TYRES EUROPE: “ENERGY LABELLING OMNIBUS SHOULD SIMPLIFY, NOT ADD COMPLEXITY TO THE TYRE INDUSTRY”

Following the publication of the European Commission’s Omnibus on Energy Labelling, Tyres Europe calls for a more consistent approach to simplification in the proposed amendments to the tyre labelling framework.

The proposal includes measures to reduce certain administrative steps, such as digitising the labels, establishing a technical link between EPREL and the Digital Product Passport registry, and enabling the EPREL database to automatically generate label images.

However, after a first assessment of the package, other elements risk moving in the opposite direction.

Proposals to provide additional empowerment for delegated acts, which could enable rescaling of the label, will create new regulatory uncertainties and technical impediments.

Similarly, the proposals to expand the Product Information Sheet (PIS), introducing nested labels and expanding EPREL database requirements, risk adding administrative complexity for manufacturers and the wider tyre supply chain, without clear evidence that they would improve consumer choices.

Finally, the Omnibus should include clear and consistent amendments that ensure the digitalisation of the tyre label.

Recent evidence shows that the challenge is not the absence of information, but limited consumer engagement with the tools already in place.

According to the Commission’s own report, only 39% of surveyed consumers recalled seeing the tyre label while shopping, down from 50% in 2017. The same report found that only 5% of consumers were aware of or had consulted the EPREL database when purchasing tyres.

Independent findings, including the Lizeo Report on the Evolution of the Tyre Label, also indicate that the label has had a limited impact in shifting consumer demand towards higher-performing tyres.

Adam McCarthy, Tyres Europe Secretary General:

“The priority should be to make the existing tyre label better understood and used by consumers, not to add new layers of complexity that risk creating costs without changing purchasing behaviour. A simplification package should simplify.”

During the 2021 revision of the Tyre Labelling Regulation, EU co-legislators already decided not to introduce additional EPREL data requirements, recognising the significant technical and administrative challenges they would create for the tyre sector.

Tyres Europe therefore calls for a more coherent and targeted approach:

• Improve consumer awareness and understanding of the existing tyre label.
• Support market incentives that help consumers choose better-performing tyres.
• Avoid adding new technical layers without clear evidence of consumer benefit.

Tyres Europe stands ready to work with the Commission and co-legislators to ensure the final framework delivers practical simplification, better consumer information, and a competitive regulatory environment for European businesses.