The European Commission’s Automotive Simplification Package presented yesterday is a first step showing a clear intention to make regulation more workable and reduce unnecessary complexity.

At the same time, the proposal misses an opportunity to simplify the regulatory regime for the only part of the vehicle which touches the road: the tyre.

Tyres are critical to a vehicle’s performance, whether that is safety on the road, energy efficiency, noise, or emissions in everyday driving. Any discussion about vehicle performance and compliance is therefore also a discussion about tyres.

One of the most significant elements of the Package is its clear move away from redundant testing. This direction is both sensible and timely. It reflects a growing recognition that multiplying laboratory tests does not automatically lead to better environmental or safety outcomes, while it does increase complexity and costs.

That same logic should now be applied consistently, including to tyres.

A quick win for the Commission’s simplification agenda would be to exclude tyres from the Implementing Act on In-Service Verification (ISV) under the Heavy-Duty Vehicle Emissions Regulation.

New original-equipment tyres are used for the trucks’ in-service testing. These tyres are already subject to type approval and conformity of production (CoP) testing under existing legislation (UN R117 and Regulation 2019/2144). With the new implementing act imposing stricter tolerances than those set out in these regulations, compliant tyres may fail the in-service test even though they comply with tyre-specific legislation.

This is a clear example of double regulation that is disproportionate and undermines legal certainty. For real simplification, the same objectives of ISV can already be achieved through reinforced market surveillance, without creating a parallel regime.

Looking ahead, the European tyre manufacturing industry needs a regulatory framework that reflects tyres’ essential role in vehicle performance. This means:

• acknowledging tyres as core safety components of vehicles;
• ensuring that new requirements are introduced in a clear and predictable way;
• basing regulatory decisions on reliable data and realistic timelines; and
• supporting innovation, circularity and manufacturing in Europe.

Europe’s tyre manufacturers are investing in safer, cleaner and more sustainable products. These investments depend on confidence — and confidence comes from regulation that is clear, proportionate and coherent, and from policies that reflect the whole value chain.

If Europe wants a resilient and competitive automotive industry, tyres need to be visible in policy discussions, integrated into regulatory design, and recognised for their role in delivering safe and sustainable mobility.

Adam McCarthy, 

Tyres Europe Secretary General