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Labelling Proposal Review Meeting EC

Date: 21 Aug 2024
By: Yorick Lowin
Comment: Comments are off
  • On July 26th BIPAVER finally had been invited to a “Review Meeting” with the EC/DG Trade, IDIADA (who have been contracted by the EC to do the Supporting Study on potential labelling of C3 retreaded tyres), ETRMA, ETRTO to discuss the findings of this study. The Meeting took place physically in Brussels at the EC offices and in parallel by web-access, giving more individual BIPAVER members the possibility to participate.

Here a short summary of the meeting:

I. Welcome and Introduction:
P. Tosoratti welcomes all physically present and remotely connected participants of the meeting.
Short wrap-up of historic context:

  • Regulation (EU) 2020/740 (tyre labelling regulation, amending Reg(EU) 2017/1369 and repealing Reg (EC) No 1222/2009) entered into force June 25th 2020 and has been applied from May 1st 2021
  • Article 13 Delegated Acts: by June 26th 2022 requirements for retreaded (C3-) tyres should have been introduced, under the condition that a suitable testing method is available
  • In May 2022 DG Energy called for tenders for “Supporting Study on potential labelling of C3 retreaded tyres” (here called Review study) and granted it to Applus IDIADA
  • After “positive outcome” of review “Impact Study” “Assisting the Commission with the impact assessment for proposing a delegated act to supplement the regulation in respect to labelling of re-treaded C3 Tyres” has been grated to Viegand Maagoe A/S consultancy July 27th 2024

II. Results of Review Study performed by IDIADA (Summary):
IDIADA presented their findings and recommendations about the BIPAVER/ETRMA/ETRTO (INDUSTRY) proposal:

  • The principal approach of the INDUSTRY to keep for Rolling Noise and Wet Grip the same labelling classes and label band width as given for new tyres in Reg (EU) 2020/740 has been confirmed.
  • The recommendation has been given, that for Wet Grip the tread compound can have a significant impact on the results, nor only the tread pattern/design, as e.g. for the Snow Grip Performance.
  • The INDUSTRY proposal regarding the Rolling Resistance (RR) has also been confirmed:
    • Casing has a major impact on RR performance
    • A wider band width for RR (compared to the 1.0 N/kN for new tyres) of 1.5 N/kN and a verification tolerance of 0.7 N/kN is needed
    • The 3 options to obtain a RR value as proposes by the INDUSTRY have been verified and confirmed
  • Some recommendations/comments regarding RR have been given:
    • The EU Database for Average Casing RR Values should be re-qualified/updated and qualified measuring machines and methods (e.g. applying a well described Standard Buffing Process to assure comparable results, also for market surveillance tests and to calculate the Tread & Process impact to the overall RR value of the retreaded tyre (besides the Casing RR impact)
  • Regarding the EPREL Data Base (data base of EU where each tyre manufacturer/retreader must enter the product/label data for his product range) some additional parameters have been proposed
  • It has been generally recommended to create an “Expert Group” to deal and consult about the open points.

 

III. Next indicated steps from EC side (Paolo Tosoratti):

  • Discussion in the “E01295 – Working Group on Motor Vehicles” (4 October 2024)
  • Impact assessment approval (board) Q2/Q3 2025
  • Interservice consultation between EC DGs (Q3 2025)
  • WTO (?)
  • Vote by E01295/9 Member States Expert group on Motor Vehicles on final draft (Q4 2025)
  • Adoption (Q4 2025?)
  • Objection period (EP/Council, 2 months)
  • Publication on Official EC Journal (Q1 2026?)
  • It has not been finalized how long a “transitional period” (time between the official publication and date of entering into force) needs to be or whether the possibility to have a period of “voluntary application” before the mandatory enforcement.

The expert working group of BIPAVER/ETRMA/ETRTO will analyse the results and recommendation now and decide what updates/ adjustments of the existing proposal is needed. We will keep you informed about the ongoing developments!

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