New Zealand Mandatory Tyre Performance Labelling
A research briefing for the House of Representatives Select Committee. This document presents the regulatory gap, international evidence, a proven implementation model (South Korea), and a proposed framework for New Zealand.
Contents of this briefing
EXEC Executive Summary
New Zealand is the only developed Western nation with no mandatory tyre performance labelling, no minimum wet grip standards, and no independent pre-market performance testing for passenger car tyres. Compliance with the structural standard UNECE R30 is entirely self-declared; no government agency independently verifies braking performance, wet grip, or rolling resistance before a tyre is sold to a New Zealand consumer.
Between 2013 and 2023, New Zealand's road death toll increased 35%, the third-worst deterioration of any country in the IRTAD (International Traffic Safety Data and Analysis Group) network. Over the same period, countries that upgraded tyre safety regulations, including South Korea, Poland and Saudi Arabia, saw road deaths fall by 44-50%. While New Zealand's 2024 and 2025 toll has improved, the structural regulatory gap enabling substandard tyres to enter our market without performance verification remains completely unaddressed.
The petition requests that the House of Representatives recommend the Government introduce mandatory tyre performance labelling aligned with EU Regulation 2020/740, and establish minimum wet grip standards for tyres sold in New Zealand. This is not a new regulatory system. It is recognition of an existing international standard that New Zealand has simply never adopted.
01 The Problem: New Zealand's Regulatory Gap
What New Zealand currently requires
The primary legislation governing tyre imports is the Import Control (Tyres) Conditional Prohibition Order 1996, which requires tyres to comply with a recognised structural manufacturing standard, such as UNECE R30, US FMVSS 139, or ECE Regulations. The key word is structural. UNECE R30 tests whether a tyre can survive on a smooth steel drum under progressive speed stages without delaminating or deforming. It does not test wet grip, braking distance, rolling resistance, road noise, or any real-world performance metric relevant to road safety. Compliance with R30 is manufacturer self-declared. No independent pre-market testing is required to place a tyre on the New Zealand market.
Beyond import compliance, the Land Transport Rule: Tyres and Wheels 2001 sets minimum in-service requirements including a 1.5mm tread depth threshold, the lowest minimum in the developed world, shared only with Australia.
The complete regulatory gap: 40+ country comparison
The following table shows the position of 40+ countries across four regulatory dimensions. New Zealand is the only developed Western nation with none in place.
| Country / Region | Pre-market certification | Performance standards | Consumer labelling | Wet grip minimum |
|---|---|---|---|---|
| European Union (27 states) | ✓ UNECE type approval | ✓ Mandatory (R117) | ✓ Mandatory since 2012 | ✓ Yes |
| United States | ✓ Self-cert FMVSS | ✓ Mandatory FMVSS 139 | ~ UTQG since 1979 | ✓ Via FMVSS tests |
| Canada | ✓ Self-cert TSD 109/119/139 | ✓ Mandatory | ✗ No | ✓ Via TSD tests |
| Japan | ✓ MLIT + R117 (since 2018) | ✓ Mandatory | ~ Voluntary (~79%) | ✓ Yes |
| South Korea | ✓ KC certification | ✓ Mandatory | ✓ Mandatory since Nov 2012 | ✓ Yes |
| India | ✓ BIS-ISI mandatory since 2009 | ✓ Mandatory | ✗ No | ✓ Via IS standards |
| China | ✓ CCC since 2018 | ✓ Mandatory | ✓ From May 2026 | ✓ From May 2026 |
| Saudi Arabia | ✓ GCC + SASO | ✓ Mandatory | ✓ Mandatory since 2015 | ✓ Yes |
| Australia | ✓ ADR 23 | ✓ Mandatory | ✗ No | ~ Via ADR tests |
| Taiwan | ✓ CNS standard | ✓ Mandatory | ✓ From July 2026 | ✓ Yes |
| New Zealand | ✗ None (self-declared R30) | ✗ None | ✗ None | ✗ None |
The recall gap
A search of the Product Safety NZ database (productsafety.govt.nz) found zero passenger car tyre recalls on record. Of approximately 1,493 total recalls in the database, only three relate to tyres: all are motorcycle or truck tyres. Product Safety NZ explicitly states: products bought from overseas will not appear on the recalls website unless they are also sold by New Zealand retailers. An ACCC recall in Australia does not automatically trigger a corresponding NZ recall. There is no legal mechanism forcing New Zealand distributors to initiate recalls issued overseas.
Between late 2025 and early 2026 alone, five major NHTSA tyre recalls were issued in the United States covering popular models sold in this market, including 36,919 Toyo/Nitto tyres recalled for belt contamination causing tread separation, 93,959 Continental/General Tire tyres for wrong rubber compound causing tread separation, and 1,742 Firestone Destination LE3 tyres in one of the most common ute and SUV fitments in both New Zealand and Australia. None triggered a New Zealand recall.
02 The Evidence: Safety Cost of Inaction
Wet grip is the critical safety metric
The foundational MIRA/BRMA study (2003), endorsed by the Royal Society for the Prevention of Accidents (RoSPA), tested five tread depths at 50 mph on wet surfaces. At the legal minimum of 1.6mm (NZ minimum is 1.5mm), stopping distance increased by 36.8% on asphalt and 44.6% on smooth concrete compared to full tread. The difference between 3mm and 1.6mm tread was approximately eight metres (two car lengths, at 50 mph.
A separate Halfords/Cardiff University study found that at 70 mph, barely-legal tyres required up to 27.4 metres more to stop than 4mm tread tyres. The EU's 2008 impact assessment (SEC(2008)2860) quantified that A-rated versus G-rated tyres (the full range covered by EU labelling) reduce braking distance by up to 18 metres from 80 km/h on wet roads, a 30% difference for a full set of tyres.
This 18-metre difference is not hypothetical. It is the difference between stopping before a pedestrian crossing and hitting someone at 80 km/h. New Zealand consumers currently have no standardised way to know where on that scale any tyre they purchase sits.
What happens when labelling is introduced
The European Commission's 2018 impact assessment (SWD(2018)189) found that EU tyre labelling combined with minimum performance standards from the General Safety Regulation delivered approximately 260 fatalities avoided per year across Europe. This is the number of people still alive annually because labelling and minimum standards were introduced.
NHTSA crash causation data (DOT HS 811 617, 2012) found that 9% of all US crashes had tyre-related factors. Vehicles with tread depth at or below 1.6mm had a 26% crash involvement rate versus 8% for vehicles with 3 to 4mm tread, a more than threefold increase. Vehicles underinflated by 25% or more were three times more likely to have tyre-related crashes. The NTSB's 2015 Special Investigation Report documented approximately 33,000 tyre-related crashes per year in the United States, resulting in around 19,000 injuries and 539 fatalities annually.
New Zealand's specific data gap
The most recent publicly available breakdown of vehicle-factor contributions to fatal crashes in New Zealand is from 2018, when the Motor Trade Association obtained NZTA data. In that year, 51 fatal crashes involved vehicle factors, representing approximately 15% of the total toll. Of those 51, 23 involved worn tyres, making tyres the single largest vehicle defect in fatal crash causation. The AA's Mark Stockdale confirmed: "Tyres is the number one vehicle defect."
No post-2018 vehicle-factor breakdown has been published by any government body. This represents a seven-year data gap on the most critical metric for understanding tyre-related crash causation in New Zealand. WoF failure data provides a partial proxy: tyres account for approximately 28% of all WoF rejections, making them the second-most-common failure reason after lights, translating to an estimated 540,000+ tyre-related WoF failures per year based on 2022 data.
The total social cost of road crashes in New Zealand reached $9.77 billion in 2021 (3.0% of GDP), with each fatality costing approximately $5.4 million by the Ministry of Transport's own valuations. If tyres contribute to even 5% of fatal crashes, a conservative estimate given the 2018 data, the annual social cost attributable to tyre-related fatalities alone exceeds $70 million.
03 The Playbook: South Korea Case Study
Of all countries that have introduced mandatory tyre performance labelling, South Korea offers the most directly applicable model for New Zealand. It is a smaller economy than the EU, introduced reform with minimal industry disruption, aligned its system with international standards already adopted by major tyre manufacturers, and achieved measurable outcomes within years of implementation.
What South Korea did
South Korea introduced voluntary tyre performance labelling in 2011, giving the industry a 12-month familiarisation period. In November 2012, labelling became mandatory. The system rates tyres on two dimensions: rolling resistance (fuel efficiency) and wet grip performance, each rated on a 1-5 scale. The rating methodology aligns with UNECE ECE Regulation 117, the same standard used by the EU and Japan, meaning manufacturers supplying EU-labelled tyres already had the test data required for Korean compliance without conducting new tests.
The South Korean government estimated the reform would deliver 350,000 metric tons of oil equivalent per year in energy savings from improved rolling resistance across the national tyre fleet. More significantly for this briefing, South Korea's road death toll fell by approximately 50% between 2011 and 2023. While tyre labelling is one factor among many in road safety outcomes, South Korea's reform was concurrent with a broader vehicle safety upgrade programme, the approach that New Zealand's petition mirrors in scope.
Timeline of the South Korean reform
Why New Zealand can move faster than South Korea did
South Korea developed its labelling framework in 2010 before the EU's mandatory system was fully operational. New Zealand in 2026 has significant advantages South Korea did not:
- The EU EPREL database already exists. The European Product Registry for Energy Labelling (eprel.ec.europa.eu) contains registered performance data for every EU-labelled tyre. Tyre models sold in New Zealand that are also sold in the EU, which includes most major brands, already have performance data on record. This data could populate a New Zealand label system from day one.
- The label format is designed and publicly available. EU Regulation 2020/740 Annex I defines the exact label format, colour scheme, and grade display. New Zealand would not need to commission label design work.
- Test laboratories already exist in Australia. NATA-accredited (National Association of Testing Authorities) laboratories in Australia conduct UNECE R117 testing. New Zealand importers could use these without establishing local test infrastructure.
- Major manufacturers already carry the data. Any tyre manufacturer supplying EU or Korean markets, which includes every significant brand sold in New Zealand, has already conducted R117 performance testing. Compliance with a New Zealand labelling requirement would require disclosure of existing data, not the generation of new test results.
04 The Proposal: NZ Implementation Framework
The petition requests two specific actions: mandatory performance labelling, and minimum wet grip standards. The following framework proposes how both can be implemented in stages, using existing international infrastructure, with a realistic timeline.
Phase 1: Mandatory performance labelling (12-18 months)
New Zealand adopts the EU tyre label format (as defined in EU Regulation 2020/740 Annex I) as the required disclosure standard for all passenger car tyres sold at retail point of sale. The label displays rolling resistance grade (A-E) and wet grip grade (A-E), consistent with UNECE ECE R117 test methodology. Manufacturers and importers whose products are already EU-labelled need only ensure label display. No new testing is required. Products without existing EU label data would require R117 testing at an accredited laboratory before sale.
Phase 2: Minimum wet grip standards (24-36 months)
Following Phase 1 adoption, a minimum wet grip threshold is established. The recommended minimum is EU Grade C on the wet grip scale, the same threshold adopted adopted by the EU under the General Safety Regulation (GSR), which came into force in 2022 for new vehicle type approvals and applies to replacement tyres from 2024 for certain categories. This threshold eliminates This threshold eliminates the lowest-performing tyres (those that would achieve D or E grades) from the New Zealand market, while maintaining availability of the full mid-to-premium market range that currently supplies over 95% of sales.
Alignment with the Land Transport Rules Reform Programme
Transport Minister Chris Bishop announced the Land Transport Rules Reform Programme on 19 June 2025 with seven workstreams. Workstream 7, "Overhauling the vehicle regulatory system", covers simplification of import requirements, automatic recognition of overseas standards, exploration of type approval, and systematic review of the vehicle regulatory system. Initial consultation for Workstream 7 is scheduled for May 2026. Tyre performance labelling as automatic recognition of EU Regulation 2020/740 aligns directly with Workstream 7's stated objectives. It is not an addition to the reform programme but an expression of it.
Proposed implementation timeline for New Zealand
PETITION Petition Wording
The following wording has been submitted to the Tables Office for review and wording assistance under Standing Orders.
This briefing document constitutes the supporting evidence referred to in the petition cover letter. Additional technical documentation, OIA correspondence, and detailed country-by-country regulatory analysis are available on request.
The petitioner is available to appear before any Select Committee considering this petition and to provide oral evidence in support of the written submission.
05 Evidence Library: Primary Sources
All claims in this briefing are sourced from primary documents, regulatory texts, peer-reviewed research, or official government data. Sources are grouped by category below.
- 1 Import Control (Tyres) Conditional Prohibition Order 1996: the primary NZ tyre import regulation. legislation.govt.nz
- 2 Land Transport Rule: Tyres and Wheels 2001 (as at 1 May 2021: minimum tread depth, approved standards. nzta.govt.nz (PDF)
- 3 NZTA Vehicle Inspection Portal: 1.5mm minimum tread depth, WoF requirements. vehicleinspection.nzta.govt.nz
- 4 Fair Trading Act 1986: s31A voluntary recall, s32 compulsory recall powers. legislation.govt.nz
- 5 NZ Customs: import tyres to NZ: prohibition scope, rim diameter threshold, schedule standards. customs.govt.nz
- 6 EU Regulation 2020/740: mandatory tyre labelling framework; Annex I defines the label format. eur-lex.europa.eu
- 7 UNECE ECE Regulation 117: standardised test method for rolling resistance, wet grip and noise (the R117 standard). unece.org
- 8 UNECE Regulation No. 30: passenger car tyre structural standard; full regulatory text. unece.org (PDF)
- 9 EU EPREL Database: public registry of performance data for all EU-labelled tyres by model. eprel.ec.europa.eu
- 10 EU General Safety Regulation (GSR): includes minimum wet grip thresholds from 2024 for replacement tyres. eur-lex.europa.eu
- 11 Canadian Motor Vehicle Tire Safety Regulations (SOR/2013-198): TSD 109/119/139 mandatory performance standards. laws-lois.justice.gc.ca
- 12 India BIS Mandatory Certification for Tyres, covering IS 15627:2022, IS 15633:2022 standards overview. bis.gov.in
- 13 SASO 2857:2016 (Saudi Arabia): mandatory rolling resistance and wet grip labelling standard, effective November 2015. saso.gov.sa
- 14 NATA (National Association of Testing Authorities, Australia): ISO 17025-accredited test laboratories. nata.com.au
- 15 ITF/OECD Road Safety Annual Report 2024: NZ road death trend data, IRTAD country comparisons. itf-oecd.org
- 16 NZ Herald (2018): MTA data: worn tyres linked to 23 of 51 vehicle-factor fatal crashes; AA quote. nzherald.co.nz
- 17 Product Safety NZ: zero passenger car tyre recalls on record; overseas products policy. productsafety.govt.nz
- 18 Product Safety NZ: "There's no government agency in NZ that approves products for sale." productsafety.govt.nz
- 19 Office of the Auditor-General 2025: Regulating Vehicle Safety Inspections: NZTA oversight critique. oag.parliament.nz
- 20 NZTA WoF interval extension consultation (2025): cost-benefit analysis: up to 8 additional fatal crashes, 52 serious crashes 2027-2055. RNZ (15 Dec 2025)
- 21 RNZ (2011): Coroner recommends action after William Henry Paul death on SH4. rnz.co.nz
- 22 MfE: Tyrewise fee administration, Customs import entry data. environment.govt.nz
- 23 MIRA/BRMA Tread Depth Study (2003): wet braking distance vs tread depth at 5 levels; 50 mph on asphalt and concrete. Endorsed by RoSPA. rospa.com
- 24 NHTSA DOT HS 811 617 (Choi, 2012): 9% of US crashes have tyre-related factors; tread depth below 1.6mm has 26% crash involvement rate. crashstats.nhtsa.dot.gov
- 25 NTSB Special Investigation Report on Tire Safety (2015): approximately 33,000 tyre-related crashes per year in the US; 19,000 injuries; 539 fatalities. ntsb.gov
- 26 EU Commission Impact Assessment SWD(2018)189: tyre labelling and minimum standards prevent approximately 260 deaths/year across Europe. eur-lex.europa.eu
- 27 EU Commission Impact Assessment SEC(2008)2860: A-rated vs G-rated tyres reduce braking distance by up to 18 metres from 80 km/h on wet roads. eur-lex.europa.eu
- 28 Halfords/Cardiff University Study: at 70 mph, barely-legal tyres require up to 27.4m more stopping distance than 4mm tread tyres. cardiff.ac.uk
- 29 UNECE/IDIADA Worn Tyre Wet Grip Study (2021): wet grip degrades non-linearly; UNECE R117 amendment extending requirements to worn tyres in progress. unece.org
- 30 NHTSA 25T-018 (Nov 2025): Toyo/Nitto: 36,919 tyres recalled for tread separation due to manufacturing contamination. nhtsa.gov (PDF)
- 31 NHTSA recall (Oct 2025): Continental/General Tire: 93,959 tyres for wrong rubber compound causing tread separation. nhtsa.gov
- 32 NHTSA recall (Dec 2025): Firestone Destination LE3: 1,742 tyres in 265/70R17, a common NZ/AU ute fitment. nhtsa.gov
- 33 NHTSA 21T-018 (Dec 2021): Sailun/Blacklion/Blackhawk/RoadX: 84,351 tyres, belt separation, DOT plant 1YJ (Vietnam). nhtsa.gov (PDF)
- 34 NHTSA 20T-005 (Mar 2020): Sentury Tire: 6,188 tyres across 7 brands, sidewall separation. nhtsa.gov (PDF)
- 35 Ministry of Transport: Land Transport Rules Reform Programme, announced 19 June 2025, covering seven workstreams including Workstream 7: Overhauling the vehicle regulatory system. transport.govt.nz
- 36 NZTA: ANCAP vehicle safety ratings for NZ vehicles. nzta.govt.nz
- 37 Tyre Dispatch: NZ Tyre Safety Investigation: 40+ Country Regulatory Comparison. tyredispatch.co.nz
- 38 Tyre Dispatch: UBPS Braking Simulator (19-factor physics engine, 218 independent sources, 0.71% mean error), demonstrating braking distance variation across tyre types. tyredispatch.co.nz/pages/braking-simulator
- 39 Tyre Dispatch: Tread Depth Guide and Photo Gallery, documentation of tread depth wear and WoF thresholds. tyredispatch.co.nz/pages/tread-depth-wear-gallery
- 40 Tyre Dispatch: NZ WoF Tyre Compatibility Tool, guide to NZ WoF tyre axle requirements. tyredispatch.co.nz/pages/nz-wof-tyre-compatibility-tool
This briefing was prepared by Taylor Houghton, Director of Tyre Dispatch / Traction Tyres Ltd, Te Puke, Bay of Plenty. Tyre Dispatch is New Zealand's exclusive importer of Anchee and Predator tyre brands. The petition for mandatory tyre performance labelling was developed independently as a public safety initiative, backed by approximately two years of original research including 40+ country regulatory comparison, 80+ primary source citations, and OIA requests filed with NZTA, the Ministry of Transport, MBIE, and ACC. A history of consumer safety tools predating this petition, including NZ's only physics-validated tyre braking simulator and the country's first AI-assisted tyre identification system , demonstrates that this advocacy is rooted in genuine consumer safety concern rather than commercial interest.
