European Type Approval Legislation Explained and Its Impact on the Retreading Industry

At first sight, the raft of tyre industry legislation being introduced at European level is bewildering. The variety of type approval legislation being introduced certainly is complicated but this information sheet will hopefully make understanding the legislation a little easier.

Basically the legislation can be usefully split into three different sectors:

• Vehicle Type Approval Legislation
• Component Type Approval Legislation
• Labelling Directive

Vehicle Type Approval - COM (2008) 316 final

This is a Decree issued by the European Parliament and Council regarding the type approval of the vehicle for general safety. The legislation becomes applicable from 1 November 2011 for the OE market and from 1 November 2012 for the replacement market. The legislation covers rolling resistance, wet grip and tyre noise emissions but is applicable for new tyres only. Retreads are, at the moment excluded.

Component Type Approval - 2001/43EC

This is a type approval scheme for components and is applied in combination with Regulation 92/23/EC and UNECE Regulation 117. This regulation has been applicable for the OE market since February 2004 for all new type approved vehicles and from February 2005 for all new registered vehicles.

This legislation also specifically excludes retreads (there is no noise test available under Reg 117 by which retreads can be tested) and because of this, those retreaders who had supplied specialist tyres to certain OE vehicle manufacturers, have, in recent years, found themselves excluded from this business.

The legislation covers tyre noise emissions and wet grip, but not, as yet, rolling resistance. Although wet grip is included in the legislation, there is, at the moment, no authorised test procedure and therefore wet grip under ECE 117 is not yet obligatory.

2001/43 EC is currently in the news because from 1 October this year, it will progressively become applicable to the replacement market, starting with light truck tyres, truck tyres and car tyres with a diameter below 185. From this date all new tyres brought into the market in these categories will require an "S" mark.

Labelling Directive - COM (2008) 779

The latest Directive to be proposed is a special regulation concerning the marking of tyres. The Directive covers so-called "Eco-labelling" - marking the tyres according to rolling resistance, wet grip and tyre noise emissions. This proposal is currently under discussion but the planned date of ratification is 1 November 2012.

The main difficulty with this proposed regulation is the fact that although it is supposed to exist in parallel with the type approval legislation, it currently bears no relation to the tyre approval method. A further issue for retreaders is that although the introduction in 2012 will specifically exclude retreads, the proposal specifies a review by 2015 to decide whether retreads should be included in the legislation - despite the fact of course, that retreads are currently specifically excluded from both the vehicle and components type approval legislation.

Because retreads are currently excluded from the type approval legislation, there is currently no information on how the testing of retreads should be carried out, should it eventually be decided to incorporate retreads into this legislation. This issue is currently being dealt with by BIPAVER.