ECE Regulations 108 and 109

Consumer confidence in the use of retreaded tyres has received a substantial boost in recent years with the news that two EC regulations relating to the "type approval" of retreaded tyres have become mandatory across the EU. The two Regulations, which identify uniform conditions for the approval of individual retreading facilities, are ECE Regulation 108, which relates to the production of retreaded pneumatic tyres for private (passenger) cars and their trailers, and ECE Regulation 109, which specifically deals with the production of commercial vehicle retreads.

Although these regulations had been available for use on a voluntary basis since June 1998, their application became compulsory in the UK with effect from January 1st, 2004 and across the EU during 2006.

The legislation means that retread producers have effectively become 'licensed' operations, a move which has made a considerable contribution towards ensuring that the quality, integrity and performance of retreaded tyres are, at the very least, on a par with that of new tyres.

Type Approval of a tyre is a confirmation and an endorsement that the product is suitable for the purpose intended and has conformed to ECE Regulations with respect to performance, dimensions and marking requirements. When a retreader becomes approved, he is awarded an "E" number unique to his company, which must be displayed on all tyres he produces.

Type approval under ECE Regulations 108 and 109 commits retreaders to a number of actions designed to ensure traceable quality throughout the retreading process. Firstly, retreaders are obliged to submit written documentation to the Type Approval Authority in support of the process controls and procedures adopted by the production unit. They are further required to display evidence of a comprehensive and demonstrable quality control system. To this end most retread companies are ISO 9001 registered. Registration to ISO 9001 provides independent evidence that the processing company has an appropriate and on-going Quality Management System.

Regardless of this, the Type Approval Authority is entitled to randomly visit any retread producing Company in order to audit the process controls and product quality. Furthermore they are at liberty to randomly select a number of processed tyres for drum testing (load/speed performance testing) to the same parameters set out in ECE Regulation 30 (passenger tyres) or ECE Regulation 54 (commercial tyres), that is, the same tyre testing regime, which new tyre manufacturers undertake.

In the event of a selected tyre failing the drum test, two further samples of the same specification tyre are tested. If either or both of these second two samples fail, then a final submission of two samples is tested. If either or both of the final two tyres fail, then the approval can be removed! As such, the testing procedure is an effective way of confirming the quality of any given retreader's product.

Source: Retread Manufacturers Association