1. Tyre Industry contribution
HDV CO2 Regulation
Tyre Industry contribution
October 9th 2017 Editing Board meeting

2. Inputs on vehicle testing procedure

3. Remarks on Vehicle testing procedure
Article 3. Vehicle selection: The components mounted in the vehicle have to be out of series production. If this includes tyres, a rephrase would be useful to stress that EPT has to be done with the proper components: “The components mounted in/on the vehicle have to be out of series production and corresponding to those declared in the certificate.”
Article 4.1 vehicle run in and minimum 10,000 km. If this apply also to tyres, then what if they are measured afterwards and found not in line with the declared RR value (possibly better due to run-in)?
Article §10: the Article does not exclude tyres from the hashing system. Also, it is not clear why it is useful that "TA number matches the component installed in the selected vehicle" since tyre RR does not intervene in this EPT procedure.

4. Remarks on Vehicle testing procedure
Article 6.1.5: The tyre inflation pressure shall be in line with the recommendations of the tyre manufacturer(s).
Recommendations of the tyre manufacturer or recommendations of the vehicle manufacturer? In the end, the tyre inflation pressure must be entered somewhere in VECTO. Which one does the OEM use for the original declaration and for the ex post verification?
Article 6.1.5: Tyre Industry recommends to state for tyres, as for aerodynamics the following: "The bodies of the vehicles do not have to be in line with the standard bodies defined for the CO2 certification since the real power demand at the wheels is determined by the wheel torque measurement". Also in line with Article 7.1: "The data for air drag and rolling resistance coefficients are not relevant for the EPT result since driving resistances are used as measured values at the wheel as input to VECTO"

5. Regulation remaining questions

6. Conformity of Production clarification
Article 22.3: The manufacturer shall ensure that at least one in every 25 procedures referred to in the second subparagraph of paragraph 1, or, with an exception for tyres, at least one procedure per year, relating to a component family, separate technical unit family or system family is supervised by a different approval authority than the one which participated in the certification of CO2 emissions and fuel consumption related properties of the component family, separate technical unit family or system family concerned pursuant to Article 16. Not clear the process in selecting “a different Approval Authority” and role of COM, TAAs and Tyre Manufacturers with this regard. Also, what does “supervised” stand for and does imply?

7. Annex X on Tyres: article 3.4.2 – Alternative marking
The current text allows the alternative marking usage only if "regular tyre markings“ cannot guarantee a unique identification of the rolling resistance coefficient.
The alternative solutions should be an option in any case,
A clarification is required on what the "regular tyre markings" are and on top if the focus should be done on tyre marking or on tyre identification. Tyre Industry would be keen to share a proposal for amendment aimed at support COM in clarifying how to link the certificate and the tyre.

8. Annex X - Appendix 2
Section I, Points 0.14 and 0.16: Is it the same tyre RR value as in Section II line 8.4 (measured value, temperature and drum diameter corrected and aligned to EU network of laboratories)? For the purpose of the certified value needed by OEMs to feed VECTO, the declared value reported in point 0.12 is enough. Points 0.14 and 0.16 should be moved to Section II, to become respectively 8.6 and 8.5.

9. XML file as specified in Annex X – Appendix 3
Tyre Industry deems useful to clarify the process to extend and keep updated the tyre list.
Tyre Industry would suggest to clarify the meaning of "TechnicalReportID“.
Being Tyre Industry understanding that the “hashing” system will not be applicable to tyres, then “Date” string should be reconfirmed if still linked to the hashing tool or to something else.