Tyre rolling resistance: response to the EU public consultation (part 2 of 2)

1. T&E welcomes the fact that the Commission, albeit years too late, has finally stated its intention to regulate tyre rolling resistance and tyre pressure monitoring systems.
2. Effective standards must be urgently introduced applying to original equipment, replacement and retreaded tyres for all road vehicles (C1, C2 and C3 tyres).
3. T&E deplores the lack of ambition of the proposed standards. The limit values suggested are far from technology-forcing. They are insufficient to make a real difference in the marketplace.
4. A 10 kg/tonne standard for C1 and C2 tyres is much more adequate as this at least ensures that a significant part of the market has to improve its performance.
5. Standards for 2016 are also needed to push innovation. As current ‘best practice’ tyres have a rolling resistance of about 7 kg/tonne, a 2016 limit value should at least be in that range.
6. Supporting instruments are necessary, including labelling, provision of consumer information and purchase incentive programmes.
7. Labels should contain the usual seven instead of the arbitrary four bands the Commission proposes. They should be equipped with the usual red-green colour codes to ease decision making. They should apply to all tyres, be adjusted for technological progress, and include an estimate of fuel cost savings over the lifetime of the car compared with the ‘worst’ G label tyre in order to strengthen the incentive and forge a link with the interests of the consumer. Today’s best tyres should qualify for a B label rather than an A label in order to ensure a strong innovation incentive;
8. There is no justification to permit further allowances in rolling resistance limit values for extra-wide tyres intended for personal or commercial use.
9. T&E requests that the Commission introduce mandatory energy efficiency labelling. The “most efficient” category in these prescriptions should be beyond the performance of the best tyres of today, in order to pose an innovation challenge to the industry.
10. T&E strongly supports the introduction of accurate tyre pressure monitoring systems (TPMS) that detect deflation much earlier than the systems in the US, that are primarily designed to prevent dangerous levels of deflation.

Our overall conclusion is that the detailed requirements of the rolling resistance draft proposals are highly disappointing in the light of the EU’s climate and energy efficiency targets. The proposed standards and labelling scheme should be drastically improved.