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Energy Efficient Products

Are these storage situations also understood to be points of sale where the tyre label needs to be displayed?

There are storage situations along the distribution chain, where tyres will never be seen by the end-customer, especially in the case of truck tyres. 

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.