The European Commission (EC) has announced its intention to revise the European tire labelling scheme. The Commission published a roadmap on 11 July indicating the timescale for this. The final revision is expected to be published in early 2019, and most of 2018 will be spent thrashing out the details of the revisions.
Although a large consultation exercise took place in 2015, and the EC commissioned a market research firm to carry out a preparatory Study in 2016, a new public site has been opened for comments. This opened on 12 July and will remain open until 9 August. Existing comments are visible on the site. As we write there are two comments. One from the ETRMA and a second one from the European Federation of Water Services.The Commission has proposed four groups of options:
The Commission has proposed four groups of options:
- No action;
- Non-legislative action to improve the implementation of the scheme, for example by introducing additional guidance, advertising, or concerted enforcement action (including greater coordination of market surveillance authorities);
- Targeted legislative amendments, for instance by introducing snow and ice performance information on the label or by adding a requirement for suppliers and distributors to upload tire information to a digital registration database;
- An extensive revision of the Regulation, for example to introduce mandatory and independent third-party testing of the tire performance.
During an interview with the secretary-General of the ETRMA, Fazilet Cinaralp, she said there are several aspects to the revision.
Aspects of the proposed revision
Revising test methods
The first aspect is a technical revision of some of the test methods. Since the original test methods were agreed, test methodology has advanced and we have also seen a certain amount of effort by some manufacturers to develop tires to the test method, rather than real-world performance. She was keen to point out that the label grade limits are not going to be changed. It is a matter of bringing the testing methods up to date. She said that wet grip for passenger car tires will be a particular focus of this effort.
Ice and snow grip
A second aspect is the issue of ice and snow grip. Cinaralp said a number of times that the ETRMA is in favour of providing the public with more information about ice and snow grip, but emphasised that before this information can be offered, that any tests associated with the criterion must be robust and reliable.
The information would be a pass/fail test rather than a multi-level grade system. In November 2012, Europe introduced the 3-Peaks Mountain Snowflake (3PMSF) logo as a pass/fail to distinguish Summer tires from those that can perform well on wintry conditions. According to Cinaralp, any future information about ice and/or snow grip is likely to be something similar, rather than a graded scale.
She said that the standardisation work is being carried out by ISO, the international Standards organisation. This is especially important, because these tests are not just applicable to Europe, but likely to Russia, Canada and the northern United States and some parts of China. She said, “ETRMA is in support of having complementary information on the snow and ice. The work of the test method will be completed and then it is a matter of how the commission wants to make this information available and if it will be mandatory or voluntary. She added that the ETRMA wants the EC to carry out a proper assessment of the consumer impact
She said, “ETRMA is in support of having complementary information on the snow and ice. The work of the test method will be completed and then it is a matter of how the commission wants to make this information available and if it will be mandatory or voluntary. She added that the ETRMA wants the EC to carry out a proper assessment of the consumer impact on the message that will be received and does not create confusion.
Label data on web-shops
A third aspect of the label revision concerns the availability of label data on on-line web shops. She said that these there is no mandatory requirement for these online sales outlets to provide label data. As a result, different shops provide different data and this can confuse consumers.
Comments from interested parties
The comments from the Water Services Association focus on the need to identify and trace small wear particles that originate at the tire-road interface, and understand their route into the aquatic environment.
The comments from ETRMA call for a market study that tracks the evolution in label grades distribution and discerns how much the label itself had been the chief driven for any evolution of this kind.
On the Ice/Snow labelling, the ETRMA says there needs to be some study of the clarity and public understanding of the logos that might be used on the tires.
ETRMA also comments on discussions over a European tire registration database. The group says that any such tools should be “thoroughly defined and assessed in terms of objectives, final users, workload, process, accessibility and data security, management costs” and other matters.
ETRMA would also welcome a move to add retreaded tires to the scope of the label.
The ETRMA submission also expands Cinaralp’s comments above in relation to measuring wet grip. ETRMA says that experience since the introduction of the label has revealed a need for further improving the accuracy of the wet grip test method. ETRMA is already working on this method with ISO and other international organisations and calls for the new test method to be included in the new labelling regulation.
We believe that the introduction of separate ice/snow criteria will substantially increase demand for Winter tire testing facilities. Already, there is pressure on Winter test facilities due to the increased number of tire launches in the Winter segment. Many of these are private facilities designed to acquire data and generate qualitative feedback from drivers. The conditions of the ice and snow are not closely regulated at many of these facilities.
Because there are many types of snow and ice, all of which have different grip characteristics, and grip depends critically on temperature, humidity and other parameters, we expect that the ice/snow criteria will have to be tightly defined, in order to make the test criteria repeatable. This will require limits on ambient conditions when the tests are carried out.
In general, the only facilities where humidity, temperature, and other parameters can be regulated are the indoor centres, such as the TestWorld facility in Ivalo, Finland and the AIBA facility at Continental’s Contidrom facility in Hanover.
As the trend toward labelling and registration continues, the requirement for controlled testing conditions will surely rise.
A second issue is raised in the ETRMA comments – the issue of a registration database. We think that this is now almost inevitable. China is expected to introduce a registration database. The United States has moved some way down that road, and there are intense discussions across Europe on the same subject. We are convinced that the registration database will be based on date from RFID tags and that there will be a requirement for all tires to carry an RFID tag. This is likely to be introduced globally in the 2021-2025 period.
This article first appeared in our Weekly China Tire Intelligence report. A much more complete article on ETRMA activities, as well as articles on sustainability; change in the tire industry and the global natural rubber industry wil be published on July 31 in our monthly Global Tire Intelligence report.