European Commission publishes updated labelling regulation
Just under a year before its mandatory introduction, the European Commission has published its second regulation (1235/2011) paving the way for the implementation of tyre labelling requirements. Regulation 1222/2009 introduces labelling requirements detailing the display of information on fuel efficiency, wet grip and external rolling noise of tyres. According to the ETRMA, which has been involved in consultation on the legislation, the regulation aims to “increase the safety and the environmental and economic efficiency of road transport by promoting fuel-efficient and safe tyres with low noise levels.”
To summarise, the updated regulation states that passenger and light commercial vehicle tyres produced after 30 June 2012 and on sale in the EU from November 2012 will have to either come with a sticker attached or be accompanied by a label “to be displayed on tyres visible by the consumer at points of sale.” According to the ETRMA this means that “for all tyres this information must also be included on supplier web pages, brochures, price lists, on or with the invoice when the tyres have been sold…”
The latest details bring with them two key regulations relating to the implementation of tyre labelling. Commission Regulation 228/2011 provides the wet grip test method for passenger car tyres and Commission Regulation 1235/2011 provides the necessary provisions for the wet grip grading of light and heavy commercial vehicle tyres, the measurement procedure of rolling resistance including laboratory alignment and the related verification procedure. The addition of these details is key to the effective implementation and enforcement of labelling and, with less than a year to go, many sources would argue they come not a moment too soon. Manufacturers producing tyres outside Europe for example have argued that without these specific instructions it has been difficult for them to produce compliant and competitive tyres within the stipulated timeframe. Now these details have been added it is a race against time for all parties to produce the best performing tyres, according to the newly defined labelling, in time for the November mandatory implementation when each and every tyre type and size will have to be graded.
Nevertheless there will be the opportunity for those best prepared to steal a march on the competition. While mandatory implementation is scheduled for November, tyre manufacturers can voluntarily apply European labels to their products five months earlier. However, voluntary early labelling is not allowed before 30 May 2012.
That said even this depends on the correct alignment of testing laboratories, something which is still to some extent up in the air. Before the approved method for measuring rolling resistance and wet grip was still being discussed, now the finest details of the specific calibration of equipment remains on the agenda. What we do know is that the measurement of rolling resistance requires some so called “laboratory alignment” is performed, to ensure that all laboratories around the world will secure comparability of the measurements. Beyond the alignment procedure defined by the newly published Regulation 1235/2011, the list of the reference laboratories as well as the technical details to perform the alignment are expected to be published in the OJEU in the very near future. And without this final document it is still not possible to perform the alignment process properly.
Writing in an official statement marking the publication of the regulation, the ETRMA said that it firmly believes that tyre labelling will “increase interest in tyres and empower consumers and fleet owners to focus more at least on some performances when purchasing a tyre.” The association also believes that the measure will “not only encourage tyre manufacturers to upgrade their products in a context of increased competition on the market, but will offer the possibility for producers to benefit from product differentiation, based also on product quality.”
But not everyone’s view is the same. Tyres & Accessories recently returned from a series of meetings with leading Chinese tyre manufacturers in and around Shanghai and Shandong Province. Here and back in Europe there are those that view the labelling and associated legislative and logistic burden it produces Europe’s own kind of backdoor protectionism following on from the US decision to introduce import tariffs on Chinese made car tyres brought into America. But while some associated with the largest and most professional Chinese firms question the motivation behind the laws they welcome the opportunity to demonstrate the quality of the products. In fact several sources T&A spoke to were actually quite optimistic about the prospect of having labels slapped on their tyres. Their view is that when the consumer sees the label-verified performance of their products alongside the European manufactured alternatives on offer, this performance:price ratio will play in their favour. Sure they may not score an A grade, several executives told T&A, but a B or C at a much lower price is likely to be appealing to consumers.
Retreaded, off-road, temporary use-spare, studded, racing and vintage tyres are currently excluded from the scope of this regulation, but there is already high-level discussions taking place on the subject of applying something similar to the retread market. And with countries such as Korea, Japan and the US discussing and/or applying labelling programmes of their own in the truck and car tyre sectors, there are those that suggest that the spread of this trend into the remaining more speciality areas is just a question of time.