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UN R109 Base text (01 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 — 01 series of amendments

Changes from 00 series of amendments (supplement 12)

Adopted at the WP.29 193rd sessionEntry into force 2025-01-10
What changed
  • Snow test and traction tyre classification requirements are deleted, and paragraph 2.53. now refers to paragraph 6.1. of UN Regulation No. [XXX].
  • Under paragraphs 6.4.4.1. to 6.4.4.3., the documents for the Type Approval Authority and Technical Service now include UN Regulation No. [XXX] certificate(s).
  • As from 1 September 2025, Contracting Parties applying this Regulation are not obliged to accept preceding-series type approvals first issued after 1 September 2025. Until 1 September 2028, Contracting Parties applying this Regulation must accept, and grant extensions to, preceding-series type approvals first issued before 1 September 2025.
Why
  • The 01 series was proposed to address difficulties with the approval of retreading facilities producing “tyres for use in severe snow conditions” and the verification of their conformity of production.
  • The rationale is to segregate type approval of the retreading workshop from the performances of the retreaded tyres, which result from the tread pattern used.
  • The full text was also given editorial corrections where needed and aligned as much as possible with the up-to-date version of UN Regulation No. 54.

Q1What changed534 changes

Snow grip performance and traction tyre classification moved to UN Regulation No. [XXX] (paras. 2.53. and 3.4.1.)

Paragraph 2.53. now reads: “"Tyre for use in severe snow conditions" means a snow tyre or a special use tyre whose major features including tread pattern are specifically designed to be used in severe snow conditions and that fulfils the requirements of paragraph 6.1. of UN Regulation No. [XXX]”; before, it defined a “Snow tyre for use in severe snow conditions” that fulfils paragraph 7.2. of this Regulation. The snow test of former paragraph 6.6.2., the snow classification of former paragraph 7.2. and the snow test procedures of Annex 10 are deleted. The periodic tests of snow performance in former paragraphs 9.2.2. to 9.2.4. and 9.4.2. to 9.4.4. are also deleted. The “traction tyre” classification of former paragraph 7.3. is deleted too. If a retreaded tyre is classified as “snow tyre for use in severe snow conditions” and or as “traction tyre”, new paragraph 3.4.1. requires the approval mark of Regulation No. [XXX] in addition. The “Alpine” symbol must now conform to Annex 7, Appendix 1 to UN Regulation No. 117, instead of Annex 10, Appendix 1.

"Snow tyre Tyre for use in severe snow conditions" means a snow tyre or a special use tyre whose major features including tread pattern, tread compound or structure is are specifically designed to be used in severe snow conditions and that fulfils the requirements of paragraph 7.26.1. of this UN Regulation No. [XXX].
The "Alpine" symbol (3-peak-mountain with snowflake) shall be added if the snow tyre or the special use tyre is classified as "snow tyre for use in severe snow conditions.
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Tread definitions, documents for the approval and pre-cured tread packaging (paras. 2.58., 2.59. and 6.4.4.1. to 6.4.4.4.)

New paragraph 2.58. defines “Supplier of the tread used for retreading process”, and new paragraph 2.59. defines “Tread used for retreading process”. Under paragraphs 6.4.4.1. and 6.4.4.3., the documents now include a copy of the UN Regulation No. [XXX] certificate(s) instead of a copy of test report(s). In paragraphs 6.4.4.1. to 6.4.4.3., the list(s) of tyre sizes are now those annexed to the UN Regulation No. [XXX] certificate(s). Under paragraph 6.4.4.2., item (a) is now “a copy of the Regulation No. [XXX] certificate(s), as issued by the relevant Type Approval Authority based on the UN Regulation No. 117 certificate(s)”. Under paragraphs 6.4.4.1. and 6.4.4.3., item (d) is now “A copy of the last report of the Conformity of Production as required in UN Regulation No. [XXX]”. For retreaded tyres produced by using pre-cured tread type approved pursuant to UN Regulation No. [XXX], new paragraph 6.4.4.4. says “the retreader shall ensure the packaging of the pre-cured tread bear the sticker with the approval marking till it is open and start to be used for the retreading process unless the approval marking is displayed on the tread shoulder”.

For retreaded tyres retreaded produced by using pre-cured tread material(s) or an identical tread pattern design in a by using mould cure product process with a the same tread pattern not covered by paragraph 6.4.4.2. having and type approved pursuant to fulfil the requirements of paragraph 7.2UN Regulation No. [XXX], the retreader shall ensure that the material manufacturer(s) or the material supplier(s) of the pre-cured tread(s) used for retreading process provides to the Type Approval Authority (TAA) and the Technical Service issuing the approval according to this Regulation and optionally to the retreader:
A copy of the test report(s) as in Annex 10, Appendix 2 and/or 3 of the representative tyre size(s) (see definition in paragraph 2.) demonstrating compliance of the pre-cured tread(s) to the requirements of paragraph 7.2.A copy of the UN Regulation No. [XXX] certificate(s), as issued by the relevant Type Approval Authority.
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Special use tyres, snow tyres and professional off-road tyres (paras. 2.8.2., 2.8.3., 3.2.8., 3.2.13., 4.1.5.3.1. and 7.3.)

“Special use tyre” now means a tyre intended for mixed use, both on- and off-road “or for other special duty”, instead of “and/or at restricted speed”. The “Snow tyre” definition now says “major features including tread pattern” instead of “tread pattern, tread compound or structure”, and “mud and/or snow conditions” instead of “snow conditions”. Under paragraph 3.2.8., a “special use tyre” also bears an M+S inscription when the tyre manufacturer declares it at paragraph 4.1.5.3.1. as complying with paragraph 2.8.3. Paragraph 3.2.13. now adds that tyres with “MPT”, “ML”, “ET” or “POR” “may also bear the inscription M+S or M.S or M&S”. For a professional off-road tyre, paragraph 7.3. now asks for a speed category of ≤ 160 km/h for C2 tyres and ≤ 110 km/h for C3 tyres. Before, it asked for a maximum speed rating of ≤ Q for C2 tyres and ≤ K for C3 tyres.

2.8.4.2.54.
"Category of use":
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Additional service description and load/speed endurance test (paras. 2.39., 6.6.1.1., 6.6.1.2., 6.6.1.2.1., 6.6.3. and Annex 7)

Paragraph 2.39. now defines “Additional service description”, marked within a circle, in place of “Unique Point”. Under new paragraph 6.6.1.1., “In case of retreaded tyre following the load/speed combinations given in the table in Annex 8, the endurance test prescribed in paragraph 6.6.1. above need not be carried out for load and speed values other than the nominal values”. New paragraph 6.6.1.2. says: “In case of retreaded tyre which has an additional service description, the endurance test prescribed in paragraph 6.6.1. above shall also be carried out on a second tyre of the same size, structure and tread pattern at the additional load/speed combination and the applicable inflation pressure”. New paragraph 6.6.1.2.1. gives the conditions under which such tyres can be exempted from an additional load/speed test. The limit of 3.5 per cent on the outer diameter, measured six hours after the load/speed endurance test, now applies “Except for tyres with radial structure” (6.6.3.). In Annex 7, the test load percentage must now be increased for a test drum diameter larger than 1,700 mm ± 1 per cent.

- Able to be used additionally at the Unique Point, 120 km/h (speed category symbol L (reference speed 120 km/h); with a load capacity of 3350 3000 kg (single) and 3000 2725 kg (twinned or dual), corresponding respectively to the load indices 150 146 and 146 143 shown in Annex 4 to this Regulation;
If paragraph 3.2.6. of this Regulation is applied, the additional service description (Unique Point), , comprising the load indices and speed symbol, shall be shown inside a circle near the nominal service description appearing on the tyre sidewall.
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Transitional provisions and extension of approval (paras. 8.3. and 13.1. to 13.4.)

From the official entry-into-force date of the 01 series, no Contracting Party applying this Regulation may refuse to grant or accept 01 series type approvals. Contracting Parties applying this Regulation must continue to accept and extend preceding-series approvals of retreading production units not affected by the 01 series changes. As from 1 September 2025, Contracting Parties applying this Regulation are not obliged to accept preceding-series type approvals first issued after 1 September 2025. Until 1 September 2028, Contracting Parties applying this Regulation must accept, and grant extensions to, preceding-series type approvals first issued before 1 September 2025. New paragraph 8.3. says: “The Competent Authority issuing the extension of approval shall assign a series number for such an extension and inform thereof the other Parties to the 1958 Agreement applying this Regulation by means of a communication form conforming to the model in Annex 1 to this Regulation”. The approval mark example in Annex 2 now shows approval number 109R012439, meeting the requirements of the 01 series of amendments.

[figure changed][figure changed]
The above approval mark affixed to a retreaded tyre shows that the retreading production unit concerned has been approved in the Netherlands (E4) under approval number 109R002439 109R012439, meeting the requirements of 01 series of amendments to this Regulation in its original form (00)..
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Scope, tyre structures, date code and other markings (paras. 1.1., 1.3., 2.26.8., 2.26.9., 3.2.9. and 3.5.)

Paragraph 1.1. now excludes retreaded tyres with a nominal speed category symbol below eighty (80) km/h, instead of a speed capability below 80 km/h. Paragraph 1.3. now excludes tyres originally produced without UN Regulation No. 54 type approval; before, it referred to an “E” or “e” mark. The “Bias belted” structure is deleted: its definition, its “B” and “BIAS-BELTED” marking, and its place in the list of structures in paragraph 4.1.5.2. New paragraphs 2.26.8. and 2.26.9. allow the optional suffix “MPT” for multi-purpose commercial vehicle tyres and the optional prefix “ST” for special trailer tyres. The date of retreading is a group of four digits; the three-digit code for tyres retreaded up to 31 December 1999 is deleted. Paragraph 3.5. no longer says that the markings and the approval mark must be indelible; they must still be clearly legible.

Diagonal (bias ply) and bias belted bias-ply) E 32 32 N 80 - E 32 32
Retreaded tyres with a nominal speed capability category symbol below eighty (80 ) km/h;
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Editorial changes and alignment with UN Regulation No. 54 (definitions and Annexes 1, 3, 5, 7 and 8)

Many definitions and other texts get editorial changes, for example “Load index” becomes “Load-capacity index” and “Speed symbol” becomes “Speed category”. The definitions of “Class C2 tyres” and “Class C3 tyres” no longer say “conforming to Regulation No. 54”. Several references to “Regulation No. 54” now read “UN Regulation No. 54”, and the Agreement reference is now E/ECE/324-E/ECE/TRANS/505/Rev.3. In Annex 1, “APPROVAL GRANTED” now reads “Approval granted”, and the other items change the same way. The Annex 3 examples now use the size 255/70 R 22.5 instead of 295/80 R 22.5. The ETRTO and ALAPA references and addresses are updated.

issued Issued by: Name of the Type Approval Authority:
concerning: APPROVAL GRANTEDApproval granted
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Q2Why it changed

Proposed by
Expert from the small working group on retreaded tyres
Working party
GRBP, 79th session (February 2024)

Reasons

  • The 01 series was proposed to address difficulties that retreaders and Type Approval Authorities faced in practice. These concern the approval of retreading facilities producing “tyres for use in severe snow conditions” and the verification of their conformity of production. One difficulty was acceptance of snow test reports from tread material suppliers or new tyre manufacturers as proof of compliance and for “Alpine” marking. Another was an unclear split of responsibilities between the retreader and the tread material suppliers or new tyre manufacturers, especially for conformity of production.

    Sources (3)
    “This new series of amendments to Regulation No. 109 is proposed in order to address the following difficulties that the retreaders and the Type Approval Authorities have been facing in practice”
    “acceptance of snow test reports provided by the tread material suppliers or new tyre manufacturers as a proof of compliance to the snow requirements and their consequent marking with “Alpine” symbol;”
    “unclear situation concerning the repartition of responsibilities between the retreader and the tread material suppliers or new tyre manufacturers, especially concerning the verification of the Conformity of Production of retreaded tyres”
  • The snow grip prescriptions for retreaded tyres were moved to a new specific UN Regulation for retreaded tyres of classes C1, C2 and C3. The rationale is to segregate type approval of the retreading workshop from the performances of the retreaded tyres, which result from the tread pattern used.

    Sources (2)
    “the removal of the prescriptions of snow grip performance of retreaded tyres from UN Regulation No. 109 and their implementation on a new specific UN Regulation on type approval of retreaded tyres of classes C1, C2 and C3”
    “The rationale behind this proposal is to segregate type approval of retreading workshop from the performances of the retreaded tyres which result from the tread pattern used for the retreading process.”
  • Based on the rationale of point 1, the classification requirements for “traction tyre” were also removed and put in the new specific regulation. There, they are complemented by the new requirements of the 04 series of amendments of Regulation No. 117, with pertinent transitional provisions.

    Sources (2)
    “Additionally, based on the rationale mentioned at point 1, also the current requirements for the classification as “traction tyre” have been removed from UN Regulation No. 109 and implemented in the new specific regulation”
    “and there complemented by the new requirements introduced by the 04 series of amendments of Regulation No. 117 with pertinent transitional provisions.”
  • The full text also got editorial corrections where needed and was aligned as much as possible with the up-to-date UN Regulation No. 54.

    Source
    “Finally, the full text of the Regulation has been made subject of editorial corrections where needed and aligned as much as possible to the text of the up-to-date version of UN Regulation No. 54.”
  • Proposer's reason (informal document GRBP-79-26)

    Paragraph 8.3. was added and paragraph 13.4. was amended to address the extension of type approvals issued before 1 September 2025. Such extensions could still be requested until 31 August 2028 without applying UN Regulation No. [XXX].

    Submitted by Experts of the European Tyre and Rim Technical Organisation. Working party adoption: ECE/TRANS/WP.29/GRBP/77, para. 20.

    Sources (2)
    “Paragraph 8.3 has been added and paragraph 13.4. has been amended by adding a sentence in order to address the extension of type approvals issued before 1 September 2025”
    “that could be still requested until 31 August 2028 without applying UN Regulation No. [XXX].”

Document trail

  1. 2023-11ProposalECE/TRANS/WP.29/GRBP/2024/3Proposal by the expert from the small working group on retreaded tyres
  2. —Amended in sessionGRBP-79-26Changes by the experts of the European Tyre and Rim Technical Organisation
  3. —Amended in sessionGRBP-79-27Consolidated text with the changes of GRBP-79-26
  4. —Working party adoptsECE/TRANS/WP.29/GRBP/77Session report, para. 20
  5. 2024-04Sent to WP.29ECE/TRANS/WP.29/2024/64Text that GRBP sent to WP.29 and AC.1
  6. 2024-06WP.29 adoptsECE/TRANS/WP.29/1179Adopted at the 193rd session (session report, para. 162)
  7. 2025-01-10In forceC.N.56.2025.TREATIES-XI.B.16.109UN depositary notification

Q3Who is affected

Vehicle manufacturer

  • No direct action for this role.

Component supplier

  • Also affix the UN Regulation No. [XXX] approval mark on tyres classified as “snow tyre for use in severe snow conditions” or “traction tyre”.
  • In the case of paragraph 6.4.4.1., make sure the tread manufacturer or supplier provides the documents listed there.
  • Make sure approved pre-cured tread packaging bears the approval marking sticker until use, unless shown on the tread shoulder (6.4.4.4.).
  • Plan an endurance test on a second tyre for tyres with an additional service description, unless paragraph 6.6.1.2.1. exempts them.

Technical service / Approval authority

  • Be ready to receive copies of UN Regulation No. [XXX] certificate(s) and the annexed lists of tyre sizes (6.4.4.1., 6.4.4.3.).
  • Be ready to run the endurance test on a second tyre for an additional service description (6.6.1.2.).

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