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UN R109 Supplement 11 (00 series) · UNECE Regulation No. 109 (ECE R109) — Uniform provisions concerning the approval for the production of retreaded pneumatic tyres for commercial vehicles and their trailers.

UN R109 — Supplement 11 to the 00 series of amendments

Supplement 10 → 11

Adopted at the WP.29 187th sessionEntry into force 2023-01-03
What changed
  • Paragraph 6.4.10. now also permits upgrading of the service description for a used casing, under conditions on the traceability of the carcasses.
  • New paragraph 6.4.4.3. lists the documents that the retreader must provide for tyres retreaded “by using mould cure tread material(s) and design(s) not covered by paragraphs 6.4.4.1. or 6.4.4.2.” that have to fulfil paragraph 7.2.
  • New definitions and classification rules cover traction tyres, special use tyres and professional off-road tyres (paragraphs 2.8.4., 2.58. and 7.3. to 7.5.).
Why
  • The amendment is required to align the test procedures for retreaded tyres with the ETRTO proposals for UN Regulations Nos. 54 and 117.
  • New paragraph 6.4.4.3. addresses mould cure or pre-cured tread material(s) not approved according to UN Regulation No. 117 and provided or endorsed by the retreader.
  • The change to paragraph 6.4.10. aims to allow upgrading if the carcass can be identified “via any permanent system” as fulfilling the requirements of paragraph 6.4.9.

Q1What changed93 changes

Special use, professional off-road and traction tyres (paras. 2.8.2., 2.8.4., 2.58. to 2.60. and 7.3. to 7.5.)

Paragraph 2.8.2. now adds that special use tyres “are primarily designed to initiate and maintain the vehicle in motion in off-road conditions”. New paragraph 2.8.4. defines a “Traction tyre” as “a tyre in class C2 or C3 bearing the inscription TRACTION and intended to be fitted primarily to the drive axle(s) of a vehicle to maximize force transmission in various circumstances”. New paragraphs 2.58. to 2.60. define “Professional off-road tyre”, “Tread depth”, “Principal grooves” and “Void to fill ratio”. To be classified as a “traction tyre”, a tyre must have “a tread pattern with minimum two circumferential ribs, each containing a minimum of 30 block-like elements, separated by grooves and/or sipe elements the depth of which has to be minimum of one half of the tread depth” (paras. 7.3. and 7.3.1.). To be classified as a “special use tyre” (para. 7.4.) or “professional off-road tyre” (para. 7.5.), a tyre needs a tread depth ≥ 11 mm (C2) or ≥ 16 mm (C3). Both paragraphs also set a void to fill ratio ≥ 35 per cent, and paragraph 7.5. adds a maximum speed rating ≤ Q (C2) or ≤ K (C3).

"Special use tyre" is a tyre intended for mixed use, both on and off road and/or at restricted speed. These tyres are primarily designed to initiate and maintain the vehicle in motion in off-road conditions.
"Traction tyre" means a tyre in class C2 or C3 bearing the inscription TRACTION and intended to be fitted primarily to the drive axle(s) of a vehicle to maximize force transmission in various circumstances.
18 more changes in this group — open in Compare

Markings and the Annex 3 examples (paras. 3.2.13., 3.2.18., 3.5. to 3.5.2. and Annex 3)

Paragraph 3.2.13. now covers the inscription “MPT” (or alternatively “ML” or “ET”) and/or “POR” if the tyre is classified in the category of use “special”. New paragraph 3.2.18. adds the inscription “TRACTION” if the tyre is classified as traction, with new footnote 10 on the minimum height of marking. Under paragraph 3.5., the markings of paragraph 3.2. and the approval mark must now be “clearly legible and indelible”, in place of “clearly legible”. They must be “raised above or sunk below the tyre surface” or permanently marked on to the tyre, in place of “moulded on to or into the tyre”. New paragraph 3.5.1. is “[Reserved]”, and under new paragraph 3.5.2. a date of manufacture that is not moulded must be applied “not later than 24 hours after the tyre is removed from the mould”. Annex 3 now has Example 1, Example 2, new footnotes, dimensional requirements for further markings and new item (f) on two test inflation pressure indications.

The inscription "ET" or "ML" or "MPT" for Special use tyres.The inscription "MPT" (or alternatively "ML" or "ET") and/or "POR" if the tyre is classified in the category of use "special".
ET means Extra Tread, ML stands for Mining and Logging, MPT means Multi-Purpose Truck and POR means Professional Off-Road.
18 more changes in this group — open in Compare

Radial definition and tyre-size designation (paras. 2.7.3. and 2.26. to 2.26.5.)

Paragraph 2.7.3. now names the tyre structure “Radial” or “radial-ply”, in place of “Radial”. Paragraph 2.26. now excepts types of tyre for which the tyre-size designation is shown in the first column of the tables in Annex 5. Before, paragraphs 2.26.1. and 2.26.2. each gave this exception. New paragraphs 2.26.3. to 2.26.3.2. add an indication of the structure placed in front of the rim diameter marking. This is a dash or the letter “D” on diagonal (bias-ply) tyres, and the letter “R” on radial-ply tyres. Former paragraphs 2.26.3., 2.26.3.1. and 2.26.4. are now paragraphs 2.26.4., 2.26.4.1. and 2.26.5.

"Radial" or "radial-ply" describes a tyre structure in which the ply cords extend to the beads and are laid substantially at 90° to the centreline of the tread, the carcass being stabilised stabilized by an essentially inextensible circumferential belt.;
''Tyre size designation'' means a designation showing:"Tyre-size designation" means, except in the case of types of tyre for which the tyre-size designation is shown in the first column of the tables in Annex 5 to this Regulation, a designation showing:
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Documents for tread materials (paras. 4.1.5.3.1.1., 4.1.5.3.1.3., 5.4., 6.4.4.1. to 6.4.4.3., 9.2.2., 9.4. and 9.4.2.)

Paragraph 6.4.4.1. now also covers “an identical tread pattern design in a mould cure product”, and paragraph 4.1.5.3.1.1. now covers “either pre-cured or mould cure tread material”. Under paragraphs 6.4.4.1. and 6.4.4.2., the documents now go to the TAA and the Technical Service issuing the approval, and optionally to the retreader. The former separate lines “To the retreader” are deleted. New paragraph 6.4.4.3. covers tyres retreaded “by using mould cure tread material(s) and design(s) not covered by paragraphs 6.4.4.1. or 6.4.4.2.” that have to fulfil paragraph 7.2. For these tyres, the retreader must provide to the TAA and the Technical Service issuing the approval the documents in items (a) to (d). Paragraphs 4.1.5.3.1.3., 5.4., 9.2.2., 9.4. and 9.4.2. now refer to paragraph 6.4.4.3.

For tyres retreaded by using either pre-cured or mould cure tread material with a tread pattern covered by paragraph 6.4.4.1. the list shall clearly identify the tyres in order to make the relevant link with the list(s) quoted in paragraph 6.4.4.1. b). The following table is an example:
For tyres retreaded by using pre-cured tread material(s) or an identical tread pattern design in a mould cure product with a tread pattern not covered by paragraph 6.4.4.2. having to fulfil the requirements of paragraph 7.2. the retreader shall ensure that the material manufacturer(s) or the material supplier(s) of the pre-cured tread(s) provides to the Type Approval Authority (TAA) and the Technical Service issuing the approval according to this Regulation and optionally to the retreader:
21 more changes in this group — open in Compare

Standard Reference Test Tyres and snow grip index (paras. 2.52., 2.54., 7.2.1. and Annex 10, Appendix 2)

Paragraph 2.52. now refers to the standards of ASTM International and lists four SRTTs: “SRTT16C”, “SRTT19.5”, “SRTT22.5” and “SRTT16”. Before, the list had E1136-93 (2003) for the size P195/75R14 and the other three standards with “(2011)”. In the table of paragraph 7.2.1., the reference tyre “SRTT14” is replaced by “SRTT16”. Paragraph 2.54. now defines the snow grip index (“SG”) as the snow grip performance of a candidate tyre relative to that of the applicable SRTT. Before, it was the ratio between the performance of the candidate tyre and the performance of the standard reference test tyre. In Annex 10, Appendix 2, item 7 of the report now reads “Snow grip index SG”, and the test data table adds a “Factor f” row.

"Standard reference test tyre (Reference Test Tyre" or "SRTT)" " means a tyre that is produced, controlled and stored in accordance with the American Society for Testing and Materials (standards of ASTM) standards International:
E1136-93 (2003) for the size P195/75R14;F2872 – 16 for the size 225/75R16C and referred to as "SRTT16C",
9 more changes in this group — open in Compare

Upgrading of the service description of a used casing (para. 6.4.10.)

Before, paragraph 6.4.10. permitted upgrading of the service description only for the first retread of an original, first life tyre. It now also permits upgrading for a used casing, if the traceability of the carcasses to be retreaded is guaranteed (item (b)). The speed symbol or load index used for retreading must then “not exceed the conditions mentioned in the standard form in Annex 9 of UN Regulation No. 54 for these carcasses”. For a used casing whose traceability is not guaranteed till the original, first life, tyre, “the speed symbol or the load index shall then not be raised above that shown on the used casing” (item (c)). The retreader must demonstrate to the approval authority the traceability of retreaded carcasses. The former sentence on tyres which have been previously retreaded is deleted.

Upgrading of the service description as given in paragraph 6.4.9. shall only be permitted for the first retread of an original, first life tyre.:
for the first retread of an original, first life tyre.;
4 more changes in this group — open in Compare

Additional sidewall protective rubber layer (para. 7.1.4.4.)

Under paragraph 7.1.4.4., the additional sidewall protective rubber layer (ASP) rule now applies to retreaded C3 radial tyres. Before, it applied to retreaded radial tyres “with nominal section width exceeding 305 mm for dual mounting (twinning) and a nominal aspect ratio higher than 60”. New item (d) says: “In case of a dual mounting (twinning) only one tyre with ASP is allowed and has to be mounted on the outer wheel position”.

For retreaded C3 radial tyres with nominal section width exceeding 305 mm for dual mounting (twinning) and a nominal aspect ratio higher than 60, an additional sidewall protective rubber layer (ASP) may be applied to a maximum of 8 mm greater than the overall width of the same tyre size description permitted by Regulation No. 54 provided that:
The maximum allowed speed rating is index J (100 km/h).);
1 more change in this group — open in Compare
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Q2Why it changed

Proposed by
Experts from the Bureau International Permanent des Associations de Vendeurs et Rechapeurs de Pneumatiques (BIPAVER), France and the Netherlands; experts from France
Working party
GRBP, 74th session (September 2021)

Reasons

  • The amendment is required to align the test procedures for retreaded tyres with the ETRTO proposals for UN Regulations Nos. 54 and 117. Paragraphs 2.7.3., 2.8.2., 2.8.4., 2.58., 2.59., 2.59.1., 2.60., 7.3., 7.3.1., 7.4. and 7.5. are aligned with UN Regulation No. 117. The text was also prepared to cover all the tread materials.

    Sources (3)
    “This amendment to UN Regulation No. 109 is required in order to ensure that the test procedures for retreaded tyres are aligned with the proposals of ETRTO”
    “The implementation of paragraphs 2.7.3., 2.8.2., 2.8.4., 2.58., 2.59., 2.59.1., 2.60., 7.3., 7.3.1., 7.4. and 7.5. is aligned with UN Regulation No. 117.”
    “in order to align the provisions for retreaded tyres with the proposals of the European Tyre and Rim Technical Organization (ETRTO) for UN Regulations Nos. 54 and 117 and to cover all the tread materials”
  • Paragraph 3.5. is amended and paragraph 3.5.2. is added to align the retreaded tyre marking requirements with the amendment proposed for UN Regulation No. 54. Permanent marking that is neither raised above nor sunk below the tyre surface is a practice largely adopted for retreaded tyres. For this reason, this possibility has to be kept.

    Sources (2)
    “Paragraph 3.5. has to be amended and paragraphs 3.5.1. and 3.5.2 have to be added to ensure that the marking requirements for retreaded tyres are aligned with the amendment proposed in ECE/TRANS/WP.29/GRBP/2020/13 for UN Regulation No. 54.”
    “the possibility of permanently marking retreaded tyres which are neither raised above nor sunk below the tyre surface has to be kept, because this is a practice largely adopted for retreaded tyres.”
  • Paragraph 6.4.4.1. concerns pre-cured tread material(s) or an identical mould-cure tread pattern design, not approved according to UN Regulation No. 117, from a supplier. The aim is to clarify the documents to be provided to the Type Approval Authority (TAA) by the retreader. Paragraph 6.4.4.2. was rephrased/renumbered for clarification. New paragraph 6.4.4.3. addresses mould cure or pre-cured tread material(s) not approved according to UN Regulation No. 117 and provided or endorsed by the retreader. In that case, the retreader provides evidence: the test report and CoP. As a consequence, paragraphs 4.1.5.3.1.3., 5.4., 9.2.2., 9.4. and 9.4.2. are added or updated.

    Sources (6)
    “Paragraph 6.4.4.1. concerns pre-cured tread material(s) or an identical mould-cure tread pattern design not approved according to UN Regulation No. 117 and provided by a supplier.”
    “The aim of the proposal is to clarify the documents to be provided to the Type Approval Authority (TAA) by the retreader.”
    “Paragraph 6.4.4.2. concerns mould cure or pre-cured tread material(s) approved according to UN Regulation No. 117. The paragraph was rephrased/renumbered for clarification.”
    “Paragraph 6.4.4.3. concerns mould cure or pre-cured tread material(s) not approved according to UN Regulation No. 117 and provided or endorsed by the retreader.”
    “This is a new paragraph in order to address such case, then the retreader shall provide evidence: the test report and CoP.”
    “Paragraphs 9.2.2. and 9.4.2. are updated according to the new provisions in paragraph 6.4.4.3.”
  • The change to paragraph 7.1.4.4. is related to the extended tyre size range that is used in vehicle original equipment for urban application. This application requires sidewall protections for the tyres, for example 275/70 and 315/60 R 22.5. The limitation to C3 tyres and to the outside tyre position in dual mounting avoids possible problems with the clearance in the wheel housing.

    Sources (2)
    “The modification of paragraph 7.1.4.4. is related to the extended tyre size range that is used in the vehicle original equipment for urban application with the requirement of sidewall protections for the tyres (e.g. 275/70 and 315/60 R 22.5).”
    “With the limitation to C3 tyres and the limitation to outside tyre position in dual mounting possible problems in relation to the clearance in the wheel housing are avoided.”
  • The change to paragraph 6.4.10. aims to allow the upgrading of a tyre complying with the prescriptions of paragraph 6.4.9. The upgrading would be allowed if the carcass can be identified “via any permanent system” as fulfilling the requirements of paragraph 6.4.9.

    Sources (2)
    “The purpose of this amendment is to allow the upgrading of a tyre complying with the prescriptions of paragraph 6.4.9.”
    “if the carcass can be identified via any permanent system as fulfilling the requirements of paragraph 6.4.9.”

Document trail

  1. 2021-06ProposalECE/TRANS/WP.29/GRBP/2021/18Proposal by the experts from France for paragraph 6.4.10.
  2. 2021-07ProposalECE/TRANS/WP.29/GRBP/2021/16Proposal by BIPAVER, France and the Netherlands
  3. —Amended in sessionGRBP-74-30-Rev.2ETRTO proposal to amend ECE/TRANS/WP.29/GRBP/2021/16
  4. —Working party adoptsECE/TRANS/WP.29/GRBP/72Session report, para. 18 (with the amendments in Annex IV) and para. 19
  5. —Amended in sessionWP.29-186-07ETRTO proposal to amend ECE/TRANS/WP.29/2022/7; WP.29 postponed consideration to June 2022
  6. 2022-04Sent to WP.29ECE/TRANS/WP.29/2022/7/Rev.1Revised text that replaces ECE/TRANS/WP.29/2022/7 and WP.29-186-07
  7. 2022-06WP.29 adoptsECE/TRANS/WP.29/1166Adopted at the 187th session (session report, para. 182)
  8. 2023-01-03In forceC.N.490.2022.TREATIES-XI.B.16.109UN depositary notification

Q3Who is affected

Vehicle manufacturer

  • No direct action for this role.

Component supplier

  • If you upgrade the service description of a used casing, demonstrate carcass traceability to the approval authority (para. 6.4.10.).
  • Under paragraph 6.4.4.3., give the TAA and the Technical Service issuing the approval documents (a) to (d).
  • Mark “TRACTION” on retreaded tyres classified as traction tyres (para. 3.2.18.).
  • Apply a date of manufacture that is not moulded within 24 hours after removal from the mould (para. 3.5.2.).

Technical service / Approval authority

  • Be ready for the new documents of paragraph 6.4.4.3. for mould cure tread material(s) and design(s).
  • In snow grip tests, use SRTT16 where the minimum snow grip index table formerly named SRTT14 as reference.

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