In responding to an important consultation paper issued recently by the Government on the proposals by the European Commission for a new Vehicle Safety Regulation, the Tyre Industry Federation expressed serious concerns about the impact the tyre provisions will have on the UK tyre market.

Speaking about these concerns Peter Gaster, Chairman of the Federation, said: “As they stand, the proposals could well result in serious problems for the tyre industry, the motorist and the highways system in the UK. The industry has proposed a number of amendments to the legislation to meet these concerns, The Department for Transport launched a consultation on the proposals only when negotiations in Europe have reached an advanced stage. We hope that even at this point the Department will take these amendments on board and urge their adoption in the continuing discussions in Brussels.”

The regulation would:

• set more stringent values for tyre/road noise limits,
• set for the first time tyre rolling resistance limits
• set requirements for wet grip testing
• make it mandatory to fit Tyre Pressure Monitoring Systems on new vehicles.

In principle the industry supports moves to make tyres less noisy, more fuel efficient and with better grip properties. Indeed these are goals that the companies constantly pursue in the development of tyres as a matter of course. The problems relate not to these goals but the ways in which the regulation addresses them.

The key points of our industry are:

• the proposals purport to strike an integrated regulatory framework for tyres which strikes a fair balance between the various performance criteria. They do not;

• In particular the noise reductions required are of such dimensions that they will inevitably result in trade-offs in the other criteria such as wet grip, aquaplaning, wear and handling;

• For example the proposed noise limits for drive axle (traction) truck tyres would so degrade adherence for heavy goods vehicles that they would be difficult to operate in slippery condition and could block roads;

• In any event inadequate attention seems to have been given to other ways of achieving the noise reduction sought. Three to four times the level could be achieved by reducing speed in congested areas and/or reworking road surfaces.

• The implementation timetable is too tight to enable all of the thousands of product lines currently on the market to be re-engineered, tested, set up for manufacture and placed on the market in time. There is a significant risk that without concessions the industry would simply not be able to supply tyres to the extent needed, and damaging shortages could result. There is also a risk of substantial stocks of tyres not meeting the requirements being caught in the supply chain and having to be destroyed.

• The proposal will be costly to implement. By the Department’s own estimates the measures will cost upwards of £6 per car tyre. Such an imposition on motorists represents a significant additional burden for them at a time when household budgets are likely to be under considerable pressure.

• There is a potential knock on effect on tyre production, which remains a significant manufacturing sector in the UK and is especially important in certain regions such as the West Midlands and the South West.

Finally, as a general point, the industry expressed its concern at the very short timescale allowed for responding to the consultation. Four weeks for consultation on a measure of such technical complexity is quite inadequate, and by delaying the consultation to this point Government has left itself with little scope to influence negotiations in the light of the outcome.

Notes for Editors

The Federation is administered by the British Tyre Manufacturers’ Association out of its offices in Central London. Peter Gaster, Chairman of the National Tyre Distributors Association, is the current Chairman of the Federation, and John Dorken, Chief Executive of BTMA, acts as its Secretary.

TIF Members are:

• BTMA (British Tyre Manufacturers’ Association)
• ITA (Industrial Tyre Association)
• ITMA (Imported Tyre Manufacturers Association)
• NTDA (National Tyre Distributors Association)
• RMA (Retread Manufacturers Association)
• TRA (Tyre Recovery Association)

The proposals are contained in the “Commission Proposal for a Regulation Concerning Type-Approval Requirements For The General Safety of Motor Vehicles” (COM (2008) 316), presented by the Commission on 23 May 2008. It sets type-approval requirements for the general safety of motor vehicles, including regulations covering new tyres. The proposal also aims to reduce the regulatory burden on industry through the repeal of 50 Directives, and their amendments, on general vehicle safety and on tyre noise, and consolidating them into this one Regulation. The proposal has been under consideration in the European Council and Parliament since last June with the intention of reaching substantive agreement by the spring of 2009.

The Department for Transport issued a consultation document on the proposal on 7 January 2009, seeking responses by 4 February. The document can be found on http://www.dft.gov.uk/consultations/

For enquiries please contact John Dorken on 020 7457 5040 or jdorken@btmauk.com