www.etrma.org
EUROPEAN TYRE & RUBBER
EFWG-02-01
manufacturers’association
WHY THE NEED FOR ENFORCEMENT?
THE « TYRE » CASE
Enforcement Informal Working Group
WP.29, June 27 2013 – Geneva
FAZILET CINARALP,
SECRETARY GENERAL
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EUROPEAN TYRE & RUBBER
manufacturers’association
Content
• ETRMA
• Tyre regulations: REACH, type approval,
tyre labelling
• Why is “enforcement” an issue?
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TYRE INDUSTRY REPRESENTATION IN EUROPE
EUROPEAN TYRE & RUBBER MANUFACTURERS ASSOCIATION
Represents 12 major tyre manufacturers producing within the EU-27
Acts in legislative matters, such as road safety & transport, environment &
health protection, global trade
Represents the industry towards the European institutions
and other international bodies
ETRTO
is a technical organisation:
Issues Internationally referred tyre Standards and Recommendations on tyre use &
maintenance
Contributes actively to UNECE WP29 tyre regulatory activities in Geneva
Provides expertise to ETRMA on technical matters related to tyre performance
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TYRE INDUSTRY REPRESENTATION IN EUROPE
EUROPEAN TYRE & RUBBER MANUFACTURERS ASSOCIATION
Represents 12 major tyre manufacturers producing within the EU-27
Acts in legislative matters, such as road safety & transport, environment &
health protection, global trade
Represents the industry towards the European institutions
and other international bodies
EUROPEAN TYRE & RIM TECHNICAL ORGANISATION
Is a technical organisation:
Issues internationally referred tyre Standards & Recommendations on tyre use &
maintenance
Contributes actively to UNECE WP29 tyre regulatory activities in Geneva
Provides expertise to ETRMA on technical matters related to tyre performance
4
BACKGROUND
The tyre industry operating in the E.U.
 Most stringent safety and environmental regulations
 The tyre market is very diversified, fragmented and huge
> 240 different tyre brands on the market
> 62000 product lines
~ 300 million tyres annually sold with 25% imports
 Sophisticated and expensive testings
 Mix of type approval (third party homologation) and self-declaration
 Tyres replaced on average 3.7 times in the life of a car (and more frequently in the
case of Heavy Duty Vehicles)
 Significant increase of tyre imports from low cost countries (also on higher
performance segments!)
 Enforcement is responsibility of 27 individual countries (28 from July 2013)
Need to: preserve consumers/citizens’ trust in legislation
secure coordinated action against non-compliant products and products
presenting a serious risk
protect fair economic operators against unfair competition from operators ignoring
or by-passing the rules of the game
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SOPHISTICATED AND COSTLY REGULATORY
FRAMEWORK
Example: the TYRE sector
The same industrial sector, could be, directly or indirectly, significantly
impacted by various regulatory policies AT ALL LEVEL OF BUSINESS.
Consolidated
framework
(2010-2020)
Proper enforcement ensures the competitiveness of the EU market!
Materials
REACH, CLP
Production &
Process
Logistic
Product use
ETS , IPPC, SEVESO
General Safety Reg., TYRE
UN ECE regs 30,54,75,117 LABEL, VEHICLE EMISSIONS
End of Life
Waste
legislation, EPR
for NON EU manufacturing-based players
EU Authorities market
surveillance potential
for EU manufacturing-based players
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EUROPEAN REGULATORY FRAMEWORK
- Mandatory Compliance
REACH REGULATION
Restricted Substances (PAHs) in tyres
• “High PAH” restriction imposed per EU REACH Regulation
1907/2006, Annex XVII, Entry # 50. (based on carcinogenic nature
of certain PAHs used in extender oils for tyre production)
• Has been applicable for tyres produced since 1 January 2010
• Covers all tyres intended for road use faster than 25 km/hour (cars,
motorcycles, trucks, buses, agricultural and earthmover)
• Applies equally to imported tyres and EU-produced tyres
• EU importer is legally responsible for product compliance, but nonEU producers can assist with own testing and Manufacturer
Compliance Certificate, or, EU importer may perform own-test and
provide Importer Compliance Certificate for the downstream supply
chain
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EUROPEAN REGULATORY FRAMEWORK
– Mandatory Compliance
General Safety Regulation 661/2009 and tyres
• For both original and replacement tyres, must satisfy technical
requirements relating to: wet grip; rolling resistance; and rolling noise
(UNECE 117.02)
in addition to Tyre Integrity, dimensions and markings (EU Directive 1992/23 ->
UNECE 30 or 54)
– Rolling Noise: Reduction by average of 4 db(A); mandatory for new tyre types
(C1/C2/C3)from11/2012 and existing types from 11/2016
– Wet Grip: Identical to the current requirements in UNECE Regulation 117; Mandatory
for new C1 tyre types from 2012 and existing types from 2014
– Rolling Resistance:
• Phase 1: 2012 (New)
2014 (Existing types-C1&C2)
2016 (existing types-C3)
• Phase 2: 2016 (New
2018 (Existing types-C1&C2)
2020 (existing types-C3)
• EU Directive 1992/23 on tyres replaced from 1 November 2017
• Type-approval in accordance with mandatory UNECE regulations
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EUROPEAN REGULATORY FRAMEWORK
– Mandatory Compliance
UN reg.30 or 54 + 117.01/02=EC 661/2009
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EUROPEAN REGULATORY FRAMEWORK
– Mandatory Compliance
Tyre Safety & Environment Labelling Requirements
•
Regulation 1222/2009 provides harmonized labelling rules aimed to
encourage consumers to purchase tyres with higher standards for
rolling noise, fuel efficiency and wet grip (i.e., tyres meeting higher
than minimum standards required by Regulation 661/2009)
•
Refers to ISO test methods, except RR alignment is EU specific
•
Applies to passenger car tyres (C1), light commercial vehicle tyres
(C2) and heavy vehicle tyres (C3). Others exempt
•
Mandatory from 1 /11/ 2012 for tyres produced from 1 July 2012
•
Self certification but laboratory alignment for rolling resistance
•
Opportunity for every producer to demonstrate quality of its products –
wherever produced
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REACH: CONTROLS AT POINT OF SALE
Private and public authority test programmes
have been conducted (2010 & 2011)
Test programmes were objective/fair
•
ECHA test campaigns, 94 tyres tested, 59 brands,
manufactured in 53 factories in 20 countries
•
Industry test campaigns (2), >200 tyres tested, 84 brands;
manufactured in 92 factories in 20 different countries (both EU and nonEU)
•
More than 400 tests/controls were carried out.
 11% of the tyres tested were found not-compliant
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TYPE APPROVAL: CONTROL ACTIVITIES AT CUSTOMS
Non compliant marking
Controls by Dogane e Guardia di Finanzia (Italian Customs and Competition
authorities)  stopped a container with (motorcycle) tyres imported from a
third country: strangely marked and raising doubts about proper homologation
TA identification number missing or incomplete, or mis-used
means that the tyre might not have been homologated.
Therefore it should not be allowed to circulate in the EU
as its safety is not guaranteed.
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TYPE APPROVAL : ROADSIDE CONTROLS
Not - homologated tyres
Controls by Italian Traffic Police from 2003 to 2012
More than 70.000 vehicles checked on almost the entire territory of
Italy
20% of motorcycles were fitted with tyres not- homologated
10% of passenger vehicles were fitted with tyres not-homologated
TA identification number missing or incomplete, or mis-used
TA
identification
missing
or incomplete,
or mis-used
means
that the number
tyre might
not have
been homologated.
means
that the tyre
is not homologated
and to
therefore
it isin
not
allowed
Therefore
it should
not be allowed
circulate
the
EU to
circulate
EU and
unsafe
for road drivers.
as in
itsthe
safety
is not
guaranteed.
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LABEL: CONTROLS AT POINT OF SALE
Fake labels could be different from that design or the
performances may not be corresponding to the
grades shown on the label.
Controls on the compliance of the label, the
documents accompanying it and tests on the tyre are
needed to ensure that the labelling scheme is
correctly implemented.
Tyres that do not deliver on the expectation created
by the label are not only a scam for the consumer, but
also hurt the whole credibility of the scheme.
An Administrative Cooperation for Market
Surveillance (ADCO)on Tyres Labelling - ADCO Group
on Tyre Labelling was created in June 2012.
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GENERAL EXPECTATIONS
1. EU continues to maintain high level of safety and environment
protection concerning tyres as well as for other sectors and goods
(chemicals, workplace H&S), and may continue to get stricter
2. EU industry has had to invest heavily to comply fully with the
strict EU standards; expects that all producers wanting to share
the EU market will make the same investment to comply with the
stricter EU rules
3. Appears that market surveillance and enforcement activities will
be strengthened in future
4. This is an opportunity to show product quality in a very
competitive international market.
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INDUSTRY PROPOSALS
1. Harmonization of minimum level of penalties at EU level to avoid that
certain member states become more attractive for non-compliant and
unsafe goods.
2. Clear definition of responsibilities amongst various market operators.
3. Specific guidelines to Member States on verification criteria, facilities
where to find expertise.
4. Because the testing methods are sophisticated and costly, build a network
of testing labs fully recognized and approved at EU level for running
compliance test.
5. Measures to ensure cooperation amongst various market surveillance
authorities, between these and the customs authorities and between
these and customs authorities of third countries.
6. Public-private cooperation for market surveillance as well as earmarking
of funding derived from penalties.
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THANK YOU
www.etrma.org
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