Meeting with Michelin
18 September 2018
Contact points CLIMA.C4 :
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Meeting with Michelin
18 September 2018
Line to take
CO2 standards for cars and vans
The Commission proposal strikes a balance between three
main
objectives
that
were
considered
together:
(i)
environmental objectives; (ii) savings for consumers; (iii)
employment.
The intermediate 2025 target is crucial to ensure that
investments already kick-start now, while the 2030 target
gives stability and long-term direction to keep up these
investments.
We see quite diverging views emerging in the European
Parliament as well as in the Council. We note that many,
including in particular the Parliament’s ENVI Committee are
calling for more environmental ambition.
It is essential that an ambitious but realistic proposal is
adopted during the current legislative term. We must not lose
time so that the sector can contribute fully to the achievement
of our Paris commitments and that we provide certainty for the
manufacturers and suppliers concerned.
Specifically for the tyre industry:
While acknowledging that the first and most important
characteristic of a tyre is its safety in all driving and
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Meeting with Michelin
18 September 2018
environmental conditions, low rolling resistance tyres can
have a measurable positive impact on CO2 emissions.
The Tyre industry should continue innovating in order to
design tyres that can be, at the same time, safe, durable and
fuel efficient.
The Commission keeps monitoring this process and is always
open to consider solutions that can help achieve the overall
CO2 targets for the Light Duty Vehicles.
We count on your constructive contribution to this process.
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Meeting with Michelin
18 September 2018
CO2 standards for HDVs
The Commission’s proposal for EU-wide CO2 standards for
HDVs is another crucial step towards reducing greenhouse
gas emissions from the road transport sector.
The binding 2025 target of 15% reduction reflects the
application of technologies, which are mature and deployed,
while the aspirational 2030 target of 30% reduction takes
account of technologies that need further development.
The implementation rate of low rolling resistance tyres
currently is limited are the single most important existing
technologythat can contribute to the 2025 reduction target
with about 6% alone.
An early review in 2022 will allow to exploit data available by
then to set a binding 2030 target and to expand the scope to
other HDV categories, such as buses and coaches, smaller
lorries and trailers.
The incentives for zero- and low-emission heavy-duty vehicles
(ZEV/LEV) in the form of "super-credits" are set in a way that
will foster innovation and ensure faster deployment of these
technologies on the market.
Penalties to ensure compliance were set by adapting the
approach followed in the case of cars and vans to the larger
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Meeting with Michelin
18 September 2018
lifetime mileage and payload characteristics of lorries. The
marginal cost of technologies was taken into account.
Finally, it is essential that also this Regulation is adopted
during the current legislative term and we count on your
support.
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Meeting with Michelin
18 September 2018
Tyre Labelling Regulation
The Commission’s proposal for the revision of the tyre
labelling will improve transparency on the fuel efficiency of
tyres sold in the aftermarket.
Incentives for improving fuel efficiency of aftermarket tyres
from the Tyre Labelling Regulation and of factory tyres from
the vehicle CO2 Regulations complement each other.
The Commission counts on Michelin to improve also the fuel
efficiency of aftermarket tyres further.
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Meeting with Michelin
18 September 2018
Defensive points
CO2 emission standards for cars and vans
The Commission proposed a 30% emission reduction target in 2030.
Why?
The proposed 30% reduction target is ambitious and realistic. It is the
result of a robust and thorough impact assessment. A 30% reduction
target provides benefits for the environment, for consumers and for
employment:
o A 30% target will help Member States in meeting their 2030 targets
for the non-ETS sectors under the
Effort Sharing Regulation. It
will deliver emission reductions in road transport in line with its cost-
effective potential, while leaving space for additional policies, in
particular for trucks.
o A 30% target will bring economic benefits for all
consumers. The
increase in upfront cost to purchase more efficient vehicles is
outweighed by increasing fuel savings. For new cars, the net
savings over the vehicle's lifetime are up to around €600 when
bought in 2025 and up to about €1500 in 2030. The user of a
second hand vehicle will benefit as much as the owner of a new car.
o The overall impact on
employment of a 30% target is positive, as it
allows a smooth transition to low- and zero-emission vehicles. More
than 80% of the new vehicles will still have an internal combustion
engine in 2030. Plug-in hybrid vehicles are also incentivised by the
new crediting system. These vehicles have a higher labour intensity
as they have both a classical internal combustion engine and an
electric engine. This approach will ensure sufficient time for the re-
skilling and up-skilling of workers in the current automotive supply
chain.
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Meeting with Michelin
18 September 2018
CO2 emission standards for lorries
Is the 15% emission reduction target by 2025 realistic? Does it lead
to a disproportionate burden for HDV manufacturers?
The proposed 15% target does not overburden manufacturers. It
strikes the right balance and is realistic. It is based on a solid impact
assessment, which looks in particular at the economic impacts.
First, the 15% target is based on the deployment of readily available
cost-effective technologies, which are currently not widely
implemented due to the existing market barriers. These
technologies would bring about 15 to 20% CO2 emission savings in
2025 compared to 2019. Therefore, no new technologies that are
not yet on the market are necessary to meet the proposed 2025
target.
Second, the additional technology costs for meeting the target are
very limited. The additional costs for the purchaser of an average
new vehicle are estimated at about € 1 800 in 2025. This represents
1.6% of the average purchase price estimated at € 110 000.
Third, these upfront costs will be outweighed by the large fuel
savings, estimated at around € 25 000 in the first five years of use
for a new lorry bought in 2025 and up to about € 55 000 in the first
five years of use for a new lorry bought in 2030.
Fourth, flexibilities have been introduced so that manufacturers can
cost-effectively meet the target.
Banking and borrowing have been introduced to take account
of long production cycles, including a reward for early action.
Full flexibility is provided to manufacturers to balance
emissions between the different groups of vehicles within their
portfolio.
Vocational vehicles, such as garbage trucks and construction
vehicles are exempted from the target.
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Meeting with Michelin
18 September 2018
BACKGROUND
1. Handling of tyres for determining CO2 emissions of cars & vans (WLTP) and
Michelin's position
In WLTP the calculation of CO2 for each individual vehicle registered and put on the
market is based on the Interpolation Method. This consists in calculating the WLTP
cycle energy (based on the individual vehicle's mass, aerodynamic resistance and
rolling resistance of the tyres mounted on the vehicle) and obtaining the CO2 value
from the Interpolation Line between Vehicle High and Vehicle Low of the Interpolation
family to which the individual vehicle belongs.
The rolling resistance of the tyres mounted on the individual vehicle is assumed to be
equal to the Rolling Resistance Coefficient (RRC) corresponding to the rolling
resistance class to which the tyres belong (for ex. Class A, or B, etc.).
All the tyre manufacturers were satisfied with this approach, apart from Michelin,
which was proposing to use the actual value of the Rolling Resistance of the tyres
mounted on the individual vehicle at registration, claiming the using the RRC of the
rolling resistance class would have not incentivised tyre manufacturer to improve their
product quality.
It is probable that Michelin will bring up this issue again.
2. Handling of tyres for determining CO2 emissions of HDVs
Regulation (EU) 2017/2400 specifies rules for the determination of the CO2 emissions
and fuel consumption of new heavy duty vehicles to be sold, registered or put into
service in the Union. The CO2 emissions determination shall be performed by the
vehicle manufacturers using a simulationsoftware provided by the Commission.
The simulation tool uses the CO2 emissions related properties of the components as
input that have a significant impact on the CO2 emissions. The relevant input data
include the engine fuel efficiency map, vehicle weight, aerodynamic drag coefficient
multiplied by the frontal area of the vehicle (CdxA), moments of inertia from the vehicle
including standardised bodies or trailers, the specifications of the gear boxes,
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Meeting with Michelin
18 September 2018
efficiency of the auxiliaries and the exact (contrary to the WLTP where only
approximate tyre rolling resistance classes are used!) tyre rolling resistance
coefficients (RRC).
Low rolling resistance tyres are readily available on the market and could be
implemented across the whole fleet but their current market penetration is limited. The
implementation rate of the low rolling resistance tyres in 2016 was 43% while their
possible cumulative net savings during the first five years of use is 5,9% with a 1,91%
additional technology cost.
3. Tyre labelling Regulation
The EU tyre labelling system aims to provide information to consumers on the rolling
resistance, wet grip performance and external rolling noise of tyres to influence their
purchasing decisions. As tyres can make a 20-30 % difference in a vehicle's fuel
consumption, their performance has a significant impact on the fuel efficiency and
emissions of vehicles.
The new COM(2018)296 proposal on the labelling of tyres with respect to fuel
efficiency and other essential parameters and repealing Regulation (EC) No
1222/2009 aims to strengthen the rules and make the regulation more effective. It
means better visibility of the stickers, strengthened market surveillance and broader
range of performance parameters to be included.
Re-treaded tyres are out of scope of the current regulation. Labelling those tyres
would bring substantial energy savings due to their big role on the heavy duty tyre
market. Suitable testing method for re-treaded tyres has to be developed in the future.
Currently, stickers are required for cars (C1 tyres) and vans (C2 tyres) but not for
heavy duty vehicles (C3 tyres). Including C3 tyres fully in the scope of the labelling is
in line with the CO2 standards for heavy-duty vehicles.
The estimated impacts of the new regulation are: increased turnover for business of €
9 billion per year by 2030, 129 PJ annual fuel / 10 Mt annual CO2-eq savings by
2030, decreased noise emissions and fewer accidents.
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Meeting with Michelin
18 September 2018
are ongoing to try to reach an agreement between the co-legislators already by
December.
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