a basis for the impact assessment report.
 

[1] Regulation (EU) 2020/740 of the European Parliament and of the Council of 25 May 2020 on the labelling of tyres with respect to fuel efficiency and other parameters, amending Regulation (EU) 2017/1369 and repealing Regulation (EC) No 1222/2009 (Text with EEA relevance). Available at: https://eur-lex.europa.eu/eli/reg/2020/740/oj

 

[2] ETRMA/ETRTO/BIPAVER proposal for EU labelling for retreaded commercial vehicle tyres (C3 tyres). https://www.etrma.org/wp-content/uploads/2023/02/ETRTO-ETRMA-BIPAVER-proposal-for-Retread-labeling-_C3-tyres.pdf

 

[3] Document SWD(2021) 305 final  - Commission Staff Working Better Regulation Guidelines. Available at: https://commission.europa.eu/law/law-making-process/planning-and-proposing-law/better-regulation/better-regulation-guidelines-and-toolbox_en