The EC launched an Ex-post evaluation in regard to the introduction of the Tyre Labelling Scheme in line with the 1222/2009 EU. Many associations and organisations gave their feedback about the acceptance, advantages but also critics and proposed improvements of/to the actual labelling legislation. Also BIPAVER gave its feedback to the scheme, especially in regard to the role of retreaded tyres.
Evaluation and potential revision of the EU tyre labelling scheme – 1222/2009 EC
BIPAVER’s Point of View
BIPAVER would like to contribute with its opinion to the Ex-post evaluation of the European Tyre Labelling Scheme in regard to a possible integration of retreaded tyres.
BIPAVER, as the representation of the independent retreading industry in Europe, generally supports the European Labelling Scheme, although retreaded tyres are at the moment not part of it. The international member associations with their national members are in favour of creating a transparent and neutral tool to inform their end user and fleet customers about the ecological, environmental and safety relevant features and properties of tyres, retreaded in particular.
The EC statement that “the cheapest, cleanest, and most secure energy is the energy that is not used at all”, extend by the ecological use of resources and the prevention of unnecessary waste absolutely corresponds with the principle of tyre retreading.
It is a known fact that reusing a used tyre/casing implicitly contributes importantly to the sustainability. Reuse leads directly to less waste into the environment, as well as an important reduction of raw materials. Approximately 100 litres of crude oil and 69 kg of other materials are required to manufacture an average new truck tyre, a retread only needs 30 litres of crude oil and merely 15-20 kg of materials. Therefore, the carbon footprint diminishes from 220 kg of CO2 emission to only 39 kg, also due to the need of less energy. In addition a modern quality retread delivers comparable performances to a new tyre at a fraction of its price.
That makes the retreaded tyre per definition an ecological, economical and sustainable product which should be generally supported by the EC and its member states. Taking into consideration that the “base” of a high quality retreaded tyre is a retreadable high quality casing it is also common sense to motivate new tyre manufacturers to build appropriate tyres ensuring a possible second or third life as retread instead of distribution “cheap one-way” products. Enabling the retreaded commercial tyre to “visually” prove its capabilities by integrating it into the EC’s labelling schema will promote its market acceptance and competitiveness.
Therefore BIPAVER, in cooperation with ETRMA/ETRTO, proactively works to find an adequate system for the integration. With the RETRYE project, an EU co-funded analysis about the impact of retreading parameters to Rolling Resistance, Wet Grip and Noise, BIPAVER and the especially created consortium gained fundamental supporting know-how.
Due to the aftermarket share of 35- 40% in Europe retreaded truck and bus tyres have an important contribution in the segment of commercial vehicles providing a huge positive impact and added value to the circular economy.
The constraints of an integration are the vast diversity of possible products combinations in a retreading plant/workshop due to the combinations of tyre sizes, casings and tread pattern and the typical SME character of the independent retreading industry. Unlike a type homologated new tyre, million times produced the same way, it is the individuality of each retreaded tyre that makes it so difficult to find an appropriate labelling method. Accurate, reliable and repeatable in relation to the required label performance parameters but affordable and economically feasible for the SME retreader.
Not being a threat but certainly a challenge for the complete retreading business, new tyre industry driven or independent, BIPAVER constructively participates in the solution process. Underlining the fact that the retreaded tyres, as an ecological, environment friendly and sustainable product deserves more support and attention than actually given in society and politics. For further consultation regarding this subject we recommend the EY study about “The socio-economic impact of truck tyre retreading in Europe – The circular economy of tyres in danger”, from October 2016.
