01.The product

The tyre is a Vitora WorkLife in size 195/70R15C 104/102R, an 8-ply rated commercial tyre intended for light vans and small trucks. We were asked to fit this size for a customer order. It is not a size we routinely stock, so we sourced it from another supplier. The tyre is brand new — full tread, manufacturer release markings still visible.

On a new tyre, the EU energy label is co-located with the manufacturer's own brand label on the tread surface, and both are produced and applied at the manufacturing source. The wholesale and retail chain receives the tyre with both labels already affixed. Whatever the label says, the wholesaler and retailer are not in a position to verify or alter it.

The label specifications, recorded in full from the affixed sticker:

02.How we noticed: every tyre, every angle

Every tyre that comes through Tyre Dispatch, new and used, retail and wholesale, gets photographed and catalogued before it leaves the workshop. Across 1,089 individual tyre inspections logged to date we hold over 19,000 photographs and 2,600 videos, indexed against more than 230 distinct sidewall and tread detail views. Sample inspection records are visible in our public tread depth and wear gallery.

For each tyre, we typically capture and record:

• DOT code — decoded for plant of manufacture and date of production using our DOT code calculator
• Country of origin marking — verified against the DOT plant code
• Brand and model wordmarks on the sidewall
• Size designation, load index, speed rating
• E-mark and country-specific compliance markings
• CCC, SNI, BIS, BSMI and other regional certifications — see our tyre certification marks guide for what each one means
• EU energy label when present, with separate close-ups of the QR code position
• Manufacturer's printed brand label on the tread surface
• M+S and 3PMSF winter markings
• TWI tread wear indicator location and condition
• Tubeless and ply rating markings
• UTQG markings (where the tyre was built for US disclosure)
• OE markings identifying vehicle manufacturers (where applicable)
• Tread depth by gauge reading, plus walk-around and tread-sweep videos

Inspection at this depth isn't perfectionism. Anomalies only become visible at this granularity. A missing QR code on an EU label gets past anyone taking the label at face value; it surfaces when every detail is photographed against thousands of comparable inspection records, and a label that should follow a known pattern doesn't.

Brand name and label claims are not taken on trust here. The label is one piece of physical evidence sitting alongside hundreds of others on the same tyre.

03.The three compliance failures

Whether the regulation legally applies to a tyre sold in New Zealand is a separate question, addressed in section 06. As a label on its own terms, the document would fail compliance assessment under Regulation (EU) 2020/740 on three independent grounds.

1. The QR code is missing. Regulation 2020/740 Annex II, Section 1.1, lists the QR code as the first mandatory element of the upper part of the label. The QR code is generated by the EPREL system at the point of registration and forms part of the official label artwork. A label without a QR code cannot have been produced through the compliant workflow.
2. EPREL returns no result for this product. A direct search of eprel.ec.europa.eu using the GTIN printed on the label (6953913115474) returned no records. The barcode-level search bypasses brand and model-name issues and queries the unique product identifier directly. The product is not registered in the European Product Registry under any identifier.
3. The wet grip A claim is structurally implausible for the price point. EU wet grip grade A on a C2 commercial tyre requires a measured wet grip index G of 1.40 or higher. Premium European manufacturers — Continental, Michelin, Pirelli — typically achieve grade B (G between 1.25 and 1.39) on equivalent commercial product lines. Grade A on a budget Chinese commercial tyre that has not been verified through any independent system is inconsistent with the compound chemistry usually associated with this market segment. For a primer on what the grades mean and how they're tested, see our tyre grades guide.

04.How we verified it

The verification methodology is simple and reproducible by anyone with internet access. EPREL is a public-facing database. The GTIN search bypasses every variable that could otherwise produce a false negative — different brand spellings, different supplier names, different product naming conventions — by querying the unique product identifier directly.

The search was captured directly from the EPREL system interface with timestamp. The result panel returned no entries. The screenshot is reproduced below; the original file with full metadata is held as primary evidence and is available to any party with a defensible reason for seeing it (journalists, regulators, or the manufacturer's authorised representative).

We then ran a brand-level search to test whether Vitora as a brand has any entries in the registry at all.

What a compliant label looks like, in our own workshop

Hifly is not a brand we routinely stock either. Like the Vitora, this Hifly HF820 in 255/35R19 was a tyre we sourced from another supplier when we needed a size we don't normally hold. We are not promoting any brand here — Hifly is the comparison because it sits in the same market segment as the Vitora (Chinese-manufactured, budget-tier, EU-format label) but the registration story is completely different.

The QR code is in the position required by Annex II, Section 1.1, item I of Regulation 2020/740. The model identifier "203H1048" is also printed on the label, which is the field a reader can use to look up the product directly in EPREL. We did exactly that:

And at the brand level, the contrast is stark. A search for "hifly" as a brand or trademark returns 1,443 distinct registered products in EPREL.

Both Vitora and Hifly are Chinese-manufactured budget tyres. The labels look almost identical at a glance. But one brand has over a thousand registered products in EPREL with verifiable grades; the other has none. The label format on both is the same. Only one sits inside the verification system that gives the format its meaning.

The contrast here isn't Chinese versus European manufacturing, or budget versus premium pricing. It's whether a label can be independently verified.

For further reference, here are two registered fiches from premium European manufacturers showing what a complete EPREL record looks like:

• Vredestein — EPREL ID 615255 — product fiche
• Pirelli — EPREL ID 1776374 — product fiche

Both fiches show what a registered tyre's record looks like: registration number, supplier identification, the verified grades, and links to the underlying product information sheet. The Vitora WorkLife has no equivalent record.

05.What the regulation actually says

Regulation (EU) 2020/740 on the labelling of tyres applies from 1 May 2021 and replaces the older Regulation (EC) 1222/2009. Its scope covers passenger (C1), commercial (C2), and heavy (C3) tyres placed on the EU market. The regulation has a direct anti-counterfeit clause that's relevant to what this Vitora label represents:

EU lawmakers wrote that clause to address exactly the kind of label-format imitation this Vitora illustrates. Producing a label that resembles the EU label is itself a regulatory breach, for any party covered by the regulation.

The QR code requirement is set out in Annex II:

The QR code is item I — the first mandatory element. The registration obligation that produces the QR is set out in Article 5:

The Vitora WorkLife inspected here was manufactured in week 1 of 2026 (DOT date code 0126), well after the 1 May 2021 trigger date. If it were an EU-market tyre, it would need to be in EPREL.

Why the wet grip A claim is hard to take at face value

EU wet grip grades for C2 commercial tyres are defined in Annex I, Part B, on the basis of the wet grip index G. The thresholds:

Achieving G ≥ 1.40 in independent verification testing requires the rubber compound and tread design competence usually associated with the top tier of European manufacturers. The verification tolerance set out in Annex VI for wet grip is zero downward — the measured value cannot fall below the lower bound of the declared class. So a tyre claiming A on a C2 label must measure G ≥ 1.40 in any market surveillance retest, with no margin.

For context: most premium European C2 commercial tyres achieve grade B. For a budget Chinese commercial tyre to genuinely achieve grade A, it would need to outperform Continental, Michelin and Pirelli in the same category. Without an EPREL record, there is no independent verification of the claim.

06.Why this is legal in New Zealand

The label is not illegal under New Zealand law. New Zealand has no tyre-labelling regulation, no central database of tyre performance data, and no mandatory disclosure of fuel efficiency, wet grip or rolling noise. The Waka Kotahi NZ Transport Agency Warrant of Fitness regime regulates structural condition and tread depth — see our WOF tyre guide for what is and isn't checked. It does not regulate performance disclosure.

Regulation (EU) 2020/740 itself only legally reaches tyres "placed on the market" within the European Union. Article 3(15) defines a "supplier" narrowly:

A manufacturer with no EU establishment, no EU-mandated representative, and no direct EU import channel is not a "supplier" within the meaning of the regulation. It carries no obligations under the regulation. The clause exists to keep enforcement workable for EU authorities — they can only act against parties they can practically reach. It also creates a foreseeable side-effect: the same manufacturer can produce labels in the EU format for distribution in jurisdictions that have no equivalent rules, and EU enforcement does not follow the product across the border.

The label presents visually as a regulated, verified document. That presentation triggers consumer expectations carried over from EU labels seen in other contexts. The verification system that gives the label its meaning ends at the EU border.

No party in this distribution chain has broken any law that applies to them. That much is straightforward. The harder question is what a typical New Zealand consumer reading the label would understand it to mean — and the answer, reasonably, is that the tyre has been independently tested and verified. The label cannot support that reading. The argument here is not really about illegality. It is about the distance between how a label looks and what it can be relied on to mean in this market.

07.How New Zealand compares internationally

New Zealand sits at the bottom of the developed-market table for tyre transparency.

New Zealand's regulatory inventory for tyres covers structural safety, tread depth, and import compliance. It has no equivalent of EPREL, no equivalent of the EU label, and no published programme to introduce one. Australia is in the same position. Both markets are downstream destinations for tyres rejected from, or never built for, EU compliance.

08.What we're asking for

This investigation documents one tyre. The systemic question is broader: what proportion of tyres sold in New Zealand carry EU-format labels that cannot be verified, and — more pointedly — what proportion of tyres sold here would fail to meet even the lowest grade on the EU wet grip scale. New Zealand does not require labelling, does not require registration, and does not set a minimum wet grip standard. There is currently no way to know.

Tyre Dispatch's director, Taylor Houghton, lodged a petition in the New Zealand Parliament on 31 March 2026 asking the Government to introduce both. The petition is open for signatures now.

09.Methodology and the audit programme

This is the first report in a continuing audit programme. The methodology is deliberately plain:

1. Identify a tyre with an EU-format label sold in the New Zealand market.
2. Photograph the label in full, with closeups of any features in question.
3. Record specifications: brand, model, size, load and speed indices, fuel/wet grip/noise grades, regulation reference, GTIN.
4. Search the EPREL public database using the GTIN. Capture the result with timestamp.
5. Cross-reference the DOT plant code against known factory data.
6. Publish findings, evidence, and methodology together. Invite correction.

The audit programme is built on top of the Tyre Dispatch tread inspection database, which holds physical inspection records for over 1,080 individual tyres including DOT decoding, label photography, certification markings, and country-of-manufacture verification. The methodology is transparent. Anyone with a tyre, a phone, and an internet connection can replicate it.

Future reports will follow the same format. We will not publish brand-tier categorisations or aggregate market estimates without the data to defend them.

10.Sources and evidence