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European Tyre & Rubber Manufacturers' Association

ETRMA

The European Tyre & Rubber Manufacturers' Association represents 14 companies accounting for 70% of global tyre sales.

Lobbying Activity

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs) and Unknown Organization

17 Dec 2025 · Exchange of views on rubber

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur)

2 Dec 2025 · End-of-Life Vehicles Regulation

Meeting with Valdis Dombrovskis (Commissioner) and

19 Nov 2025 · Competitiveness

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and European Tyre and Rim Technical Organisation

7 Nov 2025 · Competitiveness challenges faced by the European tyre industry and regulatory simplification.

European Tyre Industry Seeks Harmonized Recycling Rules to Boost Competitiveness

6 Nov 2025
Topic — New EU Circular Economy Act aims to enhance sustainable production and secondary materials markets.
Message — The organization requests EU-wide harmonized end-of-waste criteria for all tire-derived materials, clearer definitions of recycled and bio-based materials, and recognition of chemical recycling as a legitimate recycling operation. They argue current fragmented national approaches create legal uncertainty and hinder cross-border trade in secondary raw materials.123
Why — This would reduce administrative burdens, enable greater use of recycled materials in new tires, and provide legal certainty for cross-border trade.456
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Meeting with Eva Schultz (Cabinet of Executive Vice-President Roxana Mînzatu)

23 Oct 2025 · Skills and labour needs in the tyre and rubber industry

Tyre Industry Urges Data Act Enforcement Before Digital Simplification

14 Oct 2025
Topic — Digital Omnibus initiative to simplify data, cybersecurity, and AI regulations.
Message — The association calls for prioritising enforcement of the Data Act before any legislative simplification. They request sector-specific legislation on access to in-vehicle data and consistent implementation across Member States to ensure fair competition and support data-driven services.123
Why — This would secure access to vehicle data needed for tyre services and protect investments in data-driven business models.456
Impact — Independent service providers and consumers lose if vehicle manufacturers control data access unilaterally.78
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European Tyre Industry Urges Financial Support for Electrification Transition

9 Oct 2025
Topic — EU plan to increase electrification of energy demand to achieve decarbonisation targets.
Message — The industry requests regulatory and financial support for electrification, including funding for operating costs and adapted state aid rules. They emphasize technological neutrality is needed since key manufacturing processes like curing require high thermal loads that current electrification technologies cannot fully replace. They call for revised EU funding schemes and long-term financial visibility beyond 2030.1234
Why — This would reduce their operating costs and make electrification investments financially viable in Europe.56
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Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné)

8 Oct 2025 · Tyres industry

European Tyre Industry Urges CBAM Methodology Changes to Reward Cleaner Production

25 Sept 2025
Topic — New EU rules on carbon price certification for third-country imports under CBAM.
Message — The organisation requests adjusting the current methodology to use energy consumption intensity instead of emissions intensity when calculating free allowances. They argue the current approach favours polluting production methods and fails to reward installations using cleaner alternatives like renewable electricity.123
Why — This would increase free allowances for tyre manufacturers already using renewable energy sources.45
Impact — Higher-emission manufacturers lose competitive advantage from current methodology favouring dirtier processes.6
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European Tyre Industry Urges Energy-Based CBAM Benchmarks Over Emissions

25 Sept 2025
Topic — CBAM rules on adjusting certificate obligations to reflect EU ETS free allocation.
Message — The organisation requests that CBAM benchmarks use energy consumption intensity instead of emissions intensity. They argue current EU ETS methodology favours polluting processes and penalises installations using cleaner alternatives like renewable electricity. They also seek better reflection of trade intensity in carbon leakage calculations and clear methodologies for recognising carbon prices paid abroad.123
Why — This would allow tyre manufacturers using renewable electricity to receive free allowances currently denied to them.45
Impact — More polluting manufacturers lose preferential treatment under current emissions-based methodology.6
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Meeting with Beatrice Timgren (Member of the European Parliament)

17 Sept 2025 · Competitiveness of European tyre industry

Meeting with Pascal Arimont (Member of the European Parliament)

10 Sept 2025 · EU Deforestation Regulation

Meeting with César Luena (Member of the European Parliament)

9 Sept 2025 · EUDR, Industrial Decarbonisation Accelerator Act, ETS, and CBAM

Meeting with Susana Solís Pérez (Member of the European Parliament)

9 Sept 2025 · EUDR, ETS, CBAM

Tyre manufacturers demand role for efficient tyres in fleet rules

8 Sept 2025
Topic — The Commission is consulting on rules to increase zero-emission vehicle uptake in corporate fleets.
Message — The association requests that the proposal include high-performing tyres for all vehicle types. They prefer financial incentives and tax benefits over mandatory requirements for businesses.12
Why — This would boost demand for premium tyres where European manufacturers hold a competitive advantage.3
Impact — Budget tyre manufacturers face reduced demand as the policy shifts fleets toward high-performance models.4
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ETRMA demands tyre sector inclusion in ETS state aid

5 Sept 2025
Topic — This consultation updates rules for compensating energy-intensive industries for indirect carbon costs.
Message — ETRMA requests the tyre sector be added to industries eligible for state aid. They also demand that the system of free carbon allowances be maintained.123
Why — Eligibility would provide financial compensation and protect the industry's global competitiveness.45
Impact — Foreign tyre manufacturers would lose their current cost advantage over European-based production.6
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Meeting with András Tivadar Kulja (Member of the European Parliament)

4 Sept 2025 · Environmental topics, overview of the tyre and rubber industry

Response to Revision of the 'New Legislative Framework'

2 Sept 2025

The European Tyre and Rubber Manufacturers' Association (ETRMA) welcomes the European Commission's initiative to revise the New Legislative Framework (NLF) The revision presents a critical opportunity to modernise regulatory approaches by embracing digitalisation, promoting circularity, and reducing regulatory burdens.Please see attached our paper for more recommendations.
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Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

26 Aug 2025

In the context of the public consultation on the extension of the scope of the Carbon Border Adjustment Mechanism (CBAM) to downstream products, the European Tyre Industry (ETRMA) would like to share its key recommendations and policy considerations on behalf of its members. Tyre manufacturing is energy intensive. It enables Europes economy and society. Without tyres, Europeans cannot move, our economy grinds to a halt, and our defence and agriculture are unable to function. A recent study conducted by Oxford Economics on our behalf shows that 500.000 European jobs are dependent on the tyre industry which contributes about 44bn to European GDP. However, the industry faces significant challenges in maintaining a competitive manufacturing base in Europe. The tyre sector supports regulatory instruments that enhance the competitiveness of Europeanbased production. While the industry shares the ultimate goal of CBAM, it strongly emphasises the importance of a combined assessment of both downstream products and raw materials used as direct inputs in tyre manufacturing in the context of CBAM scope extension and review. The tyre industry also suggests avoiding any further expansion of CBAM to downstream products used as input in tyre manufacturing as long as it is not clear whether tyres as a finished product will be under the downstream product list of CBAM. A regulation that is both implementable and easy to verify is essential for its success and for ensuring fair competition among operators within the same value chain.
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Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

25 Aug 2025 · Tyre abrasion

Tyre industry urges EU to recognize chemical recycling methods

19 Aug 2025
Topic — The initiative defines rules for calculating and reporting recycled content in plastic beverage bottles.
Message — ETRMA requests the formal recognition of chemical recycling as a distinct process to recover high quality material. They advocate for extending the mass balance approach to other product groups such as tyres. The association also emphasizes the need for clear definitions and certification schemes for sustainable feedstocks.123
Why — This would help tyre manufacturers meet circularity targets by simplifying the use of recycled feedstocks.45
Impact — Environmental interests may be harmed by reclassifying industrial incineration processes as recycling operations.67
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Tyre manufacturers demand fair access to in-vehicle data

17 Jul 2025
Topic — This consultation explores streamlining EU data rules to improve cross-border data sharing.
Message — The association urges the Commission to prioritize access to vehicle-generated data. They request better alignment between general data laws and specific automotive regulations.12
Why — Secure data access would allow tyre companies to offer competitive maintenance and safety services.345
Impact — Vehicle manufacturers would lose their exclusive control over profitable vehicle-generated data streams.6
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Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

17 Jul 2025 · Competitiveness

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and European Tyre and Rim Technical Organisation

15 Jul 2025 · Tyre industry

Tyre industry urges reporting exemptions for subscription-based products

10 Jul 2025
Topic — New EU rules requiring companies to disclose information about destroying unsold consumer products.
Message — ETRMA calls for a clear exemption for products provided under subscription models. They also support using a limited assurance standard to minimize reporting costs.12
Why — This would allow companies to avoid the high manual effort of tracking information.3
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Tyre industry urges strategic recognition and decarbonisation funding

8 Jul 2025
Topic — The consultation addresses the Industrial Decarbonisation Accelerator Act to speed up green industrial investments.
Message — ETRMA requests that tyre manufacturing be recognized as a strategic sector to unlock financial support. They call for harmonized permitting rules across Europe to speed up industrial projects. They also propose tax incentives to help consumers choose low-carbon tyres over budget options.12
Why — This would help them cover high operating costs and compete with cheaper global imports.34
Impact — Budget-conscious drivers and foreign manufacturers of low-cost tyres would face higher relative prices.5
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Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

7 Jul 2025 · To discuss the ongoing proposal for a harmonised classification of a critical substance used in tyre manufacturing.

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

23 Jun 2025 · Competitiveness of tyre industry and regulatory simplification

Meeting with Elisa Roller (Director Secretariat-General)

19 Jun 2025 · Discussion on policies affecting competitiveness of the European tyre manufacturing industry

Tyre industry urges EU support for bio-based material innovation

17 Jun 2025
Topic — The European Commission is updating its strategy for a circular and climate-neutral bioeconomy.
Message — ETRMA requests EU-wide standards to turn old tyres into secondary raw materials. They seek better funding for sustainable rubber alternatives like dandelions. The industry wants trade deals to secure reliable biomass and natural rubber supplies.123
Why — These policies would stabilize raw material costs and reduce reliance on imports.45
Impact — Suppliers of petrochemicals and virgin minerals may see reduced demand for their products.6
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Meeting with Pascal Arimont (Member of the European Parliament)

17 Jun 2025 · Recycling of vehicles at the end of their life

Meeting with Alexandr Vondra (Member of the European Parliament, Shadow rapporteur) and European Association Automotive Suppliers and Hyundai Motor Europe

17 Jun 2025 · ELVR

Meeting with Adina Vălean (Member of the European Parliament)

11 Jun 2025 · deforestation

Meeting with Denis Redonnet (Deputy Director-General Trade) and

4 Jun 2025 · In his mission letter Commissioner Maroš Šefčovič is tasked to “closely monitor the full enforcement of our trade agreements on market access and rules […]”.

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur)

21 May 2025 · End-of-Life Vehicles

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and PFA - Filière Automobile Mobilités and Mobilians

20 May 2025 · Access to vehicle data

Meeting with Pascal Arimont (Member of the European Parliament)

15 May 2025 · Circularity requirements of end-of-life vehicles

Meeting with Mark Nicklas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and European Tyre and Rim Technical Organisation

15 May 2025 · Regulatory issues on automotive tyres

Tyre manufacturers urge explicit exemption for retreaded products

13 May 2025
Topic — A consultation on technical amendments to the European Union's deforestation regulation product scope.
Message — The association requests that retreaded tyres be entirely excluded from the regulation's scope. They propose using a specific code for tyre treads to ensure legal clarity.12
Why — This change would prevent significant administrative costs for small businesses and industry retreaders.3
Impact — Traceability advocates lose the ability to easily verify rubber compliance at the final retail stage.4
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Meeting with Alexandr Vondra (Member of the European Parliament, Shadow rapporteur)

8 Apr 2025 · ELVR

Tyre Industry Urges Removal of Onerous Chemical Reporting Rules

26 Mar 2025
Topic — The initiative seeks to simplify EU sustainability reporting and reduce business compliance costs.
Message — ETRMA recommends limiting the chemical criteria scope to well-understood requirements aligned with existing regulations. They specifically request deleting provisions that exceed REACH standards to ensure feasible industry reporting.12
Why — Simplifying these rules would lower administrative costs and ensure parity with non-EU competitors.34
Impact — Environmental groups lose a mechanism that forces companies to substitute hazardous chemical substances.5
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Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and FIGIEFA - Fédération Internationale des Grossistes, Importateurs & Exportateurs en Fournitures Automobiles / International Federation of Automotive Distributors and Leaseurope

4 Feb 2025 · Transformation of the automotive Sector

ETRMA urges unified EU rules to boost tyre industry competitiveness

31 Jan 2025
Topic — Consultation on a strategy to improve the single market for goods and services.
Message — The association requests sector-specific data access rules and harmonized waste standards. They advocate using EU regulations instead of directives to prevent fragmented laws.12
Why — Unified reporting and data access would lower compliance costs and drive innovation.34
Impact — Vehicle manufacturers would lose their current monopoly on valuable in-vehicle data.56
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Meeting with Paulius Saudargas (Member of the European Parliament, Rapporteur) and MUST Partners and

30 Jan 2025 · End -of-life vehicles regulation

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur)

29 Jan 2025 · End-of-life of vehicles Regulation

Meeting with Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen), Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen) and

14 Jan 2025 · The role of the automotive aftermarket in the EU Industrial Action Plan for the automotive sector

Meeting with Helena Hinto (Cabinet of Commissioner Apostolos Tzitzikostas) and Insurance Europe and

10 Jan 2025 · Introductory meeting

Meeting with Rosa Serrano Sierra (Member of the European Parliament)

18 Dec 2024 · Priorities for European Commission 2024-2029

Meeting with Raúl De La Hoz Quintano (Member of the European Parliament)

18 Dec 2024 · competitiveness

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur) and Pirelli C. SpA

17 Dec 2024 · End-of-Life Vehicles

Meeting with Valvanera Ulargui Aparicio (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and Insurance Europe and

16 Dec 2024 · Exchange with the Independent Service Providers (ISPs) on the upcoming Commission Initiatives that will support the whole sector competitiveness, including the Competitiveness Compass, the Clean Industry Deal and the Automotive Industry Plan

Response to Digital Product Passport (DPP) service providers

10 Dec 2024

The European Tyre and Rubber Manufacturers' Association (ETRMA) welcomes this call on DPP - service providers (DPP SP) requirements. Tyre manufacturers will issue DPPs for the tyres they place on the European market. As such, they will have to entrust the copies of the issued DPPs to a DPP service provider. In addition, the Tyre industry has created in 2022 a data space, the GDSO to whom ETRMA is Associated, to allow tyre lifecycle events traceability and data exchange across the tyre circular economy. GDSO could play the role of DPP SP for the tyre industry. The European Tyre and Rubber Manufacturers' Association (ETRMA) supports the Commissions efforts to create a harmonized, fair, and secure framework for DPP service providers (DPP SP), recommending to: 1. consider existing initiatives like the tyre industry data space, GDSO, in the definition of DPP SP roles, as well as Data Governance Act requirements for trustable data intermediation services, 2. require self-conformity assessment to CEN/CENELEC DPP standards for the management of DPP by DPP SP, 3. require ex-ante cybersecurity certification of DPP SP to manage the business sensitivity of DPP back-up copies at the right level, especially for serialized product identification, 4. guarantee a fair, transparent and affordable financing mechanism of DPP services that is inclusive and future-proof over the products lifetime, 5. provide a clear roadmap with sufficient time for implementation to cope with the complexity of the system and the number of remaining open questions.
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Meeting with Jens Gieseke (Member of the European Parliament, Rapporteur) and Continental AG and Henkel AG & Co. KGaA

20 Nov 2024 · Altfahrzeuge-Verordnung

Meeting with Elena Sancho Murillo (Member of the European Parliament)

6 Nov 2024 · Relevant issues to the ENVI Committee

Meeting with Elena Sancho Murillo (Member of the European Parliament)

6 Nov 2024 · Relevant issues to the ITRE Committee

Tyre industry urges delay in new emission verification procedures

10 Oct 2024
Topic — Procedures for verifying the CO2 emissions and fuel consumption of heavy-duty vehicles in-service.
Message — ETRMA proposes excluding tyres from the act or aligning tolerances with existing standards. They also request a transition period and a reduction in the number of tests required.123
Why — Aligning the rules would lower compliance costs and prevent existing products from failing tests.45
Impact — Truck manufacturers face higher reported emissions data because of increased technical margins for tyres.67
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Meeting with Javier Moreno Sánchez (Member of the European Parliament) and EuroCommerce

17 Sept 2024 · European Trade Policy

Meeting with Nicolo Brignoli (Cabinet of Executive Vice-President Valdis Dombrovskis)

18 Jun 2024 · Meeting to present the European Tyre and Rubber Industry’s Manifesto

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Insurance Europe and

4 Jun 2024 · Discussion on preparation of delegated act on conditions to access data for repair and maintenance activities

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

21 May 2024 · A resilient and sustainable European industry - priorities next legislative period

European tyre industry urges EU to avoid double regulation

4 Dec 2023
Topic — This consultation revises EU rules on vehicle design, recycling, and end-of-life management.
Message — The association wants tyre requirements managed under ecodesign laws rather than vehicle regulations to prevent overlapping rules. They call for consistent definitions to ensure retreaded tyres are not treated as waste.12
Why — This provides the industry with regulatory certainty and supports the commercial tyre retreading market.3
Impact — Existing recycling programs lose millions in revenue due to inconsistent fee collection systems.4
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Meeting with Nicolas Schmit (Commissioner) and

5 Jun 2023 · The upskilling/reskilling challenges in the automotive sector in order to ensure a just transition across the ecosystem

Response to Revision of the Directive on Driving Licences

31 May 2023

The European Tyre and Rubber Manufacturers Association (ETRMA) welcomes the Road Safety package proposal and in particular the modernised driving licence rules to make EU roads safer and simplify everyday life. Our position is attached.
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Meeting with Matthias Ecke (Member of the European Parliament, Shadow rapporteur for opinion)

3 May 2023 · Euro 7

European Tyre and Rubber Manufacturers Association flags taxonomy error

27 Apr 2023
Topic — The EU is establishing a classification system for environmentally sustainable investments.
Message — The organization identifies a technical error regarding automotive category references. They state the draft incorrectly cites tyre labeling rules.12
Why — This correction helps the industry avoid confusion regarding technical compliance requirements.3
Impact — Financial stakeholders may face reporting difficulties due to incorrect legislative references.4
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

15 Feb 2023 · In-vehicle data

Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur) and Volkswagen Aktiengesellschaft

15 Feb 2023 · Austausch zur EU-Verkehrspolitik

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

10 Feb 2023 · access to in-vehicle data legislation

Tyre industry urges Euro 7 alignment with global UN standards

9 Feb 2023
Topic — This consultation concerns new, stricter emission standards for road vehicles across Europe.
Message — They want EU rules to match international UN testing methods and limits. The group suggests applying standards to all new tyres for faster impact. They propose measuring wear based on vehicle weight to protect heavy tyres.123
Why — Using international standards would prevent regulatory duplication and help manufacturers compete internationally.45
Impact — Non-compliant international competitors lose their advantage if strict market surveillance is enforced.6
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European tyre industry seeks cybersecurity rules for aftermarket parts

20 Jan 2023
Topic — Proposed regulation establishing mandatory cybersecurity requirements for products with digital elements.
Message — The association requests that aftermarket systems are clearly covered by the regulation. They recommend defining criteria for critical automotive products to ensure safety. They also call for harmonized rules with international vehicle standards.123
Why — Standardized certification would prevent vehicle manufacturers from blocking third-party digital tyre services.4
Impact — Vehicle manufacturers lose exclusive control over digital connections to their vehicles.5
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Response to Creation of the Common European Mobility Data Space

6 Dec 2022

The European Tyre & Rubber Manufacturers Association welcomes the Commissions initiative to come up with the creation of the common European mobility data space. The feedback is attached.
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Response to European Critical Raw Materials Act

25 Nov 2022

See the attached file
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ETRMA Urges Flexible Hazard Rules For Rubber Mixtures

17 Oct 2022
Topic — This consultation concerns the addition of new hazard categories to chemical classification rules.
Message — ETRMA requests flexible classification rules that account for chemicals trapped within rubber matrices. They also seek specific guidance and longer transition periods for mixtures.123
Why — Tailored rules would prevent rubber products from being inaccurately labeled as hazardous mixtures.4
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Meeting with Thierry Breton (Commissioner) and

16 Jun 2022 · Data Act ; in-vehicle data

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Insurance Europe and

10 Jun 2022 · Prep meeting for meeting with Commissioner Breton on 16/6

Tyre industry urges specific rules for vehicle data access

12 May 2022
Topic — The Data Act establishes a framework for cross-sectoral data access and use.
Message — The association supports the right of users to share data with third parties. They request a specific regulation for the automotive sector to standardize data access. This should include an independent authority to govern access rights.12
Why — Sector-specific rules would prevent vehicle manufacturers from unfairly blocking access to valuable technical data.3
Impact — Vehicle manufacturers lose their ability to act as exclusive gatekeepers of in-vehicle data.4
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

12 Jan 2022 · Recapitulation of the ambitions and discuss next steps and actions to be taken

Response to Measures to reduce microplastic pollution

10 Jan 2022

ETRMA welcomes the opportunity to provide our comments on the upcoming measures aimed at reducing the presence of unintentionally released microplastics. The tyre industry has been collaborating over the last 15 years through various research projects to developing a better understanding of the fate and possible effects of particles generated during normal tyre use and wear, through research projects performed under the umbrella of the World Business Council for Sustainable Development (WBCSD) Tyre Industry Project (TIP) . Tyre and road wear particles (TRWP) are a mixture of approximately 50% tyre tread fragments and 50% elements from the road surface (mainly minerals and road dust). A 2010 publication by Kreider et al . provides a characterization of the tyre and road wear particle as generated under controlled laboratory conditions. The study characterized the density and size of TRWP: • Density: The density of TRWP, aggregated by tyre tread rubber and embedded minerals and other constituents of road dust, is estimated to be around 1.8 g/cm3. • Size: TRWP has a size range from 1-350 microns (a micron is one-thousandth of a millimetre), the most common – the median value – being between approximately 80 and 100 microns. These characteristics determine transportation and fate in the environment and differentiate TRWP from other particles covered by the Call for evidence. The European Tyre Industry is committed to actively pursue the work towards a reliable & representative test method, filling knowledge gaps through robust science and supporting the TRWP Platform; ETRMA Calls on the legislator for ex ante and in-depth assessment of most effective measures for prevention and mitigation of TRWP and will continue to cooperate and dialogue with the EU Institutions and relevant stakeholders. For more details of the Industry action plan, please see the attached document.
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Response to Extension of scope of procedures for determination of CO2 emissions of heavy-duty vehicles

9 Nov 2021

ETRMA welcomes the publication of the Draft act amending Regulation (EU) 2017/2400 as regards the determination of the CO2 emissions and fuel consumption of medium and heavy lorries and heavy buses and the introduction of electric vehicles and other new technologies. ETRMA would like to amend two points for keeping references up-to-date. In this respect, please consider the attached document. Thank you.
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Meeting with Thierry Breton (Commissioner) and

27 Oct 2021 · Data

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

20 Sept 2021 · Microplastics, Euro 7, general safety regulation

Response to Requirements concerning data to be made available to the Commission and third parties for automotive market surveillance

19 Jun 2021

The European Tyre & Rubber manufacturers Association represents 14 global tyre companies manufacturing in Europe from 93 tyre plants in 21 Members States. The Tyre Industry is subject to type approval requirements both as Original Equipment suppliers as well as Replacement Market suppliers. The Tyre Industry is a key contributor to the European automotive value chain. The European Tyre Industry reviewed the draft regulation on Market Surveillance draft Implementing Act, and its comments are summarized in the document attached, for due consideration by the European Commission Services.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

31 May 2021

ETRMA views on the Inception Impact Assessment on the revision of CLP Brussels, 31st of May 2021 Rubber is a versatile material flexible and resistant used for many applications. The majority of the industry producing from rubber articles in Europe is organized in two main blocks. The most visible and known is Tyres present in vehicles. The other is the General Rubber Goods (GRG) sector whose main application fields can be summarized as follows: the automotive and transport sector 63%, the industrial appliances sector 8-10%, the household applications 10% , energy / offshore 10-12% , food contact materials 4-5% and leisure 1-2%, . The majority of the GRG sector are small medium size companies, SMEs. The use of chemicals in the tyre and rubber industry is of outmost importance due to the necessary quality, safety and performance of the products. To give an example of the complexity, there are more than 1600 substances registered under REACH for its use in the sector of rubber manufacturing. The strong and robust chemical regulatory framework in Europe has placed the rubber industry at the foreground on chemical compliance, and strengthened its position worldwide. The producers of rubber articles, as downstream users of substances and mixtures to produce rubber goods, are in a unique position in the value chain. Rubber articles are in many cases part of more complex articles serving to a large variety of sectors. This central position in the value chain boosts the industry importance and knowledge on legislation on products, articles, chemicals and mixtures. Since its approval in 2006, the REACH legislation has evolved, from focusing on registration and evaluation of substances, to define restrictions and requirements on products in articles. An evolution, which has been emphasized even more in the recent chemical strategy for sustainability, placing in the front row the use of substances in articles. This evolution is demanding an adaptation of rubber sector to new regulatory requirements at an extreme fast pace, in an environment where competitiveness and global trends already pressure the sector . ETRMA would like to share the following considerations and points of attention in the coming CLP revision It is positive to increase the information on hazardous substances across the value chain with the inclusion of new hazard classes. However, the inclusion should aim to be a global harmonization with affordable, robust and agreed tests and methods. Proportionate transition periods for setting new hazard classes are essential to overcome the impacts on access low tonnage specialty chemicals of a deviation of the Global Harmonized System. The criteria to classify mixtures should remain affordable and adaptable to all shapes, sizes, textures and matrices of chemistry Digitalization of safety data sheets, labels of other requirements should be free open-access and user-friendly. More information available at the attached document
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

31 May 2021

ETRMA views on the Inception Impact Assessment on the revision of REACH Brussels, 28th of May 2021 Rubber is a versatile material flexible and resistant used for many applications. The industry producing rubber in Europe is organized in two main blocks. The most visible and known is Tyres present in vehicles. The other is the General Rubber Goods (GRG) sector whose main application fields can be summarized as follows: the automotive and transport sector 63%, the industrial appliances sector 8-10%, the household applications 10% , energy / offshore 10-12% , food contact materials 4-5% and leisure 1-2% . The majority of the GRG sector are small medium size companies, SMEs. The use of chemicals in the rubber industry is of outmost importance, to mention there are more than 1600 substances registered under REACH for its use in the sector of rubber manufacturing. The strong and robust chemical regulatory framework in Europe has placed the rubber industry at the foreground on chemical compliance, and strengthened its position worldwide. The producers of rubber articles, as downstream users of substances and mixtures to produce rubber goods, are in a unique position in the value chain. Rubber articles are in many cases part of more complex articles serving to a large variety of sectors. This central position in the value chain boosts the industry importance and knowledge on legislation on products, articles, chemicals and mixtures. Since its approval in 2006, the REACH legislation has evolved, from focusing on registration and evaluation of substances, to define restrictions and requirements on products in articles. An evolution, that has been emphasized even more in the recent chemical strategy for sustainability, placing in the front row the use of substances in articles. This evolution is forcing an adaptation of the rubber sector to new regulatory requirements at an extreme fast pace, in an environment where competitiveness and global trends already pressure the sector . ETRMA would like to share the following considerations and points of attention in the coming REACH revision Access to raw materials could be hampered by too demanding registration requirements Rethinking the authorization tittle for REACH in favor of other risk management measures would secure a level playing field for EU manufacturers of articles without compromising safety. Any extension of the generic approach shall be risk based and support the EU manufacturing industry, essential to boost modern society Digitalization of safety data sheets should be free open-access and user-friendly. A level playing field can only be achieved with homogenous and continuous enforcement across EU member states More explanations in the attached document
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Meeting with Thierry Breton (Commissioner) and

16 Mar 2021 · The tyre industry

Response to Standardised access to vehicle information for on-board diagnostics, repair and maintenance and security features

3 Feb 2021

European tyre manufacturers are well-positioned to help the automotive sector as well as the policymakers to meet the new safety, smart and sustainable mobility objectives. The technologies that allow connected vehicles to assess and execute routines that were only possible within dedicated workshops, extend further to a new set of analyses that we generally address as “predictive maintenance”: https://ec.europa.eu/growth/tools-databases/dem/monitor/tags/predictive-maintenance The EU Commission already a few years ago was addressing in a study this new domain as “identifying the correlation between multi-sourced data and specific types of failure and repair work''. https://ec.europa.eu/growth/tools-databases/dem/monitor/sites/default/files/DTM_Autonomous cars v1.pdf The benefits of predictive maintenance are multi-fold. Lower repair frequency and overall maintenance costs are direct benefits, as customers can get immediate alerts before the failure occurs and minimize repair work. These alerts are possible in case of tyres thanks to proprietary algorithms that would need data at a high frequency and quality. The same is possible for many other components subject to tear and wear during the vehicles’ life. https://ec.europa.eu/growth/content/service-and-predictive-maintenance-contracts_nn#:~:text=Predictive%20maintenance%20uses%20sensors%20and,predict%20failures%20before%20they%20occur.&text=Technological%20advances%20such%20as%20M2M,services%20such%20as%20predictive%20maintenance. In this regard, predictive maintenance i.e. prognostics, is a key element for the whole automotive ecosystem to ensure safety at first place and for this reason we would appreciate the Commission to reflect our proposal into the legal text being adopted.
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Response to Revision of EU rules on food contact materials

29 Jan 2021

Industry needs a unique internal market for rubber materials in contact with food. ETRMA welcomes that the announced new EU specific rules will address non-regulated products and it is ready to support and contribute to the development of the new EU specific rules over the coming years. The EU industry of General Rubber Goods (GRG) includes approximately 6000 companies, most of them SMEs. EU production is estimated around 2.3 million tons of GRG. The food contact materials and drinking water sector accounts for 2% of the total production sector. Rubber uses in food contact material include, the following applications: food transportation (conveyer belts, hoses, tubing, rotating transport rollers and rolling mills); food handling (gloves), machinery components (seals, gaskets, hoses, flexible connectors and diaphragm/butterfly valves); plate heat exchangers and general seals (used in machinery and storage vessels);sealants (can and bottle seals/closures); baby feeding (teats and breast caps); household appliances (including seals in pressure cookers), etc. We welcome the publication of the Inception Impact Assessment of the Revision of EU rules on food contact materials (FCMs), particularly the announcement to address the situation of materials for which there are no EU specific measures and they remained subjected to national measures. Indeed, rubber materials in contact with food suffer from different implementation measures of the FCM regulation across EU Member States. Several EU Member States - France, Germany, Italy, The Netherlands or Spain - have adopted specific regulations for rubber in food contact materials. The content of the positive lists and the provisions varies from country to country. This situation leads to obstacles for the internal market and additional burden for companies. We estimate the costs to certify a rubber FC product at several thousands of euros for each Member State. In addition, compliance and enforcement of the current regulation is poor and not fully implemented, risking that non-compliant products are on the market. This compromises the health and the safety of consumers, and threats the level playing field for those that fully comply. ETRMA would like to share the following considerations: ( see the document attached)
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Contribution of tyres to climate change mitigation as enabler of clean mobility The European tyre industry has been working to provide the transport sector with tyres that contribute to enabling clean and safe mobility. Mainly because of their rolling resistance (RR), tyres account for up to 30% [HDVs], 20% [Cars] and 10% [LDVs] respectively of the fuel consumption of vehicles (e.g. when tyres are properly inflated and maintained). The EU tyre industry has taken a proactive approach in reducing CO2 emissions through new and advanced tyre technologies whilst promoting road safety. This engagement was reflected by the industry’s efforts to meet the legal requirements of both the tyre type approval performance thresholds (since 2012) and tyre labelling (whose review was concluded earlier in 2020). The European Commission estimated that “by choosing a tyre that is in the top class for energy efficiency, and thereby performs the best, energy consumption by 2020 will be up to 45 TWh per year lower than would have been the case without the rules. That is equal to saving roughly 15 million tons of CO2 emissions per year by 2020. Thanks to rapid developments in technology, partly driven by the motivation to appear in the top performing classes, the annual savings across the EU resulted in higher savings at roughly 77 TWh. These energy efficiency measures will thus reduce annual CO2 emissions by close to 25 million tons by the end of 2020.” On top of implementing these regulatory requirements, already in 2016, the European tyre industry committed to further reduce the rolling resistance coefficient of HDV tyres by 1% per year until 2030. Taking into account the forecasted increase by 18% of road transport, this will result in removing from the European roads the equivalent of 81,000 40 tonnes trucks every year. To ensure the full impact of the progress made by the industry so far and particularly to exploit fully the benefits of the tyre labelling regulation, there is the need to support the market uptake of best graded-tyres for both private consumers and public authorities, and both on their fuel efficiency and safety criteria ratings. The need to “Support the market take-up of fuel efficient, safe and low-noise tyres” Including tyres in the sustainability taxonomy means supporting clean mobility In this context, ETRMA believes that certain tyres should be recognized as products contributing to climate change mitigation. As explained above, their benefit is easily identifiable and quantifiable through the official EU tyre label. Unfortunately, as the uptake of these best graded tyres remains low (tyres with Rolling Resistance and Wet Grip class B&B remain, in 2020, less than 2% of the Market ), there is the need to further incentivize their uptake, including supporting investments in the sector . In this context, ETRMA believes that introducing such top [or best] graded tyres in the taxonomy would be beneficial to the market uptake of such tyres and, in turn to achieving the objectives of this legislation. It should be noted however, that – since tyres are first and foremost a safety product and given that there is a trade-off between rolling resistance and wet grip – rolling resistance should not be singled out as a criteria for the purposes of Annex I, but it should always be accompanied by at least comparable results in terms of safety. This is why all amendments below always pair these two performances. Even if not strictly relevant in “substantially contributing to climate change mitigation”, wet grip remains key to ensure that European transport is both clean and safe. ETRMA believes tyre’s external noise level requirements are not relevant in the context of this delegated act, as the noise performance does not directly relate with climate change mitigation, for ex. to the reduction on energy efficiency during tyre use. The following amendments are suggested to the proposed text: (see document attached)  
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Response to Revision of EU legislation on end-of-life vehicles

19 Nov 2020

The European Tyre & Rubber Manufacturers’ Association (ETRMA) and its members count around 4.300 companies in the EU, employing directly 360.000 people. We have strong presence in the EU and candidate countries with 93 tyre-producing plants and 17 R&D centres. EU production is estimated in 5.1 million tons of Tyres and 2.3 million tons of General rubber goods. Tyres are essential to the functioning of multiple elements within the mobility system – they have an important role in road safety, they can contribute to CO2 reduction from transport as well as to the optimisation of other performances (e.g. traffic noise), and through more recent technological developments around tyre’s digitalisation they can enable predictive maintenance and reduce traffic congestion, amongst other benefits. For General rubber goods, the automotive sector accounts for 65% of the production including, wiper blades, seals, air and radiator hoses and seatbelts as their main components. Rubber is resistant to several chemicals used in a car and can withstand the heat and cold. Rubber is also used to make gaskets used in cars, which help create a seal so there is no leak when fluids are flowing through junction areas in a pipe or a hose. The current ELV directive considers the vehicle frame. The scope rightly does not include tyres. The management of end of life tyres –once removed from the ELVs – is carried out through national EPR schemes since late 90’s. This approach has been successful so far in collecting and recycling tyres; two-thirds of end of life tyres arising under EPR regime. There are 23 European Producers Responsibility Schemes in Europe and the collection and treatment rate of Tyres have reached up to 92% on 2018 . The future revision of the ELV directive shall avoid a change in the scope that hampers and affects the current End-of-Life Tyres, ELT, collection scheme and successful value chain. We signal the need to integrate the ELV directive into the targets and goals of the EU Green Deal and the Circular Economy Actin Plan. In this sense, requirements to include recycled material in the automotive will be investigated in the revision ELV directive. We endorse the principle and endeavours towards recyclability/up-cyclability. However, when it comes to minimum recycled content in tyre production, technologies would still need substantial development and maturity to meet not only demands of the circular economy, but also essential technical performances of tyres. The same applies for general rubber goods. The type of rubber used in each good adapts to the final application. Its function is what defines whether a recycling solution can be used. For instance, it is possible to use micronized rubber powder to substitute a percentage of butyl rubber and vulcanized rubber in some applications. However, this is not a practice that can be extended to every rubber good for every performance. Therefore, the establishment of a recycled content for GRG goods is still premature and not possible as a general rule. The ELV directive revision shall also address to the new trends in automotive, to mention the increase in electric vehicles and need to address digital data treatment. ETRMA is ready to contribute and help shape the new era of ELV. We offer our support and contribution in the coming stakeholders’ consultation and public consultations.
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Response to Sustainable Products Initiative

10 Nov 2020

The European Tyre & Rubber Manufacturers’ Association (ETRMA) and its members count around 4.300 companies in the EU, employing directly 360.000 people. ETRMA tyre company members represent 59% of the global tyre sales. We have strong presence in the EU and candidate countries with 93 tyre-producing plants and 17 R&D centres. The EU industry of General Rubber Goods, GRG, includes approximately 6000 companies, most of them SMEs. EU production is estimated in 5.1 million tons of tyres and 2.3 million tons of GRG. Tyres are essential to the functioning of multiple elements within the mobility system – they have an important role in road safety, they can contribute to CO2 reduction from transport as well as to the optimisation of other performances (e.g. traffic noise), and through more recent technological developments around tyre’s digitalisation they can enable predictive maintenance and reduce traffic congestion, amongst other benefits. Tyres are high-tech engineered articles, requested to perform under extreme conditions without compromising key environmental performances (e.g. energy efficiency) nor the key role of tyre on road safety. Therefore, an element of tyre’s sustainability is the equilibrium between its environment- and safety-related performances and attributes. Additionally, present and expected trends in tyre´s use are linked with Tyre-as-a-Service (TaaS) and more broadly with Mobility-as-a-Service. On the one hand, retreaded (i.e. remanufactured) tyres for heavy-duty vehicles are often part of an integrated connected services model. On the other hand, “smart tyres” (e.g. tyres with digital attributes) as part of “smart mobility” and in-vehicle data ecosystems have the potential to take further the TaaS model and expand the access to high quality products. TaaS can improve the sustainability footprint of tyres during use, e.g. drivers obtain more real-time information about performances related, but not limited to, fuel efficiency safety. At the same time, TaaS can ensure an optimal interaction between the elements that have a high impact on sustainable mobility, e.g. interactions amongst vehicles, drivers, and infrastructure. All these aspects related to the use and placing on the market of tyres must be taken into account when defining EU’s Sustainable Product Policy (SPP). ETRMA believes that the SPP offers an excellent opportunity to capitalise on existing technologies, best practices and rules at the tyre sector, which could find wider implementation to serve the purposes of a circular economy. In view of the ongoing SPP Inception Impact Assessment, ETRMA would like to make the following recommendations – both in relation to key principles in designing the SPP, and to aspects related to tyres and rubber goods.   I. General Recommendations for SPP: 1. The emerging SPP initiative shall strike a balance among environmental, social - including safety - and economic objectives for products and services. This is particularly needed when considering sectorial specificities. 2. The SPP shall be built on sector-by-sector robust assessments and approaches. 3. Effective enforcement and market surveillance are essential for existing and future rules. 4. Incentives at points of sale and through green public procurement for products and services 5. Homogeneity of the EU actions – for both rules and for incentives – is crucial for the integrity and effective functioning of the Single Market 6. Implementation as much as possible of proven, relevant international standards ETRMA full answer in the document attached
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Response to Review of the Construction Products Regulation

19 Aug 2020

The European Tyre & Rubber Manufacturers Association (ETRMA) and its members count around 4.300 companies in the EU employing directly 360.000 people. ETRMA tyre corporate companies represent globally 59 % of world sales and 7 out of 10 world leaders are our Member. We have strong presence in the EU and candidate countries with 93 tyre-producing plants and 17 R&D centres. Several general rubber goods are covered under the scope of the construction products regulation, for instance joints and bearing pads for bridges. The use of rubber goods for construction products is essential to secure the safety of civil structures. The use or rubber goods in construction works usually covers specific niche applications, producers are highly specialised SMEs. Many applications of End-Of-Life Tyres derived granules are under the scope of the construction products regulation. For instance, moulded goods such as tiles or carpets in sport facilities, asphalts, and crumb rubber granules used as infill material in artificial grass. ETRMA believes that the CPR needs to adapt and enhance its role to boost the use of recycled materials. Adaptions to the CPR shall bear in mind the green deal objectives and the need to move towards a circular economy society. In the view of supporting the Inception Impact Assessment, ETRMA would like to highlight the following: • The CPR is needed in order to secure a level playing field and a single market of construction goods across Europe. There is no need to change or derogate de regulation. • The CPR needs to enhance its scope to promote the green deal and the circular economy goals, particularly facilitating the access to the market in equal condition of recycled goods in construction works. • The application of Basic requirement 7 related with the environmental performance of products needs to be harmonised across Member States. The CPR should enforce the EU single market and prevent the need for industry to develop different environmental declaration for each EU Member State. The Commission should coordinate and invest resources in supporting harmonization. • The standardization process of harmonised standards shall take into account the specificities of each sector. • Clarification on the scope of the CPR regarding groups of products is required to avoid double regulation, this is critical for rubber goods covered by the drinking water directive and the construction products directive. • Further, the interface between chemicals, products and waste must also be addressed in the CPR. For instance, depending on the situation, ELT derived rubber granules are mixtures under REACH, waste under the Waste Framework Directive and construction products under the CPR. Adding clarify on the scope of each regulation is key to boost recycling of ELT derived rubber. • Any guidelines, technical document or related that aims to clarify the CPR should be adequately agreed and used by Member States in its local enforcement. Otherwise, guidelines are weak on clarifying aspects. ETRMA will also share its views during the public consultation on Future Options for the Review of the Construction Products Regulation.
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Response to Sustainable and Smart Mobility Strategy

29 Jul 2020

ETRMA* represents European tyre and rubber goods manufactueres - a sector that has a crucial role in moving people and goods around Europe and the world, in a sustainable manner. ETRMA welcomes the publication of the Roadmap as well as its focus to combine green and digital transitions with competitiveness and resilience. The same elements play a key role in the identified pathway for recovery published by ETRMA on 12 May, when the sector asked to prioritize the initiatives to achieve climate neutrality and digital transition, and requested a supportive and reasonable timing to the overall changing regulatory framework. In this context, ETRMA welcomes the coherent approach between the projected new transport strategy, the Green Deal and the EU COVID-19 recovery plan and is happy to contribute to this consultation and indicate ways to make the best use of existing tools to achieve these shared objectives and to indicate the gaps that need filling to deliver on such objectives. Please find the full position of ETRMA in the attached paper. *About ETRMA: The European Tyre & Rubber Manufacturers Association (ETRMA) represent nearly 4.400 companies in the EU, directly employing about 370.000 people. The global sales of ETRMA’s corporate members represent 70% of total global sales and 7 out of 10 world leaders in the sector are ETRMA Members. We have a strong manufacturing and research presence within the EU and candidate countries, with 93 tyre-producing plants and 17 R&Dcentres
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Meeting with Lucia Caudet (Cabinet of Commissioner Thierry Breton)

7 Jul 2020 · Industry outlook, recovery and decarbonisation

Response to Chemicals strategy for sustainability

19 Jun 2020

The European Tyre & Rubber Manufacturers Association (ETRMA) and its members count around 4.300 companies in the EU employing directly 360.000 people. ETRMA tyre corporate companies represent globally 59 % of world sales and 7 out of 10 world leaders are our Member. We have strong presence in the EU and candidate countries with 86 tyre-producing plants and 16 R&D centres. Rubber is a versatile material flexible and resistant used for many applications. The industry producing rubber in Europe is organised in two main blocks. The most visible and known is Tyres present in vehicles. The other is the General Rubber Goods (GRG) sector whose main application fields can be summarized as follows: the automotive and transport sector 63%, the industrial appliances sector 10% and house applications 10% sector. The majority of the GRG sector are small medium size companies, SMEs. The use of chemicals in the rubber industry is of outmost importance, to mention there are more than 1600 substances registered under REACH for its use in the sector of rubber manufacturing, even if in the individual production processes, relatively few chemicals are used. The strong and robust chemical regulatory framework in Europe has placed the rubber industry at the foreground on chemical compliance, and strengthened its position worldwide. The initiative presented by the Commission on setting a Chemical Strategy for Sustainability is an opportunity for the rubber sector. Over the last years, ETRMA has voiced industry’s view on the initiatives named in the Road Map as stakeholder. We see the proposed strategy as an opportunity to add coherence, simplicity and accuracy to the entire regulatory framework and boost rubber´s industry move towards meeting the green deal´s objectives. In order to do so, we wish to highlight the following relevant points. (see document attached) Securing a level playing field for rubber manufacturers. Substances present in products. Regulatory Management Options Analysis, RMOA, are essential to choose adequate regulations on hazardous chemicals REACH and OSH interface Better predictability = more investments to European enterprises Secondary Materials are Safe for further use
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Response to Carbon Border Adjustment Mechanism

26 Mar 2020

INTRODUCTION The European Tyre and Rubber Manufacturers’ Association (ETRMA), representing the voice of tyre and rubber goods producers in Europe, and its members are fully committed to contribute at large to the objectives of the Paris Agreement and the Climate-Neutrality objectives set in the European Green Deal. EXTENSIVE EFFORTS LED TO REMARKABLE ACHIEVEMENTS The European Tyre and Rubber Manufacturers have since more than 20 years been on the path to develop a more circular tyre and rubber economy, reduce material waste, reduce direct and indirect CO₂ emissions and develop high quality products favouring reduced CO₂ emissions during use. These are just some examples of the actions taken reaching remarkable achievements, inter alia, thanks to the fact that the Tyre industry was included in the list of carbon leakage . A PARIS AGREEMENT WIT A LEVEL PLAYING FIELD MECHANISM Recognizing that the Paris Agreement objectives have been co-signed by most industrialized countries in the world it is fair to ensure that the EU steps up its effort to influence the carbon footprint of products and services accessing the EU single market from other countries, sometimes, with a less ambitious climate action plan. Therefore, European Tyre and Rubber Manufacturers looks with interest to the Commission’s intention to establish a mechanism permitting both domestic and foreign market player to equally contribute to the effort of EU to meet the global climate objectives. Recognizing the challenges in setting a fair adjustment process ensuring these will encourage third country producers to deliver on their commitment on the Paris Agreement goal, we call upon the Commission to establish a strong dialogue with the EU stakeholders like our sector. This in the aim to develop the most efficient and fair instrument and avoiding establishing measures that could unintendedly have direct or indirect impacts on our specific sector. ETRMA The European Tyre & Rubber Manufacturers Association (ETRMA) and its members count around 4.300 companies in the EU employing directly 360.000 people. ETRMA tyre corporate companies represent 59 % of global sales and 7 out of 10 are among top 10 world leaders. ETRMA has a strong presence in the EU and candidate countries with 93 tyre-producing plants and 17 R&D centres. www.etrma.org (Please find further details in attachment to this contribution)
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Meeting with Gwenole Cozigou (Acting Director-General Internal Market, Industry, Entrepreneurship and SMEs)

29 Jan 2020 · Courtesy meeting and discuss Green Deal in general

Response to A new Circular Economy Action Plan

20 Jan 2020

CIRCULAR ECONOMY IS HIGH ON OUR INDUSTR'Y AGENDA The European tyre manufacturers believe in a future inclusive economy based on an efficient use of resources, ensuring full recovery of waste-stream at highest possible value with minimal material functionality loss, and no uncontrolled emission, driven by an innovative and sustainable market economy. IT ALL STARTS WITH PRODUCT DESIGN A long-standing design-for-reuse strategy has been implemented by the tyre industry. Aircraft tyres, truck & bus tyres, off-road/earth moving tyres and agricultural tyres are mostly designed to last more than one tread-life. Tyre casings are designed to last for several tread-lives, permitting remanufacturing of worn tyres to be fitted with a new tread, thereby extending their lifetime and significantly reducing the material and product functionality loss. Retreaded tyres lead to 70% material savings thanks to material recovery and a longer lifespan. When it comes to recycling the first and by far the most important EU policy action was the 1999 ban on tyre landfill. This action, as well as the implementation of an Extended Producer Responsibility (EPR) in many European countries, sparked an immediate creation of an available quality source of input material into the already existing, but timid, tyre recycling market. Today, the European Tyre recycling is recognized and is very successfully collecting virtually all ELTs for recycling with a 62% material recovery rate and the residual 38% as energy recovery. After 20 years, the tyre recycling market has significantly matured maintaining a strong call for a favourable regulatory environment and a dedicated support from policy makers to ensure the right measures are taken and funding granted to force technology forward. Notably, support and focus on scientific breakthroughs to reach higher valuation and less material functionality loss in the recycling of vulcanized rubber is crucial to close the loop. Today, the reuse of tyre derived secondary raw materials in the manufacturing of new tires is limited by physics, but remains a vision and a target for the industry. Dedicated industry work on end-of-life tyre management and support to recycling processes, ELT-derived materials have been characterized and standardized. ETRMA and its members are engaged in these processes at multiple levels and strive together with the recyclers to foster a sustainable development of recycling processes delivering high value secondary raw-materials, with the lowest possible material functionality loss, in an industrial symbiosis perspective. POLICY ACTIONS MATTERS FOR THE TYRE CIRCULAR ECONOMY The European tyre industry recognizes that although most circular economy actions have to be taken by the industry and consumers, regulators and policy makers have a significant role to play. The European Institutions and Member States could play an important role in supporting measures driving consumers towards existing tyre products favouring the circular economy objectives. For instance, several steps have been taken by the industry to facilitate repair and remanufacturing, increasing tyre lifetime and reducing environmental impact. Premium truck tyres, for example, are designed to be retreaded up to three times leading to 70% material savings thanks to material recovery and a longer lifespan. ETRMA CALLS FOR: • A favourable regulatory environment and dedicated support from policy makers to ensure the right measures are taken and funding is granted to support and drive technology forward, • Support and focus on scientific breakthroughs to reach higher valuation and less material functionality loss in the recycling of vulcanized rubber is crucial to close the loop, • Supporting measures by the European Institutions and Member States to drive consumers towards retreaded truck tyres, which favours the objectives, set in a circular economy. WWW.ETRMA.ORG
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Response to Driving licence legislation ex-post evaluation

10 Sept 2019

The European Tyre and Rubber Manufacturer’s Association (ETRMA) welcomes the timely revision of the Driving License legislation, which provides an excellent opportunity to promote an increasingly eco-friendly and safe driving behaviour on European roads. The tyre industry has been closely cooperating with the European Commission to establish the Third Driving Licence Directive , which recognised the importance for drivers to understand the fitting, correct use and care of tyres. For a future Directive, ETRMA calls for a reinforced focus on environmentally friendly driving practices in the driving licence training requirements. Concretely, provisions regarding environmentally friendly driving could be included in ANNEX II, Theory Test, point 2.1.2. For the full ETRMA contribution, please see the file in attachment.
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Response to European Partnership for Safe and Automated Road Transport

27 Aug 2019

The European Tyre & Rubber Manufacturers Association (ETRMA) has been a committed supporter of clean, safe and connected mobility solutions in Europe. In this regard, the tyre industry welcomes the European Commission’s initiative to establish a long-term framework for research and pre-deployment programmes for cooperative, connected and automated mobility (CCAM) across the EU. In terms of the tyre industry’s activities in connected and automated mobility, we have been a keen supporter of the European CCAM agenda and research policy, for instance through our participation in the European Commission’s Single Platform for CCAM. Furthermore, tyre manufacturers are constantly innovating with the vision that tyres and mobility services will become an integrated capability of the connected and automated vehicle itself in the future In order to maximise the efficiency for implementing a joint European vision for R&I activities, ETRMA supports Option 2, an ‘Institutionalised partnership’ as the right framework for this mechanism. The tyre industry has identified the following benefits stemming from Option 2: • Inclusiveness, level-playing field and fairness: Actors across the mobility industry, the academic sector and public authorities will need to cooperate to build the necessary ecosystem to enable and foster innovation and competition in the field. Therefore, ensuring the highest possible level of diversity amongst partners will help coordinate future actions in a more impactful manner and at a significant scale. In this regard, an Institutionalised partnership would allow for a wider range of interested stakeholders to contribute to R&I projects and access EU funding. Furthermore, it will intensify the exchange and reuse of results, thus the efficiency of efforts will also increase. This approach would safeguard fairness and create a level-playing field amongst actors with different capacities in the field of mobility. • Maximising synergies: R&I efforts in CCAM need to go hand in hand with enhanced road safety and healthy environment while also contributing to maintaining the EU industry leadership in this field. Option 2 would foster cooperation and maximise synergies amongst various segments of the mobility system and different sectors in the value chain. In order to ensure timeliness, flexibility and efficiency, the following elements need to be prioritised when establishing Option 2: • A Reasonable timeline needs to be clearly determined in order to avoid delays, gaps and inefficiencies during the implementation of the partnership, which could hamper the deployment of CCAM on European roads. • A clear roadmap for the partnership needs to be defined beyond the mentioned objectives, commitments, KPIs and outputs in order to make sure that the actions are sufficiently concrete and impactful. Since CCAM is a vast domain, priorities shall be clearly set prior to the launch of the partnership.
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Response to Towards the future Generalised Scheme of Preferences legal framework granting trade advantages to developing countries

10 Jun 2019

The European Tyre & Rubber Manufacturers Association (ETRMA) and its members count around 4.300 companies in the EU employing directly 360.000 people. ETRMA tyre corporate companies represent globally 59% of world sales and 7 out of 10 world leaders are our Members . We have strong presence in the EU and candidate countries with 86 tyre-producing plants and 16 R&D centres. ETRMA would like to take the opportunity of the publication of the GSP Inception Impact Assessment to contribute to the preparatory work of the Commission towards the Review of the current GSP Regulation. In June 2017, ETRMA had already submitted its comments on the Mid-Term Evaluation of the EU's GSP and, since then, the preoccupations of the industry have not changed: there is the need to update the graduation system based on HS8 level, rather than at GSP Section level. Full comments are attached.
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Response to Commission Regulation amending Annex XIV to REACH

3 May 2019

ETRMA, The European Tyre & Rubber Manufacturers Association, urges the European Commission to exclude ADCA from the proposed list of substances for inclusion in Annex XIV of REACH • ETRMA requests the European Commission to set all the necessary steps to establish an Occupational Exposure Limit value at European Level. • ETRMA calls the REACH Committee to support the exclusion of ADCA from Annex XIV. ADCA is a blowing agent that decomposes at approximately 200°C during manufacturing of rubber products (if activators present, the temperature could be lower). The decomposition of ADA creates homogeneous microcells in the rubber matrix which allows to achieve low densities products without compromising other key proprieties like flexibility, resistance, acoustic and heat exchange properties. ADCA is needed and appreciated in the production of rubber for first the homogeneity of the microcells produced but also for its high decomposition threshold, and good gaseous yield. Traces of unreacted ADCA in quantities below < 0.1% might remain. Those reaming particles are always strongly bounded inside the rubber matrix and consequently are not bioaccessible during the normal use of articles. The potential risk of using of ADCA is then strictly limited to industrial sites. At rubber manufacturing places ADCA´s exposure is duly controlled by the risk management measures in place through our guidance on safe use of ADCA published in 2015 and signed by major users. The key points introduced in the guidance are: • The use of non-dust forms such as pellets, • The introduction of close systems and facemask during the process step of handling bags, weighting and mixing. Risk management measures in place to control worker’s exposure have proven effective to control the potential risk the substance may pose for workers. The measured concentration of ADCA in air before personal protective equipment are 10 times below the UK´s national Occupational Exposure Limit of 1 mg/m3. Setting an European Occupation Exposure Limit under the Chemical Agents Directive 98/24/EC, will secure that the current available Risk Management measures in place are applied across all EU countries. The inclusion of an Occupation exposure limit under the CAD is a procedure that could be concluded in less than 3 years if there is a truth willingness to do it by the European Commission. Inclusion ADCA in annex XVII of REACH, by establishing a maximum Environmental Reference Value to be met at workplaces – as done at Entry 71 of Annex XVIII of REACH - can achieve a similar protection for workers. Including new entries in Annex XVII is a process that can be completed in less than 2.5 years. The European Commission proposal of including ADCA in Annex XIV of REACH Regulation (EC) No 1907/2006 to force the use of substitutes is impossible to achieve by rubber producers. Research on ADCA substitutes over the last years has been unsuccessful for rubber producers. Manufacturers of rubber products using ADCA will irremediably be forced to apply for an authorization for the use of ADCA, an expensive, tedious and uncertain process, which only grant access for a limited period, if granted (see affair n T-837/16, ECLI:EU:T:2019:144). It will create a loss in turnover in the rubber industry of 473 million euros, compromising more than 1700 jobs and hampering the production of more than 2.6 million tonnes of general rubber goods in Europe. ADCA inclusion in Annex XIV will prone the delocalization of investments and resources outside Europe For more information find the attached document
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Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

12 Feb 2019 · Tyre labelling

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

12 Feb 2019 · Assessment of the revision of the tyre labelling regulation

Response to Revision of the ETS State aid Guidelines

16 Jan 2019

- Comments on the consultation process ETRMA, the European Tyre and Rubber Manufacturers' Association, welcomes the extensive public consultation foreseen by the European Commission and the targeted consultation of stakeholders and Member States. For the sake of transparency and for providing regulatory certainty to the relevant sectors, we invite the Commission to foresee also stakeholders workshops to explain the process and receive feedback before starting the sector specific consultation. In particular, the questionnaire for the targeted consultation should be presented well in advance to the industrial sectors and they should have the possibility to comment before the questionnaire is finalized in order to ensure the questionnaire covers all relevant aspects for a given sector and gives the interested sectors the appropriate time to contribute. The draft impact assessment should also be published ahead of time and be subject to public consultation. - Objectives and policy options The Roadmap misses to clarify better which are the policy options that the Commission intends to consider in the impact assessment. In particular, when referring to the “more targeted list" that "would have to be established based on the economic situation of the relevant sectors”, it is not clear whether the Commission intends to use the Carbon Leakage list for the EU ETS phase IV as a starting point and then further restrict it with more targeted criteria. Therefore, it is not clear if being a sector listed on the Carbon Leakage list is a precondition to apply and be eligible for the compensation of indirect ETS costs. This clarification should be provided at the earliest stage of the consultation process. The inception paper also rightly set as objective the need to preserve the incentives of the EU ETS for a cost effective decarbonisation of the economy, incentivising energy efficiency measures. ETRMA fully agrees with these objectives and calls on the Commission to avoid inconsistencies and contradictions between the criteria set and the objectives. In particular, a carbon leakage criterion giving a higher weight to the energy intensity of a sector rather than the exposure to the extra-EU competition (trade intensity) would hinder the most virtuous sectors in terms of emissions. The tyre sector reduced the CO2 emissions by 20% in the last decade, and this is one of the main reasons why it has been excluded from the Carbon Leakage list 2021-2030 and will not being granted the compensation of direct ETS costs. The Commission should adopt a more comprehensive approach when defining the criteria for the compensation of indirect costs and should not limit itself to the same criteria of the carbon leakage list that are not targeted to the objective of the State Aid Guidelines. In particular, the criteria defined should give the right weight to the trade intensity and the exposure to competition with extra-EU countries. The eligibility criteria should allow sectors to be assessed fairly on a qualitative base taking into account all relevant parameters to demonstrate the risk of carbon leakage due to ETS indirect costs. - Economic impacts ETRMA welcomes what is recognised in the inception impact assessment: “the guidelines will have significant economic impacts both for sectors eligible for compensation and for other sectors, which may compete with eligible sectors in certain product markets". "Should the Guidelines be excessively strict as regards which sectors are eligible for compensation or as regards the maximum compensation amounts, this could result in carbon leakage (e.g. via the relocation of economic activity outside the scope of the EU ETS)”.
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Response to Stepping up EU Action against Deforestation and Forest Degradation

15 Jan 2019

The European Tyre & Rubber Manufacturers Association (ETRMA) and its members are fully committed to ensure sustainable production and supply of natural rubber. This means looking after the people, communities and natural resources touched by natural rubber production and supply. Therefore, ETRMA supports the Commission’s Deforestation Roadmap initiative. ETRMA and its members call upon the European Commission to engage with the Tyre and Rubber industry in order to develop constructive and viable solutions in the fight against deforestation, delivering on environmental and industrial objectives. One of these is to support the further development of ways to reduce unnecessary pressure, onto the existing geographical areas, to increase production area through e.g. means of yields improvement and transparency of the supply chain, alternative sourcing of natural rubber and circular economy actions. Initiatives on natural rubber sustainability have been launched in which ETRMA and its members are participating stakeholders e.g.: the Sustainable Natural Rubber Initiative (SNR-i) in the context of the IRSG, and Tire Industry Project’s Global Platform for Sustainable Natural Rubber (GPSNR), under the auspices of the World Business Council on Sustainable Development (WBCSD). Further details can be found in the attached initial response.
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Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella) and European Plastics Converters Association and Environmental Resources Management

14 Jan 2019 · listing of ADCA in Annex XIV of REACH

Meeting with Dominique Ristori (Director-General Energy) and Manufacture Française des Pneumatiques Michelin

7 Dec 2018 · les développements des pneumatiques en Europe et son rôle clé pour plus de sécurité et gains d'énergie dans le secteur automobile

Response to Cooperative, Connected and Automated Mobility (CCAM)

15 Nov 2018

ETRMA welcomes the possibility to provide comments on the Roadmap on Cooperative, Connected and Automated Mobility (CCAM) and to offer its view on how a balanced and timely initiative from the European Commission could support innovation and help achieve mid-term goals for road safety. The present paper anticipate a more detailed contribution that will be provided to the ongoing public consultation. ETRMA messages: - Data Access: The Roadmap rightly and coherently foresees in the scope of the Recommendation on CCAM, expected to be published by Q1 2019, the governance framework for access to data generated by connected vehicles, together with cybersecurity and connectivity. However, the expectation was for clear and binding regulatory proposal as called by many stakeholders, considering that access to in-vehicle data is key to guarantee fair and undistorted competition on the market and to take the opportunities offered by CCAM to improve road safety and stimulate innovation. - Impact assessment: ETRMA would like to invite the Commission to still reconsider the decision to not produce an impact assessment, despite the fact that the “principles” recalled in the Roadmap will not be binding but only intended to steer the course of future initiatives. - Cybersecurity: On cybersecurity, ETRMA invites the Commission to adopt the principle that vehicle security should not represent an impediment but an opportunity to guarantee the storage and execution of aftermarket software, services, applications or data. Data Access ETRMA concurs that models on access to in-vehicle data are still emerging, but we rather witness their convergence toward an exclusive and privileged access that favors certain actors in the mobility services and automotive supply chain. Rather than waiting the consolidation of these models uptake by a consistent market quota, that could lead to severe and irreversible consequences for many industrial actors active on the current EU Market, a timely action from the regulator is by far the most effective, opportune and expected response to the request coming from many stakeholders operating in the mobility sector. By limiting the access for the third parties, the current models also limit the safety benefits and the innovation potential that could be brought. Studies sponsored by the Commission , the Joint Research Centres’ technical report on access to digital car data and competition in the aftersales service , as well as initiative brought forward by the European Parliament , all concur to flag the above-mentioned risks and call for the Commission to take a timely action before it turns to be too late. Impact assessment In light of the above, ETRMA considers the use of the impact assessment as an insightful methodology to capture and measure the magnitude of impacts of the different models mentioned in the roadmap on the three key aspects. Albeit limited to the definition of principles, the “steering effects” (i.e. the results of the recommendation) can still have impacts that should be subject to a proper evaluation addressing their influence on social, environmental and economic aspects. ETRMA asks the Commission to conduct a thorough impact assessment that takes into account all the options for a governance framework on access to data, including the risks related to the delay of a legislative act allowing direct and timely access to real time in vehicle data. Cybersecurity CCAM mobility represents a new frontier for IT solutions developments that need to adapt to new products (connected cars) different from traditional IT devices. ETRMA looks with great interest and stands ready to contribute to the definition of those common rules and certificates that will result inclusive and not exclusive for all actors contributing to making vehicles ride safe and secure. For this reason, ETRMA encourages the Commission to promote and align the work programme on cybersecurity.
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Response to Legislation on end-of-life vehicles - evaluation

31 Oct 2018

ETRMA welcomes the revision of the ELV Directive and the possibility to comment on the Roadmap. At this point in time, we have focused our comments on ELT management aspects. ETRMA reserves the right to provide additional comments related to the Roadmap during the forthcoming Open Public Consultation. In most European countries, tyre manufacturers have created non-profit ELT (end-of-life tyre) management companies managing the collection, sorting and recovery of tyres sold to end consumers (the tyre “replacement” market). These companies operate under the EPR model required by national law which impose producers which place tyres for the first time onto the national replacement market to pay an ELT ecofee to those ELT Management companies. This model is being progressively extended to most European countries (currently 15 ELT Management companies set up by tyre manufacturers are operating and the EPR model has been adopted in 23 Member States). Tyre manufacturers fulfil their statutory obligations through those ELT management companies. Within Europe, 94% of all UT tyres generated have been treated in an environmentally safe manner, either through the reuse of part-worn tyres as second hand tyres or the reuse of the tyre casing for retreading or through recycling or energy recovery of End-of-Life Tyres. Vehicle manufacturers have their own recycling obligations covering the whole vehicle, set within the European ELV (End of life Vehicle) directive. The management of those ELTs from ELVs may be provided by ELT management companies as a service to other entities (e.g., vehicle manufacturers) if permitted by the legislative framework and statutes. As a possible improvement of the current ELV Directive, the revision of the ELV Directive should ensure a better alignment between national EPR regulations (ELTs from the replacement market) and the ELV Directive (ELTs from ELVs), as regards two aspects: Article 7 of ELV Directive (Reuse and recovery). When dismantling ELVs, a number of used tyres can still be reused, for example as second-hand tyres. In theory, the sales on the national tyre replacement market of re-usable tyres from ELVs by the ELV dismantler should be accompanied by the payment to ELT Management companies of the ecofee for those tyres in compliance with the national ELT EPR legislation. In practice, this is seldom the case and this feeds a flow of “free riding” tyres in Europe. In accordance with the above, ETRMA considers it necessary to modify the first section of Article 7 of the ELV Directive to expressly state that, in the case where EU MS have approved regulations on components used in the replacement market, the ELV components that are reusable or have been prepared for reuse, shall be subject to the EPR regime of the manufacturer of the waste stream in which they are converted to once they are introduced into the replacement market. Article 1 of the ELV Directive (Purpose) Some EU MS have established minimum objectives of preparation for the reuse, recycling and recovery that are applied on the total weight of the ELVs, without differentiating between ELVs and components of ELVs that have acquired the condition of waste after dismantling the vehicle. ETRMA considers it necessary to modify Article 1 of the ELV Directive to expressly state that the EU MS, in case they have approved regulations on components incorporated in new vehicles and/or used in the replacement market, should unify and homogenize the following: i) environmental objectives of preparation for the reuse, recycling and recovery of the components incorporated in new vehicles included in the scope of the ELV Directive that have become waste; and ii) environmental objectives of preparation for the reuse, recycling and recovery of the components placed for the first time on the replacement market that have become waste
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Response to Determination and verification of the CO2 emissions and fuel consumption of heavy-duty vehicles

5 Oct 2018

Tyre Industry comments to Appendix 2 to Annex 10 Please find below items concerning the Information Document (Appendix 2 to Annex X), which would need to be corrected. The numbering in Section I is confusing. In our understanding, the current points 0.2 and 0.12 are headlines for the following points. Therefore, it would be good to show this also in the numbering of the points. Also brand name and trade description should be placed next to each other. In Section II, it is provided twice to indicate the date of test (points 4. and 9.). We recommends to change one of the points to “Date of test report”. In line with the current practice, we propose to change item 4. accordingly: With the current proposal of the commission, it would be required twice (in points 8.4 and 8.6) to indicate the aligned Rolling resistance value. Therefore, point 8.4 should be deleted. Consequently, ETRMA propose to change point (4) of Annex IX (on page 30) of the proposed amendment as follows: “(4) Appendix 2 is amended as follows: (a) SECTION I is amended as follows: points 0.14 and 0.16 are deleted; [comment: if points 0.14 and 0.16 are deleted, point 0.15 would follow point 0.13.] points 0.1 to 0.16 are replaced by the following: “0.1. Name and address of applicant: 0.2 Make 0.2.1 Name and address of manufacturer: 0.2.2 Brand name/ trade description: 0.2.3 Trade description/commercial name: 0.2.4 Tyre class (in accordance with Regulation (EC) No 661/2009): 0.2.5 Tyre-size designation: 0.2.6 Tyre structure (diagonal (bias-ply); radial): 0.2.7 Category of use (normal tyre, snow tyre, special use tyre): 0.2.8 Speed category (categories): 0.2.9 Load-capacity index (indices): 0.3 Declared rolling resistance coefficient 0.3.1 Tool(s) to provide additional rolling resistance coefficient identification code (if any): 0.3.2 Declared rolling resistance level of the tyre: ..................................................................................... [N/kN] 0.3.3 Load FZ,TYRE: ................................................................................................................................................. [N]” (b) in SECTION II is amended as follows: (i) point 4. is replaced by the following: “4. Date of test report:” (ii) the following points are inserted point 8.4 is replaced by the following: "8.54. Alignment equation: 8.65. Rolling resistance level of the tyre (in N/kN rounded to the first decimal place, in accordance with ISO80000-1 Appendix B, section B.3, rule B (example 1)) Cr,aligned: …………………………………………………………………….…..[N/kN]";
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Response to Revision of the Drinking Water Directive (RECAST 2017)

27 Mar 2018

Elastomer materials are used in Drinking Water applications worldwide for more than 100 years. Elastomers components are present in drinking water infrastructures such as pipelines conveying potable water, seals gaskets, joints, hoses, lining for water containers. The processes used to produce elastomer materials are continuously evolving. Given the variety of applications hundreds of substances are used in elastomer products in contact with drinking. Further, research is constantly on-going to identify and improve the performance of elastomers in contact with drinking water. The Drinking Water regulation 98/83/EC Article 10 encourages members’ states of the European Union to guarantee that a certain level of water quality criteria is met. During the implementation process – on-going for more than 20 years - each member state developed its own compliance system for drinking water products; as a result, the provision for safety requirements and related tests to be applied to elastomer products in contact with drinking water differ. It remains a challenge for industry to comply with all different systems. The current situation hampers the creating of a truly single market for drinking water products, putting at stake the industry´s ability, in its vast majority SMEs, to grow and cope with worldwide competition. The European Commission revision proposal of the drinking water directive published on January (COM(2017) 753) recognises the problems producers of drinking water face. However, it fails in providing a solution to set a real framework for products in contact with drinking water. Suggesting the creation of provisions through the Construction Products Regulation (EC 305/2011) is not the solution; to mention, most of elastomers products used in drinking water applications fall outside the scope. ETRMA urgently requests from the European Commission and the European Parliament to work towards the creation of a single market for drinking water products that necessary includes: • A clear system to harmonize ALL drinking water products compliance systems, standards and requirements across EU, • A positive list of substances for elastomer products in contact with drinking water applicable to all EU members states, • A system to assess compliance for new substances to be used in elastomer products applicable to all EU members states.
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Response to Carbon Leakage List 2021 - 2030

10 Nov 2017

ETRMA, the European Tyre and Rubber Manufacturers’ Association, welcomes the possibility to provide a feedback on the Inception Impact Assessment on the Carbon Leakage List 2021-2030. As a preliminary step to the publication of the Impact Assessment, this consultation is a first opportunity for the tyre sector to highlight some essential aspects to be taken into account when defining the methodological parameters that will be the basis for the determination of the Carbon Leakage list for the phase 4. As a trade exposed sector with limited ability to pass on carbon costs, the methodological choices that the Commission will make for both the quantitative criteria and the qualitative assessment may determine the possibility or not for the sector to be included in the Carbon Leakage list. In light of this, ETRMA intends to provide more detailed and technical comments on the specific parameters that will be considered in the Impact Assessment by answering the next on line public consultation. Herein we would like to provide some initial considerations on significant methodological aspects, not mentioned in the Inception Paper, that should be considered in the Impact Assessment. - Methodology for the determination of the Gross Value Added (GVA): The Inception Paper does not mention, among the methodological choices to be considered before compiling the list, the Gross Value Added (GVA), which is a key factor for the calculation of the Emission Intensity. The value of the criterion metric is sensitive to the source of Gross Value Added (GVA) therefore Impact Assessment should clarify the source to be considered and the level of accuracy of the data. - Need to clarify the calculation methodology for the emission factor for electricity: The average EU28 emissions factor for electricity might be different from the figures for individual countries in which tyre manufacturing facilities are located. Using country specific emission factor could lead to a significant change in the result. Therefore, the Impact Assessment should take into account this aspect and the Commission should clarify which approach intends to adopt.
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Response to Evaluation and potential revision of the EU tyre labelling scheme

20 Jul 2017

ETRMA welcomes the commencing evaluation of the EU Tyre Label. The tyre industry acknowledges the need for, on the one hand, increased awareness and use of the tyre label by users and professional operators, and on the other hand continuous and effective market surveillance. In other words, there is still a large potential for the full establishment of the current label scheme on the EU market and its delivering on the original policy objectives of the tyre labelling regulation. An indication for that is the preliminary study and the tyre industry’s observations. ETRMA recognises the possibility for some targteted legislative amendments, as outlined in the evaluation roadmap. Of interest to consumers could be additional label information for winter tyres, and the label’s application to retreaded commercial tyres. Both of these options remain to be matched with the appropriate methodologies. ETRMA looks forward to the planned, comprehensive impact assessment, and remains a responsible stakeholder through the revision process of the tyre label. More detailed comments in the attached paper.
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Meeting with Jean-Luc Demarty (Director-General Trade)

4 May 2017 · Safeguard proceeding by Turkey on tyres

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

31 Mar 2017 · research opportunity for tyre/road interaction on tyre and road wear emissions

Meeting with Astrid Ladefoged (Cabinet of Vice-President Karmenu Vella)

22 Mar 2017 · Tyre dust

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

16 Mar 2017 · priorities tyre industry including tyre and road wear particles

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

25 May 2016 · EU tyre retreading industry in circular economy

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

15 Mar 2016 · Situation tyre producers in Europe

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

23 Jul 2015 · Energy Union

Meeting with Justyna Morek (Cabinet of Commissioner Elżbieta Bieńkowska), Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

13 Jan 2015 · Introductory meeting