Five Category System Would Maximize Tire Choices for ConsumersRMA Comments submitted to NHTSA
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WASHINGTON, D.C., August 24, 2009 – Tire manufacturers are proposing a tire fuel efficiency rating system that is more likely to assist motorists to choose fuel efficient replacement tires than a system proposed by federal regulators.
In written comments to a proposed tire fuel efficiency consumer information regulation by the National Highway Traffic Safety Administration (NHTSA), the Rubber Manufacturers Association said its members believe that to establish effective consumer information requirements regarding tire efficiency, the program must meet the following:
• Provide information at point of sale;
• Provide meaningful information that is easy to understand by consumers;
• Provide a wide range of tire efficiency choices across the rating scale to each consumer about replacement tire choices appropriate for the consumer’s existing vehicle;
• Be cost effective to minimize the cost effect of this information to consumers.
RMA supports a five category rating system that maximizes the tire efficiency choices across the rating scale for available to each consumer.
“Since consumers shopping for replacement tires are limited in their tire selections by requirements of their existing vehicle, it is important to design a rating system that maximizes the tire efficiency choices across the rating scale for each consumer. The appeal of a rating system will depend on whether a consumer has “good” choices appropriate for his vehicle across the rating scale,” RMA wrote.
In June, NHTSA proposed a tire fuel efficiency rating system that would be printed on a paper label on every replacement passenger tire sold in the U.S. The rating system would rank tire fuel efficiency on a 0-100 point scale. The proposed rule also would rate wet traction capability and tread wear. The regulation was required by energy legislation enacted by Congress in 2007. RMA advocated in favor of the provision to create a tire fuel efficiency consumer information program.
RMA said that NHTSA’s proposed rating approach would not provide consumers with useful information about fuel efficiency of replacement tires suitable for their vehicles. Under the NHTSA proposal, a typical consumer shopping for a replacement tire for a specific vehicle would have a choice only along approximately a 20 to 30 point spread on the 100 point scale.
“The proposed rating scale gives consumers an illusory view of the tire efficiency choices available to them for their vehicle and does not assist consumers in purchasing fuel efficient tires for their vehicle,” RMA wrote. “On the other hand, this rating approach encourages consumers to purchase smaller tires and could promote the purchase of tires with inadequate load-carrying capacity to safely carry the load of the vehicle. Although many tire dealers would discourage and in many cases would not sell a tire with a rated load capacity insufficient for the vehicle, NHTSA should not promote a system that could lead to this type of safety concern.”
RMA said that NHTSA should develop a system that promotes tire efficiency, regardless of vehicle class.
“Unfortunately, since the proposed system would not favorably rate any tires suitable for larger vehicles, it would send the message to owners of these vehicles that they have no fuel efficient tire choices, so they should not base tire purchasing decisions on this information,” RMA wrote.
RMA also expressed opposition to the propose tire rating system label as a means of providing point of sale information to consumers.
“RMA proposes that NHTSA mandate that tire retailers have the rating information available to consumers in the dealer showroom or waiting area. RMA recommends that NHTSA give tire retailers options for making this information available and require that each retailer choose one or more options that suits their business model and needs. Options could include: tire manufacturer brochures, tire manufacturer product catalogues, in-store online access to the NHTSA website, tire manufacturer websites or the tire retailer’s website containing the rating information,” RMA stated.
RMA estimates that initial costs for manufacturer testing and reporting would range from $14,657,250 to $53,157,440, while annual costs range from $12,280,322 to $34,745,722. Initial costs for the proposed tire labeling requirements would range from $21,921,745 to $30,641,745, while the annual cost estimates range from $11,543,764 to $16,782,340. RMA said in its comments that NHTSA underestimated industry costs.
“The tire industry has long supported the concept of providing information to consumers about its products at point of sale and welcomes the opportunity to begin providing consumer information about a tire’s contribution to vehicle fuel economy,” RMA said.
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The Rubber Manufacturers Association is the national trade association for the rubber products industry. Its members include companies that manufacture various rubber products, including tires, hoses, belts, seals, molded goods, and other finished rubber products.