Our FAQs on the new EU Tyre Label
How will Falken distinguish between old and new label product when delivering stock to warehouse and retail locations?
From our point of view there is technically no need to distinguish between tyres labelled under the old regulation 2009/1222 and tyres labelled under the new EU regulation 2020/740. We will only change the labels on tyres in production at the time of the changeover. The tyre composition will not change. We will have an internal database documenting the change to enable us to define the production week of the changeover to the new EU label.
Will tyres labelled under the new EU regulation 2020/740 have new order numbers and/or article numbers?
No. The tyres will have the same article number as well as the same EAN number.
Will point of sale literature be provided to our business to assist with end users’ understanding of the changes?
We are working on POS documentation to inform B2B customers and end customers. You can find the flyer in PDF format on our website.
Will tyres labelled under the old regulation 2009/1222 and tyres labelled under the new EU regulation 2020/740 be suitable for fitting on the same vehicle and on the same axle?
There will be no technical change to the tyre composition, so tyres can be mixed.
How long do you expect your stock transition phase to last? (i.e. old product shipped for use before new product from your storage facilities, received at your warehouse before 1 May 2021)
Falken Tyre Europe GmbH will gradually change throughout 2021. The deadline for manufacturers is 30 November 2021. After November 2021, manufacturers can only place tyres with the new label on the market. Distributors can keep selling tyres with the old label even after November 2021.
Please see the EU regulation 2020/740 Article 6 for the obligations of tyre distributors.
We would prefer for you to show the new label as soon as the change has been made in production, but throughout the transition period it is our understanding that either label can be displayed. After November 2021, only the new label may be shown in end-customer displays.
Is there a potential penalty if we display the old label during the transition period? Will we receive a penalty if we display the old label during the transition period?
The EU Market Surveillance Authorities have agreed to respect the transition period.
It is our understanding that the old material can be used until the transition period for manufacturers is over in November 2021.
Are the rules now any stricter at point of purchase regarding the requirement for the dealer to be able to show the tyre label at the reception desk?
Please see the EU regulation 2020/740 Article 6 for the obligations of tyre distributors. Generally the label must be observable for any customer. Furthermore, the product information sheet must be made available in printed or electronic form.
Article 4 and Article 6, establishing the obligation to accompany tyres with the new label, apply from 1 May 2021.
All tyre classes produced from 1 May 2021 (thus bearing a date of production equal to or later than “1821” and necessarily placed on the market after this date) must bear the label from Regulation 2020/740.
Can tyres placed on the market before 30 April 2021 bear only the label as under Regulation 1222/2009? What about from 1 December?
From 1 May 2021, both the old and the new label may be found on tyres at the sales point, depending on the date on which those tyres were placed on the market.
There is no obligation to relabel tyres that have been placed on the market before 1 May 2021. Tyres may be found in shops or stores for years to come. However, from 1 December 2021, NO tyre in the scope of the Regulation may be placed on the market with the label from Regulation (EC) 2009/1222, irrespective of the production date.
Yes. The QR code links 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. The QR code is a machine-readable universal resource locator (URL), leading to the specific record in the EPREL system.
Such a link includes the unique code associated with a specific tyre type, i.e. the EPREL product identifier. The QR code gives access to the public information in EPREL that constitutes the label and the PIS.
The public information appears in the internet browser. A PDF version of the label and PIS can be displayed, downloaded or printed.
Equivalent models have a different unique product number and QR code, but link to the same label and PIS content (because of the definition itself of “equivalent”).
Is it the tyre manufacturers’ obligation to provide the PIS, or is it sufficient for the distributor to go to EPREL and download the PIS to fulfil its obligations?
EPREL can automatically produce a PIS from data entered by the supplier and in any official language of the EU. To fulfil the obligation, the tyre type must be registered in EPREL if a printed version is not provided.
How does the supplier give the information to the distribution chain? Is provision of the QR code enough?
The QR code provides a direct link to the “public” information stored in EPREL, i.e. to all parameters which are part of the label and of the Product Information Sheet.
Alternatively, the URL clearly corresponding to the QR code must be provided for situations where a QR reader is not available.
According to Art 32), of the framework regulation EU 2017/1369, suppliers shall provide the Product Information Sheet on demand from dealers within 5 working days. In principle, the aim of the QR code is to provide anybody with instant access to the Product Information Sheet online by reading the QR code with a suitable tool.
EPREL will not make any information publicly available before the starting date of application of the new label, i.e. provision of the QR code alone does not permit access to the information before 1 May 2021.
More in general, the QR code does not provide any publicly accessible information before the starting date of placement on the market as given in EPREL.
Since the QR code is available in the distribution channel, can “accompanied” be understood as fulfilling the obligations regarding the PIS?
The word “accompanied” is used in the Regulation in Article 4: “suppliers shall ensure that tyres are accompanied by a tyre label (in the form of a sticker or a printed tyre label) and by a product information sheet. No clear indication is given as to the format of the product information sheet. 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 product information sheet. However, if the customer cannot access the PIS via the EPREL system using the QR code, then the PIS can be made physically available.“
From our point of view, there is technically no need to distinguish between tyres labelled under the old regulation 2009/1222 and tyres labelled under the new EU regulation 2020/740. We will only change the labels on tyres in production at the time of the changeover. The tyre composition will not be changed. The tyres will have the same article number as well as the same EAN number. FTE will not differentiate between the different labels.
There is no obligation to relabel tyres that have been placed on the market before 1 May 2021. Tyres may be found in shops or stores for years to come. Tyres delivered to distribution customers and retail shops can be sold with no restrictions. Throughout 2021, it may happen that Falken delivers tyres from its stock that bear labels under the old regulation 2009/1222, due to the fact that those tyres were produced before May 2021. There might also be cases where FTE ships both new and old label tyres within the same batch of one tyre specification.
In May 2021 the EU Parliament will pass a new tyre labelling regulation, (EU) 2020/740. This new regulation repeals the previous labelling regulation (EU) 2009/1222.
What is the performance difference between the grades on each criterion, “D” vs. “C” vs. “B” vs. “A”?
For the technical basis for the label grading, please see the regulation (EU) 2020/740 ANNEX I concerning the testing, grading and measurement of tyre parameters. Here you can find the tyre performance levels relevant for the label grading.
For the technical basis for the label grading, please see the regulation (EU) 2020/740 ANNEX I. The value measured for external rolling noise (N, in dB(A)) shall be declared in decibels. The external rolling noise class shall be determined and illustrated on the tyre label on the basis of the limit values (LV) set out in Part C of Annex II to Regulation (EC) No 661/2009.
The label shows all required grading as per the new tyre labelling regulation (EU) 2020/740.