Tyre Labelling Legislation Changes - What are your obligations?
UPDATED: 12/04/2021.
As most of CAM’s customers will know, changes to tyre labelling legislation and suppliers’ obligations to the consumer are imminent.
For European Union members the new regulation EU REG 2020/740 will come into force on Saturday 1st of May 2021 and will also apply to Northern Ireland (bound by the Northern Ireland Protocol).
The political landscape has evolved significantly. Britain has left the European Union, the Northern Ireland Protocol came into effect on 31st December 2020 and the UK is no longer bound by European law.
As the leading software and app supplier to the UK’s tyre industry, CAM have been in consultation with the industry for around 6 months. We’ve been working hard to help our customers be compliant with their tyre labelling obligations. In this article we’ll gather the facts and clarify:
What are your companies’ obligations as a tyre supplier? What is different in GB & NI? And how are CAM preparing to help you meet your legal obligations?
Tyre Labelling Changes in 2021
Q: What changes for tyres sold in Great Britain from the 1st May 2021?
The short answer is nothing!
The new EU legislation does not apply to retailers in Great Britain, who remain subject to GB REG 1222/2009.
The Department for Transport have confirmed that new “GB equivalent” to the EU REG 2020/740 tyre label regulations is planned but there are – as yet - no confirmed timescales.
However all new manufactured tyres will be supplied with the new EU Tyre label as per EU REG 2020/740.
In simple terms, both tyre labels are in active use and retailers - and their customers – will be seeing both for some time.
GB Retailers continue to be subject to their tyre labelling obligations as per the regulation GB REG 1222/2009.
The DfT have confirmed that “the DVSA market Surveillance Unit will continue to oversee that consumers have the necessary information to choose the best products for their intended use in line with the intention of the regulations.”
Q: What changes for tyres sold in Northern Ireland from the 1st May 2021?
The Northern Ireland Protocol means EU regulations apply and therefore tyres sold in Northern Ireland must comply with the new EU tyre labelling obligations as per EU REG 2020/740.
All new manufactured tyres will be supplied with the new EU Tyre label.
Tyres already in retailers’ stock can retain their ‘old’ tyre label (sticker).
Tyres working their way through the supply chain can also retain their ‘old’ tyre label (sticker).
Some tyres may never be updated to an EU label. (The requirement to apply the new regulation is based on the date a tyre is produced and when it was first made available for sale in EU).
In simple terms, both tyre labels will be in operation for some time.
Retailers are subject to the new tyre labelling obligations as per EU REG 2020/740 – read on to find out about the practical differences.
Q: You previously mentioned an interim label?
As the leading software and app supplier to the UK’s tyre industry, CAM have been in consultation with industry associations and them in turn with the Department for Transport. All parties agree that presenting consumers with 2 different labels, each using different classes will not help consumers make informed choices.
An “interim label” has been proposed to bridge the gap. It is suggested that this temporary label should be presented digitally to the consumer and should reclassify tyre data from the old 1222/2009 classes to the new EU 2020/740 classes.
Critically though, there is nothing in current EU or GB law to oblige the use of the interim label.
The new EU REG 2020/740 Tyre Label (for EU & NI Tyre Retailers)
Q. Why are new tyre labels being introduced in the EU?
The EU has committed to cut its greenhouse gas emissions to reach climate neutrality by 2050. Reducing CO2 emissions from road transport is a significant part of the strategy and helping consumers choose more fuel-efficient tyres will reduce transport emissions. The new, updated tyre labels are designed to help drivers make informed choices about tyres’ fuel efficiency.
Q: What does the new EU REG 2020/740 label look like?
Q: What vehicles does EU REG 2020/740 relate to?
The new EU regulation applies to C1 (Car & SUV), C2 (Van & Light Trucks ) and C3 (Truck) tyres.
Q: What changes have been made to grading systems on the new EU REG 2020/740 tyre label?
It includes new and revised grading systems:
Revised: Rolling Resistance classes
Revised: Wet Grip classes
Revised: Fuel efficiency classes (‘A to E’ only, removing classes F & G)
New: Noise classification (A, B & C)
Q: What are the ‘pictures’ on EU REG 2020/740 tyre label?
New performance pictograms:
New: Snow Grip Pictogram (a 3 peaks mountain snowflake symbol is shown when tyres are suitable for severe snow conditions)
New: Ice Grip Pictogram (Shown when tyres are suitable for ice conditions - unlikely to be popular/relevant to tyres in the UK & Ireland)
Q: What else does the new EU REG 2020/740 tyre label include?
A new QR code allows customers to link to the new European EPREL database of EU Commission approved Tyres.
Q: Is EU REG 2020/740 more than just a new tyre label?
Yes. There is also a new requirement to offer customers a Tyre Product Information sheet in hard copy (print) & via the EPREL website. More details in the FAQs below.
Q: Where can I explore the details of EU REG 2020/740 in more detail?
Practical Changes EU & NI Tyre Distributors Need to Make
Article 6 of EU REG 2020/740 updates EU & NI tyre distributors’ obligations when supplying tyres to consumers. Read on to find out more about the legislation and the practical changes that are required.
Q: What does article 6 of EU REG 2020/740 cover?
Article 6 sets out all of the “obligations of tyre distributors” to share tyre performance information with consumers as they research and purchase tyres. It details what and how this information should be shared, whether customers walk-in, phone to enquire or purchase online etc. Read article 6 of EU REG 2020/740.
Q: Are tyre distributors’ obligations different to those in the previous REG 1222/2009?
Yes. There are new obligations and some significant updates. One obligation is also removed. There is no requirement to include tyre measurements (or the tyre label) on invoices under the new EU 2020/740.
Q: Will article 6 of EU REG 2020/740 affect my tyres sales in Northern Ireland?
If you are selling tyres in Northern Ireland, the new obligations under article 6 will apply from 1st May 2021.
Q: In practice what do EU & NI retailers need to do to comply?
For Walk-ins
Where the tyre (& the label) is NOT visible to the customer
Provide or display an electronic copy of the tyre label before the sale takes place.
Where the tyre IS visible to the customer, but it carries the old label (due to remaining stock)
Provide or display an electronic copy of the correct tyre label before the sale takes place.
Also:
Print copies of the tyre’s product information sheet should be available upon request.
Be able to direct the customer to tyre data on the EPREL website.
For Phone Enquiries
Where prices are discussed
Inform the customer about the classes for each of the parameters on the new tyre label.
Also:
Print copies of the tyre’s product information sheet should be available upon request.
Be able to direct the customer to tyre data on the EPREL website.
For Internet Sales
Where prices are displayed
Display the new tyre label near the price.
The label must be sized to be clearly legible & proportionate.
In my Direct Marketing
Where you undertake any “paper based distance selling”
Include the relevant tyre label on the document.
Also:
Direct the customer to the EPREL website for further tyre data.
In my Technical promotional materials
That include a tyre’s brand, tyre type identifier and size.
Include the tyre label in the technical promotion materials.
In my Advertising
On adverts for a specific tyre
Include the tyre label in the advert.
On generic tyre brand adverts (typically run by manufacturers, not retailers)
The tyre label is NOT required for generic adverts.
Q: On 1st of May I will have existing stock on my shelves that will still have the old label on?
Existing tyre stock that is already in the supply chain and on retailers’ shelves that has the ‘old’ label, will NOT need to be relabelled (as it is typically not seen by the customer). However, retailers’ digital information that they share with customers must be up to date and using the new labels. This would include on websites, customer facing displays in reception areas etc
Q: But are there any consequences to not complying?
Yes! The Market Surveillance Unit from the Department for Transport recently completed a mystery shopper exercise making tyre enquiries with 68 British tyre retailers. Their findings found 78% of those retailers were not compliant with their legal requirement to provide tyre labelling information.
From 1st January 2021 the Driver and Vehicle Standards Agency (DVSA) have confirmed they will now be enforcing tyre labelling compliance through civil sanctions. Fines of £1000 per non-compliance have been proposed.
On a letter to the BTMA on the 9th March, the DfT have confirmed that “the DVSA market Surveillance Unit will continue to oversee that consumers have the necessary information to choose the best products for their intended use in line with the intention of the regulations.”
How CAM Products can Help your Tyre Business Comply with Your Tyre Labelling Obligations
For stock & price enquiries via the phone – accurate tyre performance data at your fingertips
CAMEO (powered by CAM’s OTC) ensures every tyres’ performance attributes are instantly available. Ideal for telephone enquiries, not only can a member of your team quickly confirm your stock availability and best prices, you can also share each tyres’ fuel consumption, wet grip & noise classification data with your client.
Talking to a client that is looking for optimum wet grip? No problem! Sort your stock view into rank order and share accurate information with your customer.
For customers that are shopping around – quote including tyre performance data, every time
Whether you are emailing or printing a quote, include each tyres’ performance data as standard. Include the complete tyre label or a short data summary; both options ensure your clients are fully informed and that you are fully compliant.
Via your e-commerce website – seamlessly include tyre data & tyre labels with your online shoppers
CAMEO user? Integrate your e-commerce site with CAM’s MIDaS solution and display the tyre label alongside your sale price. You can list every tyres’ fuel efficiency class, wet grip class and external rolling noise class information instantly on your website. There is no need to maintain your tyre data, CAM does that for you.
**This article will be updated as new information becomes available. However it should not, in any way, substitute real legal advice and is for informational purposes only. **