Aruanne - COM(2026) 326

EN EN

EUROPEAN COMMISSION

Brussels, 24.6.2026

COM(2026) 326 final

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE

COUNCIL AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE

Report on the implementation of Regulation (EU) 2020/740 on the labelling of tyres with

respect to fuel efficiency and other parameters

1. INTRODUCTION

1.1. Policy and legal context

Tyres are a critical component of every road vehicle. Tyre rolling resistance directly affects

the vehicle’s energy consumption. Encouraging the demand for, and the development and

production of, more efficient tyres can therefore reduce fuel costs, emissions and imports

of fossil fuels – or increase the range of electric vehicles by reducing the electricity needed

per driven kilometre. The first formal EU act on efficient tyres was adopted in the wake of

the 1973 oil crisis, recommending ‘that the fitting of radial-ply tyres on all vehicles,

including heavy goods vehicles, be encouraged’ by Member States (1).

Fifty years on, radial tyres have become the default technology, but road transport still

accounts for a significant part of total EU final energy consumption (around a quarter), and

the vast majority of that energy still comes from oil. Meanwhile, innovation in tyre design

and materials has made further efficiency gains possible. Estimates suggest that replacing

high rolling resistance tyres with low resistance ones could cut average energy

consumption of passenger cars by some 2% (2). For heavy duty vehicles, rolling resistance

from tyres is far more important, and the potential for efficiency gains greater: rolling

resistance influences energy use up to one third in diesel trucks and over half in a more

efficient electric ones (3).

At the same time, another tyre parameter, wet grip, is critical for safety as it determines a

vehicle’s breaking distance. Wet grip and rolling resistance are competing metrics, and for

customers deciding on which type of tyre to buy there may be some trade-offs between

safety and energy performance. To make well-informed purchasing decisions, customers

should therefore have information on both parameters. To this end, the first EU Tyre

Labelling Regulation (TLR hereafter) was adopted in 2009 and revised in 2020. Tyre labels

provide easy to understand information to stimulate demand for, and competition in the

supply of, better tyres.

The TLR’s legal bases are Article 114 and 194 of the Treaty on the Functioning of the

European Union. The Regulation’s scope covers tyres for passenger vehicles (C1), vans

and light trucks (C2) and heavy trucks and buses (C3) (4). The TLR works in tandem with

minimum performance requirements set in other legislation. Type-approval legislation, in

particular UNECE Regulation 117, establishes the most important minimum performance

standards for tyres placed on the EU market in terms of rolling resistance, wet grip, noise,

snow grip and ice grip. Relevant minimum performance standards are also set in UNECE

Regulations 30 (C1 tyres), 54 (C2, C3 tyres), 172 (re-treaded tyres). While no EU

ecodesign legislation has yet been adopted for tyres, tyres are included in the 2025-2030

working plan on ecodesign and energy labelling (5).

(1) 76/494/EEC: Council recommendation of 4 May 1976 on the rational use, through better driving habits,

of energy consumed by road vehicles, OJ L 140, 28/05/1976 P. 0014 – 0015.

(2) Zacharof, N., Fontaras, G., Ciuffo, B., Tsiakmakis, S. et al. Review of in use factors affecting the fuel

consumption and CO2 emissions of passenger cars; Joint Research Centre, 2016.

(3) Hyttinen, Jukka et a. Effect of Ambient and Tyre Temperature on Truck Tyre Rolling Resistance,

International Journal of Automotive Technology, Nov. 2022.

(4) Tyres for off-road, construction, agriculture or for two and three-wheeled vehicles are out of scope as

fuel efficiency or safety aspects would not be relevant.

(5) COM(2025) 187 final.

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1.2. Main changes in the 2020 revision of the Tyre Labelling Regulation

The key changes introduced by the 2020 revision were to:

• align the label style and format with the more familiar energy label;

• reduce the number of performance classes, from seven (A-G) to five (A-E), for

both rolling resistance (energy efficiency) and wet grip (safety) because more

stringent UNECE type-approval requirements had banned tyres falling into the

worst performing classes on the label;

• require registration of every tyre type in the European Product Registry for

Energy Labelling (‘EPREL’) (6);

• improve customer awareness of the tyre label by strengthening the requirements

for showing the tyre label to consumers;

• empower the Commission to adopt certain changes through delegated acts.

1.3. Scope of this report

Article 15 of the TLR requires the Commission to carry out an evaluation of the Regulation

and submit a report to the European Parliament, the Council and the European Economic

and Social Committee. The report is to assess ‘how effectively this Regulation and the

delegated acts adopted pursuant thereto have led end-users to choose higher‐performing

tyres, taking into account the impact … on business, fuel consumption, safety, greenhouse

gas emissions, consumer awareness and market surveillance activities. The report shall

also assess the costs and benefits of mandatory independent third‐party verification of the

information provided in the tyre label, taking into account experience gained with regard

to the broader framework provided by Regulation (EC) No 661/2009’.

This report focuses on the following topics:

• consumer awareness, understanding and use;

• market evolution;

• delegated acts;

• market surveillance and enforcement;

• third-party verification and testing;

• test machine alignment;

• issues identified as part of the implementation.

Some aspects are analysed as part of the Impact Assessment accompanying the omnibus

simplification proposal on energy-efficient product legislation adopted in parallel with,

and informed by, this report and the underlying analysis. A separate report on the

implementation of the Energy Labelling Regulation (Regulation (EU) 2017/1369) is

adopted in parallel to the present report.

1.4. Analytical basis

This report builds on several sources of data and input including:

• a survey of consumers and tyre and vehicle dealers (7);

• EPREL data for tyre registrations;

(6) https://eprel.ec.europa.eu/.

(7) Study on consumer understanding of the EU tyre label applied since 1 May 2021.

3

• input from stakeholders and authorities, including via the work of various

working groups including the Administrative Cooperation Group (AdCo) for tyre

labelling (8) and the Expert Group on laboratory alignment for the measurement of

tyre rolling resistance (9);

• the Information and Communication System for Market Surveillance (ICSMS) (10);

• other publicly available analyses and resources.

2. THE REDESIGNED TYRE LABEL

A 2018 review study (11) found that the tyre label had not reached its full potential because

end users were not well aware of its existence and it was not being adequately enforced by

the MSAs. The study also found that some intrinsic factors were hindering the success of

the label, such as a misleading performance class subdivision, inaccurate and incomplete

information and lack of trust in what some respondents considered a self-declaration.

Figure 1. Illustration of the original tyre label (2012) and the revised (new) label (2021).

The updated tyre labelling legislation has applied since 1 May 2021. Figure 1 compares

the original and the revised label. The new label includes several new features:

• Rolling resistance. The lowest classes were rescaled to become D and E. This

eliminated the empty D class for C1 and C2 tyres (12). The same value range was

kept for each tyre type;

• Wet grip. Label classes were rescaled, and the empty D class was eliminated.

Blue shaded arrows were added to the wet grip scale (recalling water), to

distinguish safety aspects from energy.

(8) List of administrative cooperation groups.

(9) https://ec.europa.eu/transparency/expert-groups-register/screen/expert-

groups/consult?lang=en&groupID=2519.

(10) ICSMS.

(11) https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1460-Evaluation-and-

potential-revision-of-the-EU-tyre-labelling-scheme_en.

(12) No empty class had been set for C3 tyres that, anyhow, had no obligation to bear a label sticker.

4

• External rolling noise. The class indication was aligned with other energy labels

using a letter scale. The sound level was expressed in decibels (as for other

labelled products) and a pictogram with soundwaves was retained.

• Two new pictograms were added, for tyres type-approved for use in severe snow

and severe ice conditions (13).

3. CONSUMER AWARENESS, USE AND UNDERSTANDING OF THE TYRE LABEL

Consumer understanding of the tyre label was tested through a consumer survey. The main

findings are summarised below:

Figure 2. Consumers self-reported understanding of the tyre label elements (baseline = all

respondents (n=4 590).

As Figure 2 shows, most consumers find the tyre label easy to understand. Only 9 to 18%

report difficulty with any specific element. A large majority, consider all current label

elements relevant, particularly wet grip (94%). The majority (78%) felt that the amount of

information present on the label is appropriate. Other parameters not currently featured on

the label, such as mileage, were rated as equally or more relevant. Noise and microplastic

release are viewed as less important or not influencing consumers’ choice (14).

The survey confirmed the results of a 2019 study (15) and found that the label played a

meaningful role in guiding the consumers and professional buyers who checked it. About

80% of both groups stated the label helped them select more efficient or safer tyres.

Tyre dealers and distributors are familiar with the label and generally view it positively.

This does not consistently translate into proactive use during sales. Half the interviewed

salespeople say that they only discuss the label if the consumer prompts them to do so.

One in six discourages customers from relying on the label, pointing out that it is only

based on a self-declaration; instead, they base their recommendations on profit margins,

discounts, incentives, stock availability or customers’ budget.

(13) No class rating is indicated for snow and ice grip, as the testing method (braking on a snowy or icy path)

does not provide sufficiently accurate and repeatable results.

(14) This not surprising, confirming that the purchase choice is influenced by aspects that can be translated

into money savings or increased safety.

(15) Study assessing consumer understanding of tyre labels, https://data.europa.eu/doi/10.2833/210444.

BRAND Size

TYPE Class Size

5

Figure 3. Tyre dealers’ and distributors’ perception of the tyre label (baseline = all respondents

(n=201).

About half of vehicle dealers see little value in including tyre labels for all available

options in vehicle purchase offers, due to low customer interest at the time of sale or

because the customer does not have the option to make a selection (16). Consequently, these

dealers consider the current requirements disproportionately burdensome and suggest that

a smaller or simplified version of the label should be allowed for use in purchase offers (17).

The EPREL website is recognised as a valuable source of additional information by the

consumers, professional buyers, dealers and distributors familiar with it, although actual

usage appears limited. However, information on some important parameters is currently

missing in the database (18). Some dealers noted that EPREL simplifies their work, as it

reduces their reliance on suppliers for information. Some dealers have integrated APIs to

link their websites directly to EPREL, enabling automatic display of tyre labels and product

information sheets in the correct language.

4. MARKET EVOLUTION

Technological progress has enabled simultaneous improvements in rolling resistance and

wet grip, while UNECE parallel legislation has banned tyres that would have been in

rolling resistance classes F and G. This trend is continuing and, particularly for C1 tyres,

UNECE requirements will not allow any new tyre in class E and most of D class to be

placed on the market. As a result, the current scale offers less differentiation for purchase

choices and a weaker competitive incentive for manufacturers to innovate. Similarly, for

noise, all tyres, already since before the Regulation entered into force, have been in classes

A and B.

The TLR requires suppliers to register tyres in EPREL before placing them on the market.

By 2025 EPREL had listed almost 230 000 tyre types: 81% C1, 10% C2 and 9% C3. The

parameters of those registrations are presented below.

(16) With the exception of luxury cars or diplomatic sales, the tyres mounted on the car depend on the tyre

batch available when the vehicle is assembled at the factory. Some car retailers may agree to exchange

the wheels, if possible and as an exceptional courtesy to the customer.

(17) E.g. just an indication with a class arrow.

(18) E.g. currently for C1 tyres, it is not mandatory to indicate which, among the registered tyres, is fabricated

according to the vehicle OEM specifications, or, for C3 tyres, which are for the drive, steering or free-

rolling axle, or which are for urban or long haul use etc.

30%

31%

35%

39%

46%

40%

18%

12%

16%

8%

7%

7%

1…

1%

0%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

The tyre label provides reliable information about key tyre characteristics.

The tyre label provides accurate information about key tyre characteristics

The tyre label provides easy-to-understand information about key tyre characteristics

Strongly agree Agree Neither agree nor disagree Disagree Strongly disagree Don't know

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4.1. C1 tyres

4.1.1. Rolling resistance

Figure 2 shows the estimated C1 tyre average rolling resistance, based on label classes and

date of placing on the market (19). The dashed line shows the extrapolated business-as-usual

(BaU) case to 2024 based on the models registered in EPREL from 2015 through 2021,

with modest progress for new tyre types placed on the market.

Figure 4. C1 tyre rolling resistance.

The average rolling resistance of new tyres placed on the market since 2021 appears to

have dramatically improved (20). It is estimated that there has been a 5.1% reduction in C1

tyre rolling resistance since 2021 compared to BaU.

(19) Unlike all other product labelling regulations, the TLR does not require the real value of the parameter

determining the class for rolling resistance and wet grip, but only for the noise.

(20) Weighted percentage values for the mid-point label class are used because the Regulation does not

require suppliers to enter the rolling resistance coefficient in EPREL, only the class associated with it.

8,4 8,5 8,6 8,7 8,8 8,9 9,0 9,1 9,2 9,3 9,4

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Ro lli

ng R

es is

ta nc

e (N

/k N

)

new tyre label takes effect

7

4.1.2. Wet grip

Figure 5 shows the estimated average C1 tyre wet grip. Although less pronounced, wet

grip performance also appears to have improved compared to BaU for tyres placed on the

market after 2021 (21).

Figure 5. C1 tyre wet grip.

It is estimated that there has been about a 2.4% improvement in wet grip performance

compared to BaU. This results in shorter braking distances on a wet road.

(21) Based on weighted percentages of the mid-point label class, because suppliers are not required to enter

the wet grip index in EPREL, only the class associated with it.

1,30

1,32

1,34

1,36

1,38

1,40

1,42

1,44

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

W et

G rip

In de

x (G

)

new tyre label takes effect

1,30

1,32

1,34

1,36

1,38

1,40

1,42

1,44

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

W et

G rip

In de

x (G

)

new tyre label takes effect

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4.1.3. External rolling noise

Figure 6 shows the estimated average external noise, based on the declared value. Noise

has increased slightly only until 2018, possibly as a result of the trade-off with wet grip

(which improved significantly), and of a trend towards larger aspect ratio tyres in new car

models. There is no discernible divergence from BaU.

Figure 6. C1 tyre external rolling noise.

4.2. C2 and C3 tyres

Similar trends to those for C1 tyres were found for C2 and C3 tyres. For C3 tyres, an

improvement in rolling resistance of about 7.3% was found compared to BaU. Other

factors may have contributed to the progress shown by the EPREL data. Increased focus

on safety and the wider share of electric vehicles on the roads may have stimulated

improvements in rolling resistance (22).

Although rolling resistance, wet grip and noise are conversely interrelated parameters, it is

possible to improve all three simultaneously. In 2025, several manufacturers offered tyres

with A-class for all three parameters.

Share of new models: 5 - 10% > 10%

C1 Rolling Resistance

2015 A B C D E

W et

G

rip

A 0.0% 0.5% 2.0% 2.3% 0.0% 4.8%

(22) For trucks, the formula for calculation of fleet CO2 emissions according to EURO IV legislation includes

the rolling resistance coefficient of original equipment tyres (in diesel trucks tyre rolling resistance

contributes 30 to 40% of energy use). In electric trucks the share is higher because of the high electric

motor efficiency, keeping the energy efficiency focus unchanged.

69,00

69,50

70,00

70,50

71,00

71,50

72,00

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Ro lli

ng N

oi se

- D

ec ib

el A

ve ra

ge (d

B)

new tyre label takes effect

9

B 0.0% 1.9% 19.8% 11.6% 0.7% 34.0%

C 0.0% 0.5% 21.0% 22.5% 2.5% 46.6%

D 0.0% 0.1% 2.6% 9.6% 0.7% 12.9%

E 0.0% 0.0% 0.2% 0.8% 0.7% 1.7%

0.0% 3.0% 45.7% 46.7% 4.6%

C1 Rolling Resistance

2020 A B C D E

W et

G rip

A 0.7% 1.7% 7.5% 2.9% 0.0% 12.8%

B 1.4% 2.4% 18.9% 16.4% 0.9% 40.0%

C 0.1% 0.7% 11.2% 23.6% 0.5% 36.1%

D 0.0% 0.2% 1.4% 6.6% 0.5% 8.7%

E 0.0% 0.3% 0.7% 0.3% 1.2% 2.4%

2.2% 5.3% 39.6% 49.8% 3.2%

C1 Rolling Resistance

2024 A B C D E

W et

G rip

A 1.1% 5.1% 9.5% 3.6% 0.0% 19.4%

B 2.2% 6.6% 24.9% 7.7% 0.6% 42.1%

C 0.3% 1.3% 17.6% 7.5% 0.4% 27.2%

D 0.2% 0.6% 3.7% 4.9% 0.5% 9.9%

E 0.0% 0.1% 1.1% 0.1% 0.1% 1.4%

3.9% 13.8% 56.8% 23.9% 1.6%

Figure 7. Evolution of C1 tyre rolling resistance and wet grip.

Figure 7 illustrates how rolling resistance and wet grip have evolved over the last decade.

The tables depict the relative proportion of tyre models in 2015, 2020 and 2024 in each

combination of the parameters.

Over this period, the models placed on the market shift toward the upper left corner,

simultaneously improving rolling resistance and wet grip. The largest segment moves from

a combination of D for rolling resistance and C for wet grip in 2015 and 2020 to C and B,

respectively, in 2024.

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5. DELEGATED ACTS

Article 13 of the TLR empowers the Commission to adopt delegated acts to:

• introduce new information requirements for retreaded tyres;

• include parameters or information requirements for tyre abrasion and mileage;

• adapt other aspects to technological progress.

5.1. Retreaded tyres

Retreaded tyres are worn tyres that are remanufactured with a new tread replacing the worn

one to give them a second or even third life. Retreading results in a reduction in materials

and energy used, and related GHG emissions, close to two thirds. In 2022, three industry

organisations, ETRMA, ETRTO, and BIPAVER, submitted a proposal to the

Commission (23) to label retreaded C3 tyres. The Commission conducted a preliminary

technical study and started to prepare the analytical basis for a proposal. Stakeholders have

been consulted, and work is ongoing.

5.2. Abrasion and mileage

As mentioned in chapter 3, and resulting from two consumer surveys in multiple countries,

an indicator of potential useful service life (or ‘mileage’) of tyres would boost customers

interest in the tyre label: together with rolling resistance, it is an indicator of economic

savings, potentially compensating a higher upfront purchase cost of replacement tyres. No

suitable test method for measuring tyre abrasion and mileage was available until recently,

thus the Commission have been unable to take action for introducing information

requirements (as from Article 13.3).

Work is in progress, in the specially constituted UNECE Tyre Abrasion Task Force (TF-

TA) (24) to set abrasion testing methods for C1, C2 and C3 tyres. The C1 UNECE abrasion

test (25) includes two methodologies: an on-road vehicle convoy method, conducted under

limited weather and climatic conditions, and an in-door drum method (26). The former test

covers 8 000 km on open public roads (27). Work for C2 and C3 tyres is ongoing, and

conclusions are expected in 2027 for C2 tyres but later for C3 tyres.

The Commission has urged TA-TF to develop a metric linked to tyre wear to assess

mileage potential (28) as the activity has focused, so far, solely on setting abrasion minimum

requirements. In the meantime, a threshold limit for C1 tyres has been set in the Euro 7

Regulation.

(23) The same method would be used as for new tyres.

(24) https://wiki.unece.org/pages/viewpage.action?pageId=160694352.

(25) GRBP 83, (WP.29/GRBP) Working Party on Noise and Tyres (83rd session) | UNECE, is a subsidiary

body of the World Forum for Harmonisation of Vehicle Regulations.

(26) The quicker, more repeatable and less polluting in-door method, similar to the tests used for measuring

rolling resistance, saves months to tyre manufacturers introducing new tyre types.

(27) 25% urban, 25% regional roads and 35% highways, at three temperature levels, between 5 °C and 25 °C.

The convoy-based test poses repeatability and affordability challenges for MSAs.

(28) UNECE Regulation 117 will be amended to include the abrasion thresholds. Data on abrasion levels and

tread loss, thus, becomes part of the type-approval documentation. If the declaration by tyre

manufacturers, via the type-approval documentation on testing results for abrasion would also include

the tread depth loss, rating mileage may become feasible.

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Table 1. Schedule for mandatory abrasion thresholds according to Euro 7 (Regulation (EU)

2024/1257).

Applicable Requirement C1 Tyres C2 Tyres C3 Tyres

New tyre models from: 1 July 2028 1 April 2030 1 April 2032

All tyre models from: 1 July 2030 1 April 2032 1 April 2034

Non-compliant models in market

until:

30 June 2032 31 March 2034 31 March 2036

5.3. Other aspects

The labelling of retreaded tyres would require amending multiple TLR annexes. In

addition, the TLR also lacks clarity or detailed requirements for some respects (nested

labels, public parameters, compliance documentation). This is source of uncertainty for

suppliers and both tyres and vehicle dealers and complicates compliance (29). Alignment

with the legislation on labelled energy-related products, would solve most of the problems.

6. MARKET SURVEILLANCE AND ENFORCEMENT

Regulation (EC) No 765/2008 (30) sets out the procedure for compliance verification by

national market surveillance authorities (MSAs) for tyre labelling and for cross-border

market surveillance. Regulation (EU) 2019/1020 (31) on market surveillance and

compliance of products amended Regulation (EC) No 765/2008, extending its scope and

aligning definitions and accreditation rules for testing facilities.

In addition, the TLR creates certain obligations for suppliers (manufacturers, importers

and authorised representatives) and dealers or distributors, including the obligation to

cooperate with MSAs and take immediate action in case of non-compliance. Specific

requirements are set for internet hosting service providers.

Tyres are complex, safety-critical products. Assessing tyre quality and compliance requires

specific skills and expertise. To verify performance, MSAs need specialised, costly

equipment and dedicated test grounds or tracks.

Most performance and compliance testing by MSAs is currently done on appliances

(fridges, washing machines, light bulbs), and very few have specific expertise and

experience on tyres. In many countries, few human and financial resources are allocated

to compliance control, so most perform only controls on formal aspects. Moreover, in

about half of Member States, labelling and type-approval competences are split between

(29) No small-format label is available for use in tyre catalogues, where about 20 rows on each page describe

each tyre, or for vehicle offers, where the tyre labels take 10 times the space used for the vehicle

description and its options. The lack of indication on which parameters needed to distinguish tyres of

the same size are to be entered in EPREL hinders the application of the taxonomy or any DNSH criteria.

(30) Regulation (EC) No 765/2008 setting out the requirements for accreditation and market surveillance

relating to the marketing of products.

(31) Regulation (EU) 2019/1020 on market surveillance and compliance of products.

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different authorities, with little or no coordination between them, even though the testing

equipment and procedures used are the same.

Several Member States do conduct controls, and these show high non-compliance rates.

Ireland reported results for 36 tyre models in ICSMS (32); it found that only 33% were

compliant in 2024 and 51% in 2025. Germany reported results for 60 tyre models tested;

it found that 37% were compliant in 2023 and 58% in 2024. National MSAs generally

conduct market surveillance using a risk-based approach, meaning that the non-compliance

rates found are not necessarily representative of market averages. Data from tests

performed by the JRC, however, also show very high non-compliance figures. As regards

tyres entering the EU market, customs controls at the EU external borders remained limited

and, accordingly, the discovery of non-compliance cases low.

Under the TLR, Member States are obliged to lay down rules on effective, proportionate

and dissuasive penalties, as well as establish enforcement mechanisms for infringements

of the Regulation, and notify the Commission, by 1 May 2021, of those rules. The list of

penalties notified has been published in the Energy Efficient Products portal (33).

6.1. Type approval vs tyre labelling

Type approval is not performed on every tyre model but only at the level of ‘tyre family’

and using the ‘worst-case’ scenario, for each of the regulated parameters. For example, for

rolling resistance, among the tyres with the same tread pattern but different aspect ratios,

the one with the lowest load index and largest aspect ratio is considered as the worst-case

representative tyre. This means that out of 10 or 20 tyres in the same family and with the

same tread design, only one is tested for rolling resistance, another for wet grip and

possibly another for noise.

For tyre labelling, every single member of a tyre family is in principle tested, using the

same testing method.

This means that compliance control and verification of the class claimed on the label,

unless the same as the worst case is indicated, needs a specific testing on the specific tyre

and cannot rely on the test results of the type approval for the whole family.

6.2. EU support to MSAs

The Energy Efficiency Compliant Products 4 (EEPLIANT4) is an EU co-funded

Concerted Action under the LIFE programme, the EU’s funding instrument for the

environment and climate action. EEPLIANT4 includes a tyres work package under which

TLR compliance checks will be carried out. Only four MSAs are participating: Cyprus,

Estonia, the Netherlands, and Portugal, coordinated by PROSAFE (34).

(32) Information and Communication System on Market Surveillance.

(33) https://energy-efficient-products.ec.europa.eu/national-measures-penalties-and-sanctions-tyres_en.

(34) https://prosafe.org/, an MSA coordination consortium.

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Project Programme Running time EU contribution

MSTyr15 European Commission’s Horizon 2020 2016-2019 €1 854 673

EEPLIANT4 LIFE 2024-2029 €7 999 999

Table 3. EU support for the implementation of the Tyre Labelling Regulation and related market

surveillance

The Commission also supports MSA activities through:

• bi-annual meetings and support to MSAs through the Administrative Cooperation

(AdCo) Expert Group on Tyres Labelling - Market Surveillance Administrative

Cooperation;

• the European Product Compliance Network under the Market Surveillance

Regulation (MSR);

• integration between EPREL and ICSMS;

• a ‘safeguard clause’ feature in ICSMS, allowing MSAs to share information on

products presenting a risk.

Article 34(4) of the MSR obliges Member States to report in-depth checks on compliance.

By autumn 2025, the ICSMS database listed 230 in-depth TLR inspections. Figure 8 shows

the results by Member State. Member States not appearing in the table did not report any

checks in ICSMS.

Out of the TLR checks reported, 5 found tyres posing a serious risk and 16 a high risk.

Correction measures included warnings (14), orders to withdraw the model from the

market (2) and a ban (2). Other measures included changes in EPREL (1) and a change to

the label (1). Often the correction measure is not reported.

2020 2021 2022 2023 2024 2025

Spain 30% 84% 68%

Germany 90% 93% 37% 58%

Ireland 33% 51%

Luxembourg 100%

Croatia 100%

European Union 50%

Portugal 0% 100% 0%

Denmark 0%

Figure 8. Overview of TLRcompliance testing, ICSMS. ‘European Union’ refers to the reports by

Commission JRC. High percentage (green shading) means models were found to be compliant.

6.3. Commission role in market surveillance

Tyre testing is technically demanding and appears not to be a priority for Member States.

Insufficient compliance information in EPREL, a large number of models, high testing

costs (€1 k to €10 k per unit), difficulty to build expertise, lack of laboratory capacity,

different distribution of responsibilities between national bodies in Member States and lack

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of coordination contribute to insufficient control, high non-compliance rates and – possibly

relatedly - distrust by customers and distributors (see the survey findings about perceptions

of tyre labels as unreliable due to being based on self-declaration). Figure 1 shows the

surprising rates of non-compliance for the tyres tested by JRC in the years 2021-2024.

Figure 9: Non-compliance findings by JRC between 2021-2024 (presentation to AdCo meeting,

1 April 2025, Ispra).

Stronger involvement by the Commission would be beneficial. Such a strategy is being

implemented for vehicle safety since 2020. Here, while Member States play a central role

and conduct surveillance testing, the Commission provides a second layer of control and

performs independent tests. The Commission is empowered (35) to test vehicles and their

parts, impose administrative fines directly on manufacturers and order EU-wide recalls (36).

Tyre type approval is within the scope of the Commission’s competence, but tyre labelling

falls outside it. Currently, EU-level testing campaigns are organised to assess compliance

of tyres sold on the EU market, complementing national controls and filling gaps where

national capacities may be limited (37). A centralised, coordinated approach, also covering

labelling, would create synergies and guarantee impartiality, without conflict of interest

(38). Furthermore, the additional cost of labelling compliance checks would be minimal, as

they are based on the same tests required by UNECE Regulation 117.

7. POSSIBLE THIRD-PARTY VERIFICATION AND TESTING

The Commission has sought to assess the costs and benefits of mandatory independent

third-party verification of the information provided in the tyre label, taking into account

the experience gained with the broader framework provided by Regulation (EC)

No 661/2009.

Third-party verification can help compensate MSA deficiencies in budget, labs, staff,

coordination and necessary skills. Using third parties could ensure access to state-of-the-

art laboratory equipment and specialised staff. Several labs have already gained experience

in the broader type-approval framework provided by Regulation (EU) 2019/2144 and are

also already accredited to conduct all TLR testing activities. However, third-party testing

(35) Article 9 of Regulation (EU) 2018/858.

(36) A report of activity is available from https://publications.jrc.ec.europa.eu/repository/handle/JRC130606.

(37) A report describing the activities carried out by the JRC on tyres are available at the following link:

https://publications.jrc.ec.europa.eu/repository/handle/JRC135546.

(38) National authorities may be reluctant to enforce compliance/penalties on manufacturers established in

their territory.

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and certification fees can be significant. Table shows indicative prices for testing for C1

tyre TLR parameters in laboratories accredited for tyre type-approval legislation.

Table 4. C1 tyre third-party verification testing costs (per tyre)

Test Procedure – Tyre Class C1- From To

ECE 117 R. Annex 3 – Noise €1 100 €2 000

ECE 117 R. Annex 5 - Wet Grip €950 €1 500

ECE 117 R. Annex 6 (CR) – Rolling Resistance €650 €1 250

ECE 117 R. Annex 7 3PMSF - Snow Performance €3 200 €5 500

Total for the test procedure: €5 900 €10 250

Two options exist to mitigate these high third-party verification costs.

(i) Random ex post testing, paid for by the public sector. This only appears feasible if

coordinated at EU level.

(ii) Systematic mandatory ex ante verification by suppliers, for all declared parameter

values in the label if they exceed the class equivalent to the ‘worst-case’ as

documented in type approval certificates (39). This would simply involve disclosure

of the test reports that manufacturers are supposed to perform in order to claim a

class better than the ‘worst-case’ as documented in the type-approval certificates

and which must be uploaded to EPREL.

8. TEST MACHINE ALIGNMENT

The rolling resistance coefficient (RRC) used to assess the energy efficiency class of a tyre

is measured in a laboratory using a specific machine. Major manufacturers carry out their

own RRC testing. Some independent test laboratories also have their own machines.

Regular calibration, or realignment, of machines is needed to ensure repeatable, consistent

measurements. Some non-EU countries rely on a central body to provide this calibration

service (40). There is no such EU central body. Instead, a ‘virtual reference machine’ and a

procedure have been put in place, described in Annex V to the TLR. Every two years, a

pool of 11 participating laboratories perform a resource-intense ‘round-robin’ process to

align their machines and provide a reference (41).

The Commission could develop an alternative to this periodical and burdensome

calibration exercise of the pool of different laboratories by establishing a single physical

reference laboratory one, possibly with a second row of independent laboratories providing

the service to manufacturers worldwide. The cost of such a laboratory could be covered

through fees for calibration services. It should be noted that the machines used for RRC

testing are the same as those used for type approval. Using the same machines ensures that

the labelling measurements are better aligned with the type-approval measurements and

(39) Type approval is at ‘product family’ level, while tyre labelling is at tyre-type level (each family

member).

(40) e.g. USA, Korea and Japan.

(41) The list of laboratories is published in Commission communication 2012/C 86/03. An update is due in

2026.

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reduces double testing.

9. ISSUES IDENTIFIED AS PART OF IMPLEMENTATION

Some issues related to the TLR have been identified during implementation, most of which

could be addressed by amending TLR annexes. The most pertinent ones, along with

possible solutions, are outlined below.

9.1. Promotional material, catalogues, vehicle offers

The TLR provides no detail on the format, size and modalities for the display of labels in

catalogues, online stores or promotional material or vehicle offers. The only stipulation is

that the size should be no smaller than 75x100 mm. This lack of detail has led to legal

uncertainty on the one hand and to widespread non-conformity on the other. One practical

solution, which other energy label delegated acts have provided for in a specific annex, is

the option to use a simplified, small-format label, in the form of a ‘class arrow with range’,

possibly combined with a ‘nested display mechanism’ for online pages. Figure 10 provides

an example of how such an indication might be used for tyres.

Figure 10. Examples of class arrows as an alternative to displaying the full label (in catalogues,

lists, vehicle offers on paper or associated with the ‘nested label mechanism in online sales’).

9.2. Insufficient parameters in EPREL to select tyres

Annex III to the TLR lists the data to be uploaded in EPREL: the description is very

generic, and some crucial parameters are not mentioned, thus making the publicly available

information insufficient for important real-use scenarios (42). Most of the missing parameter

values may be provided in EPREL but on a voluntary basis. This limits the usability of

EPREL for determining for determining choices, e.g. by fleet managers of the freight

transport sector (43) or, again, selection by vehicle manufacturers for original equipment

choice (44). Mandatory registration of all parameters relevant for the purchase choice would

enable such choices by customers and better exploit the label savings potential, by making

full use of digitalisation and EPREL. Moreover, identifying tyres meeting the EU

taxonomy criteria is not intuitive. A dedicated filter function may remedy this situation.

9.3. Insufficient information to perform compliance checks

Annex VI to the TLR lists the information for the compliance part of EPREL. The list is

generic and in practice constitutes a barrier to effective compliance control, particularly in

those countries where responsibility for type approval and tyre labelling is separated.

Aligning the format of parameters to be provided in EPREL for tyre labelling with that

used for energy labelling would address this issue. The lack of clarity also leads to

(42) For example, truck tyres tread design differs depending on whether the tyres are to be mounted, i.e. on

steering, traction or free-rolling axle (the casing is the same, overall performance may differ

significantly).

(43) Selection of tyres considering “axle position” or “mission profile” is crucial, as related to tread and

casing design and, consequently, to rolling resistance, noise or grip performance.

(44) Although each manufacturer launches a ‘tendering’ mechanism, the vehicle industry has clearly

expressed interest in having a complete market overview, for better tuning requirements.

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diverging interpretations and a considerable burden on MSAs, which have to request

documentation from the supplier, instead of finding it in EPREL. As every single member

of a tyre family must in principle be tested unless the class indicated on the label

corresponds to the ‘worst case’, the availability of test reports would make it possible to

simplify the compliance control activity, reducing costs and the administrative burden on

Member States.

9.4. Limited separation in performance classes

Tyre performance thresholds are set in the UNECE regulations. These are periodically

reviewed and updated. Generally, the updated requirements apply first to new tyre types,

type-approved after entry into force of the limits, and later to existing types.

Technological progress has permitted more stringent requirements to be set in type-

approval legislation, which has banned tyres belonging to the worst classes. However, the

TLR revision did not include any rescaling or adjustment of classes. As a result, all tyres

now fit in only three or four rolling resistance and wet grip classes. This reduced range

decreases customer interest in the tyre label and reduces the supplier’s incentive to

innovate in order to differentiate their products from those of their competitors. Pending a

future rescaling, this issue might be mitigated by requiring suppliers to enter in the public

part of EPREL the RRC and the wet grip index (WGI) measured or estimated to rate the

class, as is already required for noise (45), allowing professional buyers and other interested

users to differentiate among products within a class using EPREL.

10. CONCLUSION

The revised TLR has driven measurable improvements in tyre performance, notably a 5.1%

reduction in rolling resistance and 2.4% improvement in wet grip for C1 tyres since 2021,

compared to business-as-usual trends. Similar trends were found for C2 and C3 tyres. For

the latter, the improvement in rolling resistance has been even 7.3%. The market has thus

shifted towards higher-performing tyres, with more models now available that achieve top

(A) ratings across all parameters.

However, consumer awareness of and trust in the label remain limited, partly due to

inconsistent enforcement and reliance on self-declaration. Market surveillance appeared

not a priority for Member States, it requires specialised expertise and tools, is difficult to

carry out and, when performed, reveals high non-compliance rates. This highlights the

need to strengthen coordination, resources and expertise at both national and EU levels.

While third-party verification and testing could mitigate some of the current shortcomings

in market surveillance, this would come at significant cost. The current test machine

alignment exercise is cumbersome and the biannual exercise burdensome: a single

reference laboratory, possibly managed by Commission (JRC), may simplify the process

and ensure increased stability, with costs recovered by directly providing alignment

services. The machines could be used for testing for both the labelling and R.117

compliance.

EPREL is a valuable tool, but the lack of mandatory requirements to fill in relevant data

fields limits its usability for consumers, fleet managers and procurers. Meanwhile, progress

(45) Such RRC and WGI values are in any case already entered in EPREL, but only for the technical

documentation and only by some suppliers.

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on abrasion and mileage labelling is delayed by the absence of standardised test methods,

though ongoing work at UNECE may yield solutions by 2027.

Finally, the TLR implementation has revealed additional shortcomings, including the lack

of a ‘nested’ label mechanism definition. Crowding of tyre models in the best 3 classes,

for rolling resistance and in particular for wet grip and in 2 performance classes for noise

emissions undermines customer interest in the tyre label.

The modifications in the omnibus proposal presented in parallel to this report aim to better

address some of the different shortcomings whilst also simplifying compliance respect

where possible, for suppliers and retailers. At the same time, certain issues (such as those

linked to mileage, abrasion, re-treading, testing machine alignment and testing for

compliance verification) can only be tackled when additional preparatory work has

progressed.