A document issued by the EU Commission early in the Brexit negotiations had given rise to concerns that the tyre labelling regulation would not apply post-Brexit. There were even suggestions the UK might strike out on its own with a Made-in-Britain labelling scheme. From an international tyre industry point of view this would clearly be extremely challenging.

The Department for Transport recently gave the following assurance:

“Under the Withdrawal Act, direct EU law, such as The Tyre Labelling Regulation, will form part of UK domestic law after exit and hence the requirement to ensure tyres are labelled in accordance with 1222/2009 will continue to apply (at least until such time as the Government chooses to make changes).”

The DfT has also given clarification regarding the validity of tyre labelling data sourced in the UK prior to EU-exit:

“Our expectation is that provided labelling data is obtained according to the procedures set out in the regulation, it should not matter where the data is sourced. The obligation will be on the manufacturer to demonstrate that the data is sourced according to the test procedures set out in the regulation.”

A recent European study commissioned by ETRMA has shown that there are now over 78,000 different labels for car tyres alone. The recently concluded EU Market Surveillance project found 11% of the 131 tyres tested were incorrectly labelled. Improved test methods and a revised labelling regulation are currently under discussion to address this shortfall but any changes are still some years off.

The DfT has recently shown renewed interest in pursuing enforcement powers for the labelling regulation in the UK but “resources are dependent on the outworking of Brexit”.

Alfred Graham, (TIF) Chairman, said: “The implementation of tyre labelling has not been without issue but at least the assertion from the DfT that it intends to remain aligned with the EU regulations avoids a significant challenge for the tyre industry on this post-Brexit issue in the UK. As such, TIF welcomes the news. TIF has been invited by the DfT to discussions “in due course” and has indicated its intention to participate.”

Further resources

• Initial document from EU Commission:

http://ec.europa.eu/docsroom/documents/27401

• ProSafe conclusions:

http://www.mstyr15.eu/images/MSTYR/Documents/MSTyr15_2nd_Press_release_20180709_FINALv3.pdf

• ETRMA labelling study:

http://www.etrma.org/uploads/Modules/Documentsmanager/etrma-lizeo-report-2018-v9-web.pdf

In a report sent to the Minister for the Environment, Dr Thérèse Coffey, TIF has pointed out the current arrangements for used tyre collection and recovery have been persistently let down by inadequate enforcement action against the deliberately non-compliant. Too many operators, both retailers and collectors, have been able to pursue shady practices for too long, undermining legitimate operators and giving the industry as a whole a bad name.

While government is, at last, addressing some of the regulatory loop-holes that the less-than-compliant have exploited, TIF is pressing for more effective enforcement without which the promised measures will be fruitless. The report also highlights the adverse impacts of criminal activity on legitimate operators and recovery outcomes.

Peter Taylor, Secretary General of the Tyre Recovery Association, said: “For too long government has focused enforcement on legitimate operators who have chosen to apply for an environmental permit. The playing field must urgently be levelled so that all operators are subject to the same regime.”

Stefan Hay, Chief Executive of the National Tyre Distributors Association said: “We have been appalled to discover not only petty criminals but organised crime infiltrating our used tyre recovery networks. This is a call to action, not only to government but also to our industry. As NTDA and TRA seek to work more closely than ever, we must stamp out illegal practices in used tyre recovery.”

TIF has also highlighted the used tyre recovery network’s excessive dependency on unstable export markets, which is undermining much-needed investment in the UK’s processing capacity. The Federation is pressing government to take concrete action to enable the development of UK recovery infrastructure to deliver a circular and regenerative economy for tyres.

Alfred Graham, Tyre Industry Federation Chairman said:“ Our industry can be proud of its collective achievements but the report also highlights the distance we still have to run and the need for government support in reaching the goal.”

Brexit and the outworking of government’s many recent strategy statements concerning business and the environment will make Alfred’s tenure an important time for the country and the tyre industry in particular.

Outgoing Chairman, Roger Griggs, Kwik-Fit Public Affairs Director and ex-NTDA president, was thanked for his valuable contribution during his term of office.

At the same meeting the Federation strengthened its communication strategy by reiterating its principles regarding consensus and coordination.

Commnting on his appointment, Alfred said: “I am looking forward to fostering an ever closer working relationship and understanding of mutual values between all of the Federation’s constituent bodies. Our strength must lie in speaking with one clear voice at a time when our industry is facing a number of new challenges, especially in relation to regulations. I’d like to personally thank Roger Griggs for his valued work during his tenure and I look forward to working with all partners across the tyre industry.”

About Alfred Graham

Alfred began his career in the tyre industry while working with Mitsubishi Trading Corporation. Over the course of 13 years, Alfred rose to become Assistant Manager of the General Merchandise Department from where he joined a private merchant bank as Managing Director Designate of the Trading Division. In 1981, he established his own business, which specialised in importing tyres in particular from China and the Far East.

DEFRA states1: “… the purpose of this call for evidence is:

·         to gather evidence on non-exhaust emissions

·         review our estimates of their contribution to air pollution

·         develop forecasts for how they will evolve in the future

·         identify concrete actions to generate a step change in work in this area and understand policies that might support that work.

“We are particularly interested in evidence which will help us understand and quantify the true scale of the problem and also identify any potential abatement methods, new technologies or opportunities for innovation in this area.”

The tyre industry has been actively engaged with the DfT and DEFRA on the subject for some years and has already provided them with independent research on the issue. This and further findings will be submitted as part of the process.

Alfred Graham, TIF Chairman, said: “The tyre industry has been researching the characteristics of tyre and road wear particles for several years. We look forward to sharing our understanding of this topic and of the multiple opportunities to maximise tyre service life to contribute to the comprehensive body of evidence necessary to inform future government policy.”

Patrick has been managing director of Bandvulc Group, which incorporates Bandvulc Tyres Ltd, Bandvulc Tyre Contracts and Devon Rubber, since 2003. It is a family business which was founded in 1970.

“The Tyre Industry Federation performs a crucial function by speaking with one voice on behalf of its members, so it’s a great responsibility to take over as Chairman.

“However, it’s a role that I’m looking forward to as it will fully utilise my extensive knowledge of the tyre industry.”

Patrick, who replaces David Seward as the previous TIF chairman, is also a member of the Plymouth Manufacturing Group, the Tyre Recovery Association, National Tyre Distributors Association and chairman of the Retread Manufacturers’ Association.

The Tyre Industry Federation provides a common platform for the British Tyre Manufacturers’ Association, the Imported Tyre Manufacturers’ Association, the National Tyre Distributors Association, the Retread Manufacturers Association and the Tyre Recovery Association.

Among its aims are to address areas of common concern and to raise government awareness of the impact of the tyre industry on issues including road safety, climate change and sustainability.

The free document, which is available to download from the TIF website (www.tyreindustryfederation.co.uk) has been developed in conjunction with the Department For Transport and is designed as an authoritative and definitive guide on the topic, helping retailers and workshops comply with the new requirements.

“Tyre labelling is undoubtedly one of the biggest changes to impact on our industry in recent times,” explains David Seward, chairman, TIF. “For consumers, it will help them make a more informed choice about tyre purchases. Meanwhile for retailers there are a number of key issues they must understand and address. As a result of our extensive industry consultation, this guide is designed to help retailers meet these obligations and requirements.”

From July 1^st, all new tyres manufactured for sale within Europe, must be labelled according to their performance against three key criteria; fuel efficiency, wet grip and their external noise emissions.

Retailers will be required to pass this information on to consumers from 1^st November, meaning that they now have just four months left to ensure they have addressed key issues such as staff training, data handling, invoice preparation and other items.

“For too long tyres have been viewed by many drivers as a commodity item,” continues Seward. “However, if correctly employed, tyre labelling offers retailers the opportunity to move towards a more in-depth value and service-focused relationship.”

Recognising the need for information and industry guidance, the Tyre Industry Federation has worked closely with the Department for Transport to provide an authoritative guide to the topic. Extensive Industry consultation has ensured that all the key issues are addressed in this easy to read document available free to download.

Players at every level in the supply chain need to consider how they will meet the requirements of the Regulation. This will include issues such as staff training, data handling, customer communication, invoice preparation and so on. On the positive side tyre labelling will be an opportunity to move the sales process on towards a more in-depth value- and service-focused relationship opening the way to greater sales value for both consumer and supplier.

TIF Chairman, David Seward, said “Once again, TIF is meeting a need for clear information that will contribute to further increasing professionalism within our Industry”.

TIF_Tyre_Labelling_A5_May 12

Freely available here, the downloadable resource gives an overview of the tyre industry from manufacture to recycling and from road safety to lifecycle impact. Filled with information from authoritative sources the Factbook provides a concise and easily accessible insight into the many dimensions of the UK tyre industry.

Aimed at Government, journalists, or anyone with an interest in learning more about the UK tyre industry, members of the tyre trade will also find useful information to complement their existing knowledge.

 TIF Chairman David Seward said “The TIF Factbook is an important step forward in improving understanding of our industry for those who need or wish to learn more”.

The Tyre Industry Federation provides a common platform for the British Tyre Manufacturers’ Association, the Imported Tyre Manufacturers’ Association, the National Tyre Distributors Association, the Retread Manufacturers Association and the Tyre Recovery Association.

View this article on the Association of British Insurers web site