First introduced in 2012, the tyre label provides consumers across Europe with essential information on fuel efficiency, safety and noise by detailing the tyres’ rolling resistance, wet grip, and external rolling noise. By using this common scale, the aim of the EU tyre label is to make it easier for consumers to make an informed choice when buying new tyres. As of the 1st May 2021, the revised tyre label came into effect.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
With the revised tyre label regulation, the label has been reviewed in the design, to be harmonised with the very well-known energy labels that, according to a Eurobarometer poll, has an influence in 79% of European' purchase choices. The new label has now only 5 classes, instead of 7, because tyres that would be in class G and F are not allowed to be placed on the market anymore, in the light of separate type-approval new rules. The new label, finally, also includes additional information for consumers indicating if a tyre is suitable for use in severe snow conditions or in extreme ice conditions and the QR code, leading to the tyre registration in the EPREL database.
You can see how the classes from the old label have been mapped into the new ones in the picture below:
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The new tyre label regulation applies only to new passenger car tyres (C1 tyres), light commercial vehicle tyres (C2 tyres) and heavy vehicle tyres (C3 tyres).
The following categories are currently excluded from the scope of the new regulation: retreaded tyres, off-road tyres, racing tyres, studded tyres, temporary use spare tyres, tyres designed to be fitted on vehicles registered for the first time before 1st October 1990, tyres whose speed rating is less than 80 km/h, tyres whose nominal rim diameter does not exceed 254 mm or is 635 mm or more.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
In UN Global Technical Regulation (UN GTR) No.16, point 3.2.1.3 states that “The DDDD with 4 digits represents the week and year of manufacture, also known as the date code. The first two symbols shall identify the week of the year by using "01" for the first full calendar week in each year, "02" for the second full calendar week, and so on. The calendar week runs from Sunday through the following Saturday. The final week of each year shall include not more than 6 days of the following year. The third and fourth symbols shall identify the year. Example: 0110 means the first week of 2010.”
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
No change and no obligation, in respect to wet grip for worn tyres is currently in discussion for the registration in EPREL or is foreseen in tyre labels.
No change is envisaged at the time of writing this answer (March 2024).
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Article 3(18) refers to the definition of the term in Article 3(2) of the Regulation (EU) 2019/1020 on market surveillance and compliance of products: ‘placing on the market’ means the first making available of a product on the Union market.’
The operation is reserved either for a manufacturer, an authorized representative or an importer established in the Union, i.e. they are the only economic operators who place tyres on the Union market. When supplier provides a tyre to a distributor or an end-user for the first time, the operation is always considered in legal terms as ‘placing on the market’. Any subsequent operation, for instance, from a distributor to another distributor or from a distributor to an end-user is defined as ‘making available’ (see next question).
It is important to underline that first making available is related to individual units of a specific tyre type1 and is associated to registration in EPREL (i.e. from the start of application of a Regulation, the registration has to precede the “placing on the market” and the date indicated in the registrations for this has to be equal or later).
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
According to Article 3(17) of the tyre labelling Regulation in conjunction with Article 3(1) of the Market Surveillance Regulation, ‘making available on the market’ means any supply of a product for distribution, consumption or use on the Union market in the course of a commercial activity, whether in return for payment or free of charge’.
A tyre type is 'first placed on the market' only once by each supplier, but units or batches of tyres may be 'made available' several times throughout the supply chain (first wholesaler, second wholesaler, etc., retailer) before it reaches the end- user (consumer or professional user) or is further mounted into another product.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Article 4 states all obligations of tyre suppliers regarding the provision of labels and product information sheets (PIS).
For some specific elements of the distribution chain, provision of a QR code or of the equivalent humanly readable URL may be useful. However no requirement or provision is explicitly mentioned in the legislation.
Once the tyre type is registered in EPREL and the “date of placing on the market” occurred/passed, anyone can automatically download a PIS from the public part of the database and in any official language of the EU.
The tyre suppliers’ obligation is to accompany individual tyres by a printed label and by a PIS. Making accessible the PIS seems enough. However the specific case in which tyres are sold or offered by distance, the supplier has to provide the end-user with a printed format if requested.
Article 6 states that at the point of sale, distributors have to make the product information sheet available, including, upon request, in printed form. Consequently, the distributor should be able to provide the PIS in a printed form if requested.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes, under some conditions.
The word “accompanied” is used in the Regulation (EU) 2020/740 in Article 4: “Suppliers shall ensure that [..] tyres […] are accompanied free of charge”:
- by a tyre label (in the form of a sticker for individual tyres or by a printed tyre label for a batch of identical tyres) and,
- by a product information sheet (PIS). No clear indication is given as to the format of the PIS.
Article 3(8) defines the ‘product information sheet’ as a standard document containing the information set out in Annex III in printed or electronic form. If the product information sheet can be obtained in electronic form by scanning the QR code on the label (as printed on a physical support), this fulfils the obligation to accompany the tyres by the PIS unless the end customer requests a printed form.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The definition of technical promotional material is given in Article 3(7) of the tyre labelling regulation:
'technical promotional material’ means documentation, in printed or electronic form, that is produced by a supplier to supplement advertising material with the information set out in Annex IV'
Recital 24 provides more details:
'Potential end-users should be provided with information explaining each component of the tyre label and its relevance. That information should be provided in all technical promotional material, for example on suppliers’ websites, but should not be required in visual advertisements. Technical promotional material should not be understood to include advertisements via billboards, newspapers, magazines or radio or television broadcasts'.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Article 4 establishes the obligation to accompany individual tyres (or batches) with a printed label, as from 1 May 2021. Article 5 provides for different registration provisions depending on the date of production/placing on the market.
Yes, it is correct. C1 and C2 tyres produced in the period between 25 June 2020 and 30 April 2021 and placed on the market before 1 May 2021 will be bearing the old label as from Regulation (EU) 1222/2009. No label was required under Regulation (EU) 1222/2009 for C3 tyres. At the latest by 30 November 2021, units of C1 and C2 tyres produced within the mentioned period shall be registered in EPREL.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Units of C1 and C2 tyres produced in the period between 25 June 2020 and 30 April 2021 but placed on the EU market as from 1 December 2021 must be registered before placing them on the market. EPREL registration involves generation of an associated QR code pointing to it on the new label, at the latest by 30 November 2021.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
No. No retrospective registration is required for tyres types whose units will not be placed on the EU market after 1 May 2021.
On this, recital 37 of Regulation (EU) 2020/740 clarifies that no re-labelling of individual tyres is required for those already placed on the market before 1 May 2021 (date of application of Regulation (EU) 2020/740).
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The supplier formally registering the product and necessarily established in the Union (or EEA) is solely responsible for the data entered in the database and remains liable, whoever and wherever the data has been input.
Agreements between the importer or authorised representative and the manufacturer established outside the EU are not regulated in the context of the tyre labelling Regulation (EU) 2020/740 (nor of the Framework Labelling Regulation (EU) 2017/1369).
No operator established outside the EU/EEA shall be regarded as a supplier under Regulation (EU) 2020/740.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Individual units of tyres made available on the Union market have to bear a sticker, or be accompanied by a printed label in the case of batches of identical tyres.
The Regulation refers to an electronic version of the label as a “label in electronic form” and not as “printed on a display” (see definition of ‘tyre label’ in Article 3(5)).
The format of tyre labels (both in printed and electronic form) is set out in Annex II.
Article 13(1)(a) empowers the Commission to adopt delegated acts in order to amend Annex II with regard to the content and format of the tyre label.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes. The QR code leads to the label and the product information sheet as stored in EPREL: they appear on the display of a QR reader, such as a smartphone or a tablet.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Each supplier is responsible for registering tyre types, units of which it places on the market.
Each importer placing on the market tyres of a manufacturer located outside the EU/EEA, is considered as a supplier, independently of the fact that an authorised representative has been designated.
The product registration works as follows:
(a) the first time a supplier makes available a unit of a tyre type on the Union market, it must have already registered all required information in EPREL, as stated in the applicable rules. This is the case even if units of the same tyre type have already been placed on the Union market by another economic operator.
(b) If two separate suppliers place on the market units of the same tyre type, there should be two separate registrations in EPREL. The QR code on the label of each tyre unit unequivocally points to the registration and, thus, to the specific supplier.
In summary: a tyre can be placed on the EU market by any of the following categories of economic operators: EU/EEA manufacturers, authorized representatives and importers in the case of manufacturers not established in the EU/EEA. In case more than one economic actor acts as an importer, each of them is to fulfil the supplier’s obligations in relation to those units of the tyre type they first place on the EU market.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Not always. It depends on whether the individual tyres or batches have been subject to a commercial transaction, or not yet. According to the Blue Guide, the first making available of a product supposes an offer or an agreement (written or verbal) between two or more legal or natural persons for the transfer of ownership, possession or any other right concerning the product in question after the stage of manufacture has taken place.
Being unloaded at a harbor or passing customs is in itself not sufficient to consider that a tyre has been placed on the market. However, in most cases, tyres unloaded at the harbor or passing the border are already subject to an agreement and can hence be considered as placed on the market, thus those tyres must bear an individual label sticker, or, for batches, 'a printed label' must accompany them.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
If the individual tyre or batches are stored in the manufacturers’ warehouse and have not been subject yet to any commercial transaction, this means that they have not been placed on the market. According to the Blue Guide, placing on the market is about first making available a product and it assumes that an offer or an agreement (written or verbal) had been concluded between two or more legal or natural persons for the transfer of ownership, possession or any other right concerning the product.
However in most cases, tyres stored in a distributor’s warehouse may have been already subject to an agreement between two legal or natural persons and can hence be considered as “placed on the market”, or further made available in the supply chain e.g.: from a distributor to another distributor.
Otherwise said, it is not a matter of physical transfer (plant/warehouse) but of written or verbal agreement between two or more legal or natural persons for a transfer of ownership that triggers the placing on the market / making available the product in question after the stage of manufacture has taken place.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes, a new registration is necessary for tyres that still comply with the new R.117 requirements.
If the tyre does not satisfy the new requirements, this should be indicated in EPREL as not placed on the market anymore and as from which date.
New limits/requirements CANNOT result in a label change. Any change in the product, to satisfy to new, stricter requirements, will necessarily involve a NEW registration in EPREL of the new and modified product (with change of product identifier, as well).
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Tyre grading classes and snow grip qualification are determined by the tyre manufacturer using the methods of R117, or ISO 19447 for ice grip qualification. At the moment of attributing the grading class, the applicable versions of the R117 or ISO test procedure and test report are used and documented.
As with VECTO Regulation (EU) 2017/2400, conformity is assessed using the testing methods in force at the moment of the measurement and of the registration in EPREL.
The precise version of the testing method and the date of testing have to be indicated in the technical documentation to be uploaded in EPREL as part of the section «Reference to harmonised standards».
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes. All information can be provided in a single document. In EPREL all types of documentation can be checked, confirm that the document contains everything required.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Recital 14 clearly refers to ISO 19447 as the only standard for measuring the ice grip index.
Only C1 tyres with ice braking performance level above the threshold as from ISO 19447 can display the 'ice pictogram' on the label.
Recital (9) explains that it is essential to prevent that testing results obtained by market surveillance authorities are different from the testing results declared by the suppliers. This is possible only with the use of a reliable, accurate and reproducible method, and at the condition that no alternate method providing different information is used.
See also question 'Can C2 or C3 tyres labels bear the ice pictogram?'
No. Standard ISO/DIS 19447 'Passenger car tyres — Method for measuring ice grip performance — Loaded new tyres' only covers the testing method for C1 tyres. Until this standard will be updated, to cover C2 or C3 tyres, no C2 or C3 tyre can be tested and, consequently, no C2 nor C3 tyre can bear the ice pictogram.
Consequently, only C1 tyres with ice braking performance level above the threshold as from ISO 19447 can display the 'ice pictogram' on the label.
The subject matter of the Tyre Labelling Regulation (EU) 2020/740 in its Article 1, justified by Recital (9), is to provide harmonized information on tyre parameters to allow the end user to make an informed choice. It is also essential to prevent that testing results obtained by market surveillance authorities are different from the testing results declared by the suppliers.
This is possible only with the use of a reliable, accurate and reproducible method, and at the condition that no alternate method providing different information is used.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Once the registration of a type tyre is completed and the date of placing on the market occurs, some changes are not possible anymore and some others remain possible with a reason for the change to be provided in a specific notes field (this can be done either with automatic transfer or by using the GUI). These changes are logged (author, date and time).
For convenience, the accepted reasons are listed:
Correct typo: supplier made a mistake when declaring a value and has to correct it.
Change in standards: the testing standards can be amended and thus some values need to be modified.
Label scale-range change, e.g. as result of amendment of the type approval legislation
Request to change declaration by market surveillance: If an MSA detects an error or mistake that does not need a new registration, it can ask the supplier to modify some values of a registered model.
Correction without changes in declaration: during the lifecycle of a tyre type it might occur, that either the company itself produces more helpful information, or clarification, or that it turns out that for communication with MSA this correction would speed up their understanding (though strictly speaking not legally necessary). Additional information, that does not change in such a case the model, cannot lead to a compulsory change in model number (=no new registration).
Request to change declaration by an external body: Certification Bodies very frequently detect errors in declared data, sometimes typing mistakes, many times performance data that, after testing in an independent laboratory, need correction (“rerating”). Data linked to a product can represent up to dozens of values, and it can happen that one, a few, or more, need adjustment.
More details can be found in the Wiki user guidelines.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
If the change is exclusively the HL prefix and no parameter values indicated in the label of PIS is changed, please update the tyre size designation with the HL prefix. In the justification just write: 'Added HL indication, to fully match the indication on the sidewall' or similar text.
If, on the contrary, also any value in RR, wet grip, noise, etc. changes, the tyre should be registered as a new product.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Until the specific tyre type part of the OEM is registered in EPREL, the vehicle supplier cannot access the information related to the tyre type. Thus, the information can be updated only after the tyre supplier has registered the tyres in EPREL. Therefore, there is no alternative than showing the previous label.
Moreover the new label classes do not change between the old and the new label (apart from a downscaling of of classes E and F to eliminate the empty D class), consequently the new label is not going to change the customer purchase choice.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Vehicle manufacturers or vehicle importers placing on the EU market vehicles equipped with tyres not already placed on the market, act as importers of those tyres, with all related obligations.
In other terms, the vehicle importer acts as tyre importer as well.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Article 2.(c) lists T-temporary-use spare tyres as out of scope of the Regulation. The definition in Article 3.(3) refers to ‘T‐type temporary‐use spare tyre’ as a temporary‐use spare tyre, regardless of its size.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Annex II of Regulation (EU) 2020/740 mandates a minimal label size of 75x100mm.
Any technical promotional material shall display the tyre labels. No requirement on the size for the labels displayed electronically is specified. In particular, Article 4.2 and 6.7 read for tyres sold or offered for sale by distance selling 'The size of the tyre label shall be such that it is clearly visible and legible and shall be proportionate to the size specified in point 2.1 of Annex II.'
Moreover, it is technically impossible to respect a size in millimetres or centimetres on an electronic screen because the size varies depending on the 'resolution' of the screen.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Storage locations in the premises of the tyre manufacturer before any commercial transaction has taken place, are not covered by any obligation in respect to labelling.
Storage areas in the premises of a distributor where tyres are neither displayed nor offered for sale to customers is not considered as a point of sale to which Article 6 applies.
When tyres are stored in the premises of a distributor and not displayed and offered for sale to customers, no requirement for displaying the label or the PIS apply. However Article 6.4 is applicable 'Distributors shall ensure that where tyres offered for sale are not visible to the end-user at the time of sale, they provide the end-user with a copy of the tyre label before the sale'.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes. Article 6(4) reads 'Distributors shall ensure that where tyres offered for sale are not visible to the end-user at the time of sale, they provide the end-user with a copy of the tyre label before the sale.' According to the definition in Article 3(5), a ‘tyre label’ means a graphic diagram, in printed or electronic form […].
So an electronic form would be accepted for tyres not visible in the shop.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes. Article 6(4) reads 'Distributors shall ensure that where tyres offered for sale are not visible to the end-user at the time of sale, they provide the end-user with a copy of the tyre label before the sale.' According to the definition in Article 3(5), a “‘tyre label’ means a graphic diagram, in printed or electronic form […]”.
So an electronic version would be accepted for tyres not visible in the shop.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
In technical documentation, technical promotional material, quotations, sales contracts, invoices and other material, the labels of tyres,
Annex II of Regulation (EU) 2020/740 mandates a minimal label size of 75x100mm but if printed with correct size it may take the largest part of the space.
Any technical promotional material shall display the tyre labels. No requirement on the size for the labels displayed electronically is specified. Moreover, Article 4.2 and 6.7 read for tyres sold or offered for sale by distance selling 'The size of the tyre label shall be such that it is clearly visible and legible and shall be proportionate to the size specified in point 2.1 of Annex II.'
Finally, it is technically impossible to respect a size in millimetres or centimetres on an electronic screen because the size varies depending on the 'resolution' of the screen.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The tyre label is intended as an aid to support the user in an informed 'purchase' decision. It is crucial, therefore, that the user can see the label (and, if desired, the product information sheet) 'before' taking the purchase decision.
No obligation of displaying the label has been set for any document produced 'after' the payment or similar commitment by the customer. It is obviously a good practice to document the choice of the customer, once done, and for this a QR code or the human-readable equivalent URL could be printed in the invoice or analogous post-sales document, thus giving to the customer the possibility of having access to the full tyre registration in EPREL.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
All C1, C2 and C3 tyres produced from the 1st May 2021 and necessarily placed on the market after this date must show the new label. However, there are no obligations for dealers to relabel tyres that are in stock after the 1st May if these tyres were produced before that date, so before the new tyre label regulation came into effect. In other words, tyres placed on the market prior to the 1st of May can show the old label until they are sold. Therefore, both the old and the new label may be found on tyres at retailers even after the 1st May 2021, depending on the date of production.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes. Article 6(4) reads 'Distributors shall ensure that where tyres offered for sale are not visible to the end-user at the time of sale, they provide the end-user with a copy of the tyre label before the sale.' According to the definition in Article 3(5), a 'tyre label’ means a graphic diagram, in printed or electronic form […]'.
So an electronic form would be accepted for tyres not visible in the shop.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
No, unless the customer can see the label 'before the sale', i.e. at the very latest before the sales contract is signed (if on paper) or the button to confirm the purchase is pressed (for on-line sales).
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
No. There is no such obligation.
The Regulation assumes that the label and PIS must be an instrument of an informed purchase choice.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
No. As from Article 4 point 6, suppliers shall ensure the accuracy of the tyre labels and product information sheets that they provide.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
No, there is no such obligation.
The regulation assumes that the label and the PIS must be an instrument of an informed purchase choice, thus providing information ‘before the sale’.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
That depends. Article 7 does not refer to any specific media support for the label, thus a label in electronic format appears to be acceptable if the remaining vehicle information is provided in the same way.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes. The obligation can be considered to be fulfilled if the information on the tyre label and in the relevant technical promotional material is part of the documentation provided to the end-user 'intending to acquire' a new vehicle.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The label has to help the end-user in making an informed purchase choice.
'Intend to acquire' suggests that the purchase decision is close to be taken but not formalised yet, i.e. with the signature of a reservation, order or purchase contract. Therefore, at the very latest before such an irreversible action, vehicle suppliers and vehicle distributors have to provide this element of complementary information as, in principle, may it influence their purchase choice (e.g. on which rims and tyre combination).
This has to be considered as applicable not only for a vehicle displayed in a store, but also for on-line sales.
See also question 'In Article 7, how should 'before the sale' be interpreted?'
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The label has to help the end-user in making an informed purchase choice.
The provision of the tyre label is part of the technical material provided to influence the purchase decision and should not be intended as a mere document to attach at the time of signature. This appears particularly relevant if the vehicle is proposed with different rims of different size and thus different tyres types that may have an influence on the energy consumption of the vehicle, whatever 'fuel' it uses (including electricity).
This has to be considered as applicable not only for a vehicle displayed in a store, but also for on-line sales.
See also question 'In Article 7, how should 'intend to acquire a new vehicle' be interpreted?'
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
A vehicle supplier may not have certainty about which specific tyre type will be available before a certain time (e.g. because of tyre mounting scheduled in lots, stocks depleted, change in supply contract by the vehicle manufacturer, etc.). In some cases, many months may elapse between the order and the factual production of the vehicle, during which the availability of tyres may change. The label description in Annex II includes ‘Trade name or trademark of the supplier’ as a mandatory element among other technical characteristics. If multiple tyre types can be used, the information (i.e. the label and Product Information Sheet) should be made available for each of them.
The sales contract may regulate a situation where, for reasons unpredictable at the time of the signature, the car has to be finally delivered with a different tyre type.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The tyre label is intended as an aid to support the user in an informed purchase decision. It is crucial, therefore, that the user can see the label (and, if desired, the product information sheet) 'before' taking the purchase decision. No obligation of displaying the label has been set for any document produced “after” the payment or similar commitment by the customer.
It is obviously permitted to document the choice of the customer, once done, and for this a QR code or the human-readable equivalent URL could be printed in the invoice or analogous post-sales document.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The label, with the pPIS, has to help the end-user in making an informed purchase choice.
The provision of the tyre label should not be intended as a mere document to attach at the time of signature, but as part of the technical promotional material provided to influence the purchase decision. This appears particularly relevant if the vehicle is proposed with different rims of different size and thus different tyres types that may have an influence on the energy consumption of the vehicle, whatever “fuel” it uses (including electricity).
'Intend to acquire' suggests that the decision is close to be taken but not formalised yet, i.e. with the signature of a reservation, order or purchase contract. Therefore, at the very latest before such an irreversible action, vehicle suppliers and vehicle distributors have to provide this element of complementary information as, in principle, may it influence their purchase choice (e.g. on which rims and tyre combination).
This has to be considered as applicable not only for a vehicle displayed in a store, but also for on-line sales.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.