Explanatory Memorandum to COM(2008)779 - Labelling of tyres with respect to fuel efficiency and other essential parameters - Main contents
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This page contains a limited version of this dossier in the EU Monitor.
| dossier | COM(2008)779 - Labelling of tyres with respect to fuel efficiency and other essential parameters. |
|---|---|
| source | COM(2008)779  |
| date | 13-11-2008 |
Grounds for and objectives of the proposalWith as much as 23% of total CO2 emissions coming from road transport i, reducing vehicles’ energy intensity and emissions is a major challenge for the EU.The Energy Efficiency Action Plan i and the Communication on Greening Transport i announced a proposal regarding the energy labelling of tyres by 2008. The objective is to promote the market transformation towards fuel-efficient tyres, also called low-rolling-resistance tyres (LRRTs).The labelling proposal follows an integrated approach on tyres which will ensure that standardised information is supplied not only on fuel efficiency but also on wet grip and external rolling noise, so that consumers and end-users can make an informed choice. The aim is to promote, through the operation of market forces, dynamic improvement of all parameters beyond the minimum requirements set for type approval (the procedure which grants access to the EU market).
General contextTyres can play a significant part in reducing transport energy intensity and emissions since they account for 20% to 30% of vehicles’ total fuel consumption. This proportion of fuel is used to overcome rolling resistance (RR) due mainly to “hysteretic loss” (loss of energy through the heating and deformation of the wheels while rolling). New technologies make it possible to reduce RR, so that it currently varies by up to 100% across all tyre categories. For passenger cars, for instance, this means a difference of up to 10% in fuel consumption between the worst- and the best-performing tyre set.Studies show that fuel efficient tyres are cost-effective: the price differential of better-performing tyres will be compensated by savings over their lifetime. There is therefore a direct interest for tyre purchasers to reduce their fuel bill and for society as a whole to reduce emissions due to road transport. The impact at EU level could be impressive; the external study conducted within the impact assessment identified a savings potential of from 0.56 to 1.51 Mtoe per year depending on the speed of market transformation. This is equivalent to removing 0.5 million to 1.3 million passenger cars from EU roads (or 3% to 8% of new passenger cars registered).Improvements in RR have been and will be further driven on the original equipment market i by car producers who have an incentive to fit their vehicles with fuel efficient tyres in order to reduce vehicle emissions measured in compliance with type-approval legislation. The Regulation on the general safety of motor vehicles i will in addition ban the worst-performing tyres in terms of fuel efficiency through implementation of minimum requirements governing RR. The market transformation achieved through these two drivers will not, however, achieve its optimum level because of the lack of information available to end-users, in particular for the replacement market.On the replacement market, which accounts for 78% of market share i, consumers and companies have no access to objective data on tyre rolling resistance, and cannot compare increased purchasing costs with fuel savings. Market surveys have also shown that consumers would be interested in buying fuel-efficient tyres.In addition, tyre performances are interrelated, so that acting on one parameter, such as energy efficiency, may have an adverse impact on other parameters, such as wet grip, whereas optimising wet grip may have an adverse impact on external rolling noise. Potential has been identified for improving tyre wet-grip performance characteristics and external rolling noise above the minimum requirements set in the type-approval legislation i. It is therefore in society’s interest to promote optimisation of these two parameters along with rolling resistance.A labelling scheme for tyres at EU level aims to respond to the suboptimal market-transformation towards fuel efficient tyres arising from lack of information. It would allow consumers to make an informed choice, give incentives to tyre manufacturers to upgrade their products and contribute to awareness-raising.
Existing provisions in the area of the proposalThe proposal on tyre labelling is part of an integrated approach to reduce fuel consumption and emissions in road transport. Directed at the demand side, it will complement the type-approval legislation on tyres which addresses the supply side by means of minimum requirements. The minimum requirements governing rolling resistance, wet grip and external rolling noise scheduled to take effect by October 2012 in the proposal for a Regulation on the general safety of motor vehicles will guarantee a standard level of tyre quality, while further improvements above these levels will be driven by the labelling scheme. In a context of increased competition on the tyre market, it will introduce a level playing field for all; with the possibility for producers to benefit from product differentiation so that competition will not only be based on prices but also on product quality. It is also likely to decrease the entry barriers for new entrants based on reputation. The industry will, for its part, receive more return on its R&D investment since consumers and end-users will have access to objective, reliable and comparable information on tyre parameters.Harmonised and accurate testing methods will be instrumental in providing comparable information on tyre parameters. In order to reduce the administrative burden on producers and the costs of testing, the same testing methods should be applied as those defined in the type-approval legislation on tyres.
Consistency with the other policies and objectives of the UnionIncreased market take-up of fuel-efficient tyres through introduction of an energy labelling scheme will contribute to achieving the 20% energy saving potential by 2020 identified in the Energy Efficiency Action Plan i – subsequently endorsed by the Energy Council, the European Council and the European Parliament i.The proposal is in line with the revised Commission strategy on CO2 from passenger cars and light commercial vehicles i and the input from the CARS 21 high-level group i. This strategy is based on an integrated approach for achieving the 120g/km CO2 target by 2012, with 130g/km achieved through a legislative instrument on car emissions as measured at type approval i and a further 10g/km or equivalent achieved through a closed list of additional measures, including the promotion of fuel efficient tyres. Synergies with the revised car labelling proposal i will also increase recognition of the labelling scheme for tyres.Promotion of the market transformation towards fuel efficient tyres complies with the Lisbon and renewed Sustainable Development Strategy as it will encourage investment in R&D, provide for a level playing field for all and reduce the carbon footprint of road transport, thereby contributing to the policy goal concerning sustainable mobility.One of the key objectives defined in the Community Lisbon Programme for 2008-2010 i is promotion of an “industrial policy geared towards more sustainable consumption and production”, as further elaborated on in the Action Plan on Sustainable Consumption and Production and Sustainable Industrial Policy i.Tyre labelling will also play an important part in the objective of “empowering consumers” as formulated in the EU Consumer Policy Strategy 2007-2013 i since it will enable consumers to make an informed choice when buying replacement tyres.
Consultation of interested parties
Consultation methods, main sectors targeted and general profile of respondentsStakeholders’ opinions were consistently gathered throughout the process by means of bilateral meetings and various consultations with Member State representatives, NGOs, consumer and business organisations, the tyre industry, fleet managers, tyre dealers and car producers.- First reactions were gathered during DG ENTR’s public consultation on the Advanced Safety of Motor Vehicles conducted from August to October 2007, which included a proposal for a grading of tyre fuel efficiency. This provision was finally withdrawn from ENTR’s proposal so as to allow for a more in-depth analysis, but feedback from this consultation has been taken into account.- An expert group meeting with representatives of the tyre industry took place on 21 April 2008 in order to clarify technical issues.- A stakeholder workshop was held on 26 May 2008. The working document containing questions regarding various policy choices to be addressed at the workshop, stakeholders’ replies and the workshop minutes were published on the Europa website.
Summary of responses and how they have been taken into accountStakeholder consultation was instrumental in defining policy options and the possible design of a labelling scheme. All respondents throughout the consultation process in general supported the introduction of a labelling scheme, but with reservations on some technical issues:- The first public consultation by ENTR highlighted the need of avoiding downgrading tyre safety performance characteristics when designing a labelling scheme to support fuel-efficient tyres. The tyre industry developed the concept of a “Tyre Performance Integrated Approach” calling for simultaneous consideration of all relevant parameters. This concern was taken into account in the design of the labelling scheme, which provides for a multi-criteria grading scheme.- The request was put forward for more ambitious fuel efficiency classes, and for the same design to be followed as for household appliances (the “A to G” scale) i. Extensive research was conducted as a follow-up under the external study in order to precisely identify the state of the art, the technological potential for further improvements of tyre fuel efficiency and the related production costs. The results were taken into account in drafting the fuel efficiency classes so as to allow for band A to be demanding enough to drive the market towards fuel-efficient tyres but ensure that they remain cost-effective for end-users, in other words that fuel savings will compensate for increased purchasing costs.- Some stakeholders requested the inclusion of external rolling noise in the labelling scheme. External rolling noise, which was not originally included within the scope of the impact assessment, was consequently addressed.- Finally, there was extensive debate as to the relevance of including C2 and C3 tyres (tyres fitted on light- and heavy-duty vehicles) in the labelling scheme. The road transport companies, including their federation, the International Road Transport Union (IRU), called for these tyre classes to be included in the labelling scheme. Since the impact assessment showed a significant fuel saving potential on these markets, it was decided to include them in the scope of the legislative proposal.
An open consultation was conducted over the Internet from 28.04.2008 to 30.05.2008. The Commission received 14 responses. The results are available on ec.europa.eu/energy/demand/legislation
Scientific/expertise domains concernedAn external study was contracted with the European Policy Evaluation Consortium from December 2007 to July 2008 to provide input into the impact assessment.
Methodology usedThe study looked at the technical background supporting the design of a labelling scheme, including trade-off between tyre parameters, market structure and cost/benefit analysis.The specific design of the fuel efficiency and wet grip classes is based inter alia on the following factors: i the state of the art, i production costs to achieve a certain level of RR or wet grip which compared to related fuel savings or safety gains will determine the i cost-effective levels towards which the market can be rationally expected to be driven, i the accuracy of testing methods which may influence the width of the bands.
Main organisations/experts consultedMember State representatives, NGOs, consumer and business organisations, the tyre industry, tyre dealers and car producers were consulted.
Summary of advice received and usedThe existence of potentially serious risks with irreversible consequences was not mentioned.
The technical input and cost/benefit analysis were included in the impact assessment.
Means used to make the expert advice publicly availableThe external study can be downloaded at ec.europa.eu/energy/demand/legislation
Impact assessmentThe impact assessment considered the following policy options for promoting market transformation towards more fuel-efficient tyres.Option 1: No EU action. This constitutes the baseline scenario, including the adoption of minimum requirements governing rolling resistance (RR) as proposed in the Regulation on the general safety of motor vehicles and existing incentives for car producers to fit their vehicles with fuel efficient tyres in order to reduce type-approved emissions measurement levels.Option 2: Single-criterion labelling scheme for passenger car tyres (C1 tyres) regarding fuel efficiency (RR), with minimum requirements on other parameters (wet grip and external rolling noise). Option 3: Dual-labelling scheme for C1 tyres regarding fuel efficiency and wet grip, with minimum requirements on external rolling noise.Option 4: Multi-criteria labelling scheme for C1 tyres regarding fuel efficiency and wet grip extended to external rolling noise.Option 5: Extension of the labelling scheme developed for C1 tyres (Option 2, 3 or 4) to C2 and C3 tyres.Option 6: Economic instruments and public procurement.Comparison of the policy options shows that a multi-criteria grading scheme on C1 tyres (Option 4) brings the most benefits when it is also extended to C2 and C3 tyres (Option 5). The slower market take-up of fuel-efficient tyres compared to Option 2 (single-criterion labelling scheme) would be compensated by safety gains, while the extension of the labelling scheme to C2 and C3 tyres would greatly increase total fuel savings.
The Commission carried out an impact assessment listed in the Work Programme, whose report is accessible on: ec.europa.eu/governance/impact/cia_2008_en
Contents
Summary of the proposed actionThe proposal concerns creating a labelling scheme for tyre parameters including fuel efficiency, wet grip and external rolling noise, addressing C1, C2 and C3 tyres (tyres fitted on passenger cars, light- and heavy-duty vehicles). It will provide harmonised and easy-to-understand information to consumers, companies and retailers by grading tyre performance characteristics. It will guarantee that the information is made available to end-users via different media (e.g. electronic, catalogues, stickers).
Legal basisThe legal basis for the proposal is Article 95 of the Treaty.
Subsidiarity principleThe subsidiarity principle applies insofar as the proposal does not fall under the exclusive competence of the Community.
The objectives of the proposal cannot be sufficiently achieved by the Member States for the following reasons.
As highlighted in connection with implementation of the Car Labelling Directive i, the existence of 27 different labelling schemes places a major burden on producers which have to grade their products differently depending on in which countries they sell their products, and is not efficient in promoting market transformation. The discrepancies that exist between product grading contribute to confusion among consumers and undermine their ability to make an informed choice. In addition, Member States, consumer organisations and the tyre industry have expressed their support for a harmonised labelling scheme.
Community action will better achieve the objectives of the proposal for the following reasons.
A harmonised labelling scheme will reduce the administrative burden on Member States and the tyre industry. It will avoid fragmentation of the internal market and provide a level playing field for all.
The scope of the proposal is limited to harmonisation of product information; implementation and market surveillance will fall under Member States’ responsibility.
The proposal therefore complies with the subsidiarity principle.
Proportionality principleThe proposal complies with the proportionality principle for the following reasons.
The proposal does not go beyond what is necessary in order to achieve the objectives of the legislative proposal. The same tests procedure are foreseen as in the type approval procedure in order to decrease costs lying on tyre producers. Self declaration should also decrease costs of testing which were estimated around 0.03 euro per tyre in the worst case. It is also proposed to develop a sticker displaying the label in a format understandable without translation. In order to minimise logistics costs, pictograms will ensure the labelling scheme is understood without requiring the industry or tyre dealers to attach a dedicated sticker in all EU official languages. Complementary information in the relevant language will be provided on-line (web) to explain the label. Easy recognition of the label’s message by consumers will also be facilitated by making use of a layout for the label similar to the one used for white goods under the Energy Labelling Directive for household appliances.
Labelling tyres should not lead to increased tyre prices. Low-budget tyres will still be provided for sale on the market; the only change is that objective information on tyre quality will be provided to consumers so that competition does not operate on prices alone but on actual performance.
Proposed instruments: Directive.
Other means would not be adequate for the following reasons.Market surveillance and compliance with the Directive will be crucial to ensure the scheme’s success. Member States should therefore develop their own monitoring procedures. Awareness-raising campaigns explaining the labelling scheme will be better addressed to end-users and consumers if they are drafted at national level. It is therefore proposed to adopt a Directive for transposition into Member States’ legislation.The proposal uses the “split-level approach” whereby the Directive’s fundamental provisions will be adopted under co-decision, while the technical specifications and adaptation to technical progress will be adopted under comitology, in accordance with the regulatory procedure with scrutiny provided for in Article 5a of Decision 1999/468/EC.
The proposal has no implication for the Community budget.
European Economic AreaThe proposed act concerns an EEA matter and should therefore extend to the European Economic Area.
E-