TA-16-08 ETRTO Position On Amendments On TFTA ToR v1

TA-16-08
ETRTO/ETRMA position on
amendments to TFTA ToR and explaining
TA-16-09
TFTA meeting 11 October 2023

Friday, December 8, 2023 The European Tyre and Rim Technical Organization 1
May contain confidential and/or proprietary information.
Agenda
1. C1 market assessment and timeline
2. C2 and C3 timelines and rationale
3. ETRTO comments on mileage
• EU Tyre Industry supports the timeline for C1 tyres as proposed in TA-

13-04, by providing technical, logistical and financial support.
• This means that EU Tyre Industry is agreeing to perform the market
assessment in 2024 (and multi-circuit begin 2025).
• EU Tyre Industry is also looking for some partnership among TFTA by
having TFTA members joining the test campaign.
• EU Tyre Industry is also willing to provide a validity to the tests
performed and request TFTA (Type Approval Authorities, JRC, …) to
witness the tests to support this test campaign.
Source: TA-13-04
slide 14
Test method Test method Working Threshold Working
Informal document Document document Document
C1 ETRTO September 2023 February 2024 September 2025
A. a working document to amend UNR 117 introducing C1 tyres

abrasion limits and characterising tyres by the means of an index
In TFTA ToR: for both abrasion and mileage, for adoption during 81st 82nd
GRBP in February September 2025 (submitted for feedback to
the 92nd 93rd GRPE in June 2025)
2. C2 and C3 timelines:
• ETRTO reviewed the proposal made by TFTA co-chairs for C2 and C3

timelines that can be visualised as following:
Test
method
Test method Working Threshold
Informal Document Working
document document Document
C2 TFTA proposal September 2024 ? September 2025
C3 TFTA proposal September 2025 ? February 2026
• ETRTO strongly advises to reconsider the proposed timelines for C2 and C3 tyres, by
providing the detailed workprocess needed for this activity with the following Gantts:
C2 timeline:
C2 tyres test method
2023 2024 2025 2026 2027 2028 2029
S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D
vehicle method
test parameters definition
coorelati
definitio
on plan
supliers selection
n
resources availability
test campaign &
parameter testing
selection
method
validation plan execution (test method uncertainty assessment)

intermediate method assessment
method(s) selection
Regulatory body for test method(s)
drafting annexes for each test method
Informal document presenting the test method
Working document submittal for february 2026 GRBP (test methods description)
test method
Informal document amending Working document

GRPE review
Working document adoption at GRBP
WP29 adoption working doc
Entry into force
notification of publication of UN Regulation/publication of adopted amendment
Preparation of testing facilities: design of circuits (7 months) and alignment (4 months)
ISO 17025 Accreditation of test services by National Bodies ( "private"test method)
Preparation of the Market Assessment workplan (GRBP TFTA identifying the segments, tyre
selection + purchase, participating circuits, new circuit alignment, test distribution, etc)
Market assessment requirements transfered to test centers.
State of the Art
ISO 17025 Accreditation of laboratories by National Bodies (once test method EiF)
Designation as Technical Service or Approved Laboratory
State of the art TEST (cold and hot temperature ranges)
Market Assessment data post processing activity (data analysis, cluster definition, ..)
Threshold(s) proposals (based on the selected sample, Summer and Winter)
drafting regulatory proposal for thresholds and homologation
GRBP Working document submittal with preliminary thresholds
GRPE review
informal document confirming the thresholds
GRBP adoption
implement
Adoption

ation
and
Entry into force (with threshold)

C2 timeline: additional technical rationale
The proposed timeline for C2 is based on the following required elements:
C2: parameter definition and testing:

1 year for defining and evaluating the abrasion test method:
- Convoy test based on C1 test method
- SRTT definition: need to consider a C2 SRTT (existing ASTM SRTT 16C or new SRTT). Not possible to use C1
summer and winter SRTT, as not useable on all N1 vehicles in most cases  need specific tests and
potential developments
- Temperature behavior C2 tyres: need specific tests on different tyre clusters
- Test duration: estimation to be assessed on different circuits, vehicles and tyre categories
- Test load and speed
- …….
C2 validation plan
- Idem C1
C2 market assessment
- Probably less tyres than for C1 Market assessment, but shall be statistically relevant
- Longer distance (estimation)
- Lower test speed means longer test duration.
- Considering monitoring (test starting after method EIF)
Light commercial vehicle description:
What are vans?

 Vans are part of a category known as ‘light commercial vehicles’.
 The European classification system defines vans as “motor vehicles with at least four wheels, used for the carriage of goods and having a
maximum mass not exceeding 3.5 tonnes”.
o They are classified as the N1 category.
o This category is further broken down into Class I, II and III vehicles, depending on vehicle weight.
 Light commercial vehicles can also be used to transport people, in which case they are treated as passenger cars under the M categories.
 A wide variety of models and sizes of light commercial vehicles are sold and used across the EU, serving a broad range of specific purposes.
 Many light commercial vehicles are registered through multi-stage type approval. This means that the manufacturer produces an incomplete
vehicle, which is then completed by a bodybuilder.
o Thousands of different build-ups are available to satisfy customer needs (for instance camper vans, broadcasting vans, freezer boxes, etc)
Source: ACEA
Multitude of different vehicle configurations and use applications must be considered in the C2 abrasion test
method. (see annex)
C2 timeline: summary

C2 ETRTO September 2025 February 2026 February 2028
- an informal document to amend UNR 117 introducing C2 tyres test

method(s) for consideration during 82nd GRBP in September 2025
In TFTA ToR: (submitted for information to the 93rd GRPE in June 2025)
- a working document to amend UNR 117 introducing C2 tyres test

method(s) for adoption and consideration, within 83th GRBP in February
2026 (submitted for feedback and information, respectively, to 94th GRPE
in within January 2026)
- a working document to amend UNR 117 introducing C2 tyres abrasion

limits and characterising tyres by the means of an index for both abrasion
and mileage and an informal document to amend UNR 117 introducing C3
tyres test method for adoption and consideration, respectively, during 87th
GRBP in February 2028 (submitted for feedback and information,
respectively, to the 98th GRPE in January 2028)
C3 timeline:
C3 tyres test method
2023 2024 2025 2026 2027 2028 2029 2030
S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D
vehicle method selection (open road/circuit/other?)
selection of market representative tyre set for the validation plan
test campaign & coorelation
definition
test parameters definition

plan
supliers selection
resources availability
parameters testing
selection
method
validation plan execution (test method uncertainty assessment)

intermediate method assessment
method(s) selection
Regulatory body for test method(s)
drafting annexes for each test method
Informal document presenting the test method
Working document submittal for february 2026 GRBP (test methods description)
test method
Informal document amending Working document

GRPE review
Working document adoption at GRBP
Entry into force
Preparation of testing facilities: design of circuits (7 months) and alignment (4 months)
ISO 17025 Accreditation of test services by National Bodies ( "private"test method)
Preparation of the Market Assessment workplan (GRBP TFTA identifying the segments, tyre
selection + purchase, participating circuits, new circuit alignment, test distribution, etc)
Market assessment requirements transfered to test centers.
State of the Art
ISO 17025 Accreditation of laboratories by National Bodies (once test method EiF)
Designation as Technical Service or Approved Laboratory
State of the art TEST (to be defined)
Market Assessment data post processing activity (data analysis, cluster definition, ..)
Threshold(s) proposals (based on the selected sample, Summer and Winter)
drafting regulatory proposal for thresholds and homologation
GRBP Working document submittal with preliminary thresholds
GRPE review
informal document confirming the thresholds
GRBP adoption
implement
Adoption

ation
and
Entry into force (with threshold)

The proposed timeline for C3 is based on the following required elements :
C3: parameter definition and testing:

At least 1 year for defining the methodology
At least 1 year for evaluating the defined test parameters and method
- Completely other approach as for C1
- SRTT definition: need to consider a C3 SRTT (existing ASTM SRTT 19.5 and 22.5 or new SRTT).. need specific
tests and potential development of dedicated SRTT(s)
- Use case definition: how to handle steer, drive and trailer tyres and on what vehicles?
- Temperature behavior C3 tyres: need specific tests
- Test duration: estimation to be assessed on different circuits, vehicles and tyre categories
- Test load and speed
- High product differentiation depending on usages (Long Haul, regional, on-off, Urban) -> risk of wrong
performance measurement if test is not linked to usage. Strong complexity increase.
- Very high mileage of truck tires (minimum 40 000 to 200 000+ km). To reach the relevant abrasion value,
need at least 20 to 30 000 km.
-
C3 validation plan
- At least 1 year
C3 timeline: additional technical rationale (continued)
C3 market assessment
- Market assessment: number of tyres to consider horizontal market (steer, drive and trailer) and vertical
market (long haul, regional, on-off road, urban, coach, …) and impact on vehicle configuration
- Longer distance (estimated)
- Lower test speed
- Monitoring approach is crucial for environmental and resources point of view
Vehicle descriptions equipped with C3 tyres:

What are trucks?
 The European classification system defines trucks as “motor vehicles with at least four wheels, used for the carriage of goods”. They have a mass
of more than 3.5 tonnes.
o Under this system, trucks are either classified in the N2 category (weighing more than 3.5 tonnes) or N3 (weighing more than 12 tonnes).
o N3 vehicles are also referred to as ‘heavy trucks’ or ‘heavy commercial vehicles’.
 The end-use of trucks varies widely – they may for instance be used for long-haul or regional delivery, for construction or for municipality use.
 Depending on their mission, most trucks are custom-built on an individual basis, often in a multi-stage process, in order to meet specific
requirements. They can vary from the number of axles to the size of the engine, fuel tank or cab, to the height of the chassis.
 When taking the complete vehicle into account – a rigid body or a tractor plus a trailer – the truck market becomes even more complex. There are
literally thousands of shapes and sizes of trucks
What are buses?

 The European classification system defines buses and coaches as “vehicles having at least four wheels, designed and constructed for the carriage
of passengers, comprising more than eight seats in addition to the driver’s seat”.
o Buses and coaches are classified as the ‘M2’ category (for those under 5 tonnes) or ‘M3’ (for those exceeding 5 tonnes) by the system.
Source: ACEA
All those vehicles have different axle configurations, tyre segments (steer, drive, trailer), applications
(long haul, regional, urban, construction, ….), truck, semi truck, …  very high complexity (see annex)
C3 timeline: summary
C3 ETRTO September 2026 February 2027 February 2029
- an informal document to amend UNR 117 introducing C3 tyres

test method(s) for consideration during 84th GRBP in
September 2026 (submitted for information to the 95 th GRPE
In TFTA ToR: in June 2026 )
- a working document to amend UNR 117 introducing C3 tyres

test method(s) for adoption and consideration, within 85th
GRBP in February 2027 (submitted for feedback and
information, respectively, to 96th GRPE in within January
2027)
- a working document to amend UNR 117 introducing C3 tyres

abrasion limits and characterising tyres by the means of an
index for both abrasion and mileage for adoption during 89th
GRBP in February 2029 (submitted for feedback to the 100th
GRPE in January 2029)
Mileage: EU Tyre Industry comments and concerns
• As already indicated in previous meetings, ETRTO is strongly concerned with the new ToR amendment
proposal on mileage and request to keep the task addressed to TFTA on mileage as it was addressed in
the initial TFTA Terms of Reference:
Assess potential correlation, if any, between abrasion performance and mileage of tyres.
Rationale:
• The amendment to the ToR is proposing to address an EC request for working on a mileage
indicator for the EU tyre labelling regulation.
• The current ToR are already clear enough to assess a potential correlation between abrasion
performance and mileage performance. The new co-chairs proposal for a revised ToR is mandating TFTA
to propose a mileage test method in any case to respond to the new EC request. As of today, the
assessment of a potential correlation between mileage and abrasion is considered in TFTA (see meeting
minutes TA-07-13 (item 8), TA-15-15 (item 5) and presentation TA-07-05), and TFTA is working actively on
the mileage versus abrasion assessment (item is on the agenda of each TFTA meeting).
Mileage: EU Tyre Industry comments and concerns
Rationale (continued):
• Scope of the 1958 agreement defines the conditions for granting type approval and reciprocal recognition,
not the conditions for labeling and grading. Labeling or grading purpose is different than type approval and
therefore it’s not in the scope of UN 1958 Agreement. In consequence, it is not allowed to mandate a UN WP29 TF
preparing to develop a method for classifying tyres in terms of their mileage based on the abrasion rate and design
characteristics. Even the request to develop a method for assessing tyre mileage based on a separate
measurement to be performed during the same testing campaign need to be submitted at least to UN GRBP for
assessment and approval.
• Therefore, also the request to a “Working document to amend UNR 117 introducing C1 tyres abrasion limits
and for introducing labelling by the means of an index for both abrasion and mileage” cannot be retained as this is
not part of the 1958 agreement scope.
Based on the above, regarding the request to work on the mileage for labeling purposes, ETRTO strongly
recommends to keep the initial TFTA ToR for the correlation study between abrasion and mileage, by keeping the
topic on the TFTA agenda, with the understanding of a timeline to deliver; anyhow this study will have to be
performed after abrasion test validation.
Thank you
Annexes
MANY DIFFERENT TRANSFORMATIONS OFFERED TO THE
CUSTOMERS, BASED ON THE SAME BASE VEHICLE APPROVED IN
THE FIRST STAGE.
www.acea.auto 19
VEHICLES SNAPSHOT
www.acea.auto 20
OTHER SPECIAL PURPOSE VEHICLES
CONCRETE PUMP
www.acea.auto 21
OTHER SPECIAL PURPOSE VEHICLES
FIRE ENGINE 90 METERS SKYLIFT
www.acea.auto 22
HEAVY HAULAGE TRANSPORT
www.acea.auto 23
www.acea.auto 24
www.acea.auto
www.acea.auto 25
NORMAL N2 TRUCKS
• Axle loads front up to 6t, axle loads rear up to 8t

• GVW up to 12t
www.acea.auto
www.acea.auto 26
NORMAL N3 TRUCKS

• GVW up to 33t
www.acea.auto
www.acea.auto 27
NORMAL N3 TRUCKS

• GVW up to 41t
www.acea.auto
www.acea.auto 28

TA-16-08 ETRTO Position On Amendments On TFTA ToR v1

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TA-16-08

TFTA meeting 11 October 2023

1. C1 market assessment and timeline

2. C2 and C3 timelines and rationale

3. ETRTO comments on mileage

• EU Tyre Industry supports the timeline for C1 tyres as proposed in TA-

A. a working document to amend UNR 117 introducing C1 tyres

• ETRTO reviewed the proposal made by TFTA co-chairs for C2 and C3

C2 TFTA proposal September 2024 ? September 2025

C3 TFTA proposal September 2025 ? February 2026

validation plan execution (test method uncertainty assessment)

Informal document amending Working document

WP29 adoption working doc

Entry into force (with threshold)

C2: parameter definition and testing:

Light commercial vehicle description:

What are vans?

Test method Test method Working Threshold Working

- an informal document to amend UNR 117 introducing C2 tyres test

- a working document to amend UNR 117 introducing C2 tyres test

- a working document to amend UNR 117 introducing C2 tyres abrasion

test parameters definition

validation plan execution (test method uncertainty assessment)

Informal document amending Working document

WP29 adoption working doc

Entry into force (with threshold)

C3: parameter definition and testing:

Vehicle descriptions equipped with C3 tyres:

What are buses?

- an informal document to amend UNR 117 introducing C3 tyres

- a working document to amend UNR 117 introducing C3 tyres

- a working document to amend UNR 117 introducing C3 tyres

• Axle loads front up to 6t, axle loads rear up to 8t

• Axle loads front up to 10t, axle loads rear up to 16t

• Axle loads front up to 10t, axle loads rear up to 16t

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