A guide to how suppliers of vehicle brakes and tyres should prepare for the new Euro 7 Regulation

Overview: Historically, European vehicle emissions standards have focused on exhaust emissions from internal combustion engines. However, the new Euro 7 Regulation (EU) 2024/1257 standards include emissions from non-exhaust sources, such as braking systems and tyres. This reflects growing concerns over particulate matter (“PM”) pollution, which has significant implications for public health and the environment.

Vehicle OEM Responsibility: Vehicle OEMs are the entities that homologate vehicles under regulatory frameworks such as Euro 7. Therefore, it is the vehicle OEMs' responsibility to ensure that all the systems, including engines, exhaust, emissions control components, brakes and tyres supplied by tier 1 supplier companies, meet the required standards as part of the vehicle's overall compliance.

Tier 1 Supplier Liability: The compliance obligations of tier 1 supplier companies of brakes and tyres are typically based on contractual agreements with the vehicle OEMs. These contracts will outline the technical specifications the components must meet to support the vehicle's compliance with Euro 7 standards. Any failure by the tier 1 suppliers to deliver components that meet these specifications would likely result in liability under the terms of the supply agreement, rather than direct regulatory penalties.

Suppliers of vehicle brakes and tyres should prepare for the new Euro 7 Regulation in the following ways:

1. Collaborative Compliance
   Vehicle OEMs and tier 1 suppliers will need to collaborate closely to ensure that components contribute to the overall compliance of the vehicle. Therefore, while regulatory liability falls on the vehicle OEM, tier 1 suppliers play a crucial role in providing compliant components, and this is governed by their supply contracts with the vehicle OEMs.
   
   
2. Review agreements for the supply of brakes and tyres to the vehicle OEM
   In its agreement with the vehicle OEM the supplier of brakes or tyres should include a liability clause which clearly limits the supplier’s liability to the supply of products that meet the agreed technical specifications and shifts the responsibility for broader regulatory compliance and penalties to the vehicle manufacturer, except in cases where the supplier’s failure to meet those specifications directly causes regulatory non-compliance.
   
   
3. Understand the New Emissions Limits
   Manufacturers need to understand the stricter Euro 7 emission standards not just for exhaust gases but also the limits for non-exhaust emissions, such as PM from brake wear and tyre wear to design compliant products.
   Brake Emissions Limits: The Regulation sets a PM limit in standard driving cycle of 7 mg/km for brake emissions from light-duty vehicles (3 mg/km for pure electric vehicles). This limit covers particles with diameters of 10 micrometres or smaller (“PM10”). The European Commission is developing additional limits for heavy-duty vehicles.
   Tyre Emissions Limits: The Euro 7 Regulation does not currently provide specific numerical limits for particulate emissions from tyre wear. However, there are plans to introduce binding emission limits for tyres sold on the EU market. The Euro 7 Regulation leaves it to the United Nations World Forum for Harmonization of Vehicle Regulation (UN WP.29) to develop such emission limits by June 2026 for passenger car tyres; March 2028 for light commercial vehicles; and March 2030 for heavier commercial vehicles, lorries and buses. If the UN process is delayed beyond these timelines, the EU would be empowered to adopt abrasion limits for all vehicle types at the EU level before the end of 2030 via delegated acts
   
   
4. Ensure compliance with deadlines under the Euro 7 Regulation
   In particular, the Euro 7 Regulation will apply from 29 November 2026 to new types of M1 and N1 vehicles and their components, and from 29 November 2027 to all new M1 and N1 vehicles and their components.
   
   
5. Develop Low-Particulate Brake Pads
   Brake wear particles contribute significantly to PM pollution. The Euro Regulation 7 requires significant reductions in PM from brakes, so developing advanced, low-emission materials is essential.
   
   
6. Enhance Tyre Durability and Design
   Tyre wear is a major source of non-exhaust emissions, particularly microplastics. Improved materials and designs that reduce wear will help meet the new regulatory requirements.
   
   
7. Invest in Advanced Testing Facilities
   For both brake and tyre emissions, the Euro 7 Regulation includes the development of standardized testing methods to measure the emissions under real-world driving conditions. These methods are crucial to ensure compliance with the new limits, as non-exhaust emissions are difficult to measure and vary based on driving behavior and conditions. Manufacturers need state-of-the-art testing equipment to simulate driving conditions and ensure compliance.
   
   
8. Collaboration with Environmental Agencies and Researchers
   Engaging with regulatory bodies and researchers can provide insights into emerging trends, testing methodologies, and innovative materials to meet emission standards.
   
   
9. Explore Eco-Friendly Materials
   Using sustainable, low-wear materials (e.g., advanced ceramics for brakes or new rubber compounds for tyres) can reduce particulate emissions and improve overall vehicle efficiency.
   
   
10. Adapt Production Processes for Compliance
    Changes in materials or designs might require adjustments in production processes. Manufacturers need to optimize production lines for both cost-efficiency and compliance with Euro 7 standards.
    
    
11. Prepare for Digital Monitoring Requirements
    The Euro 7 Regulation will include requirements for onboard monitoring of emissions, including those from brake and tyre wear. Manufacturers should explore sensor technologies that track emissions data.
    
    
12. Review Lifecycle Emissions
    The Euro 7 Regulation focuses on reducing total lifecycle emissions. Manufacturers must evaluate their products' environmental impact from production to end-of-life and make necessary improvements.
    
    
13. Train R&D Teams on New Standards
    Educating engineering and product development teams about Euro 7 compliance requirements will help streamline the development of products that meet new standards from the outset.
    
    
14. Prepare for Market Penetration of Zero-Emission Vehicles
    The Euro 7 Regulation promotes the transition to electric and hybrid vehicles, which have different braking and tyre needs (e.g., regenerative braking and lower tyre rolling resistance). Manufacturers should adapt their products accordingly.

Conclusion

By addressing these areas, vehicle brake and tyre suppliers will be better equipped to provide products which enable vehicle OEMs to meet the new Euro 7 regulations so that the vehicle OEMs can avoid penalties for non-compliance. These penalties could include fines, recalls and prohibition of sales of vehicles or components that do not meet the new standards, liability for damages for harm to the environment or human health, civil or even criminal penalties (especially if manufacturers are found to have knowingly violated the regulations), loss of type-approval certification (meaning that the vehicles cannot be legally sold in the EU market) and reputational damage.

Get in touch

Lawrence Freeman

Senior Counsel, Bird & Bird, Brussels

lawrence.freeman@twobirds.com

About the author: Lawrence Freeman is a Senior Counsel based in Bird & Bird's Brussels office with over 30 years of experience handling issues of European regulatory, competition, and commercial law both in private practice and in-house roles.

Lawrence joined Bird & Bird in 2018 after having spent 5 years as European Counsel of Tesla, Inc. where he founded the European legal department. At Tesla Lawrence advised both on day-to-day and on highly strategic legal and regulatory issues and developed a unique expertise in regulatory issues regarding electric, connected and autonomous vehicles.

Lawrence is admitted as a Solicitor (England and Wales) and is a member of the Brussels Bar.