Retreading Legislation – Lack of direction from Brussels
“The European Truck Tyre retreading industry is healthy and provides the transport industry with high quality products which allows them to reduce tyre cost and transport cost. However, retread products are not legislatively treated equally to new tyres, and this is a growing threat to sustained growth for this industry”. The legislative problems faced by the retreading industry were outlined to T & A by Lennart Lindström – product manager at Bandag Europe – during Autopromotec 2003.The basis for the EU legislative framework is the Whole Vehicle Type Approval (WVTA) directive 70/156/EEC. This directive sets out the rules for the use and production of many vehicle parts, including tyres. Up until now, the WVTA has not taken into account the existence of retreaded tyres, nor have any of the quite numerous regulations and directives that exist for new tyres. All legislative work on tyres in the EU is solely focusing on new tyres. The WVTA does not yet exist for trucks, but work is underway to introduce this certification for trucks, and then new truck tyres must meet the same requirements.The certification principle for type approval implies that each authority grants authorisation for a vehicle, a system, a component (like tyres) and this authority remains solely responsible for the conformity of production of the certified product.For retreads ECE Regulations 108 (passenger tyres) and 109 (truck tyres) exists.Despite industry efforts to introduce ECE 108 and 109 into an EU mandatory directive, Brussels has not taken any visible initiative.In absence of the expected and desired EU directive, some member states have started to introduce ECE regulations 108 and 109 into national mandatory legislation. This is the case in France, Spain, Poland, Croatia and the Czech Republic. Other countries like the UK, Sweden and Denmark have begun the national legislative process to introduce them. This still leaves a great number of countries with no active plans to introduce these regulations. It is estimated that over 200 retread companies out of approximately 700 active companies in Western Europe have gained their ECE 109 certificate to date. Absence of equal rules creates an unfair competitive market.Bandag are suggesting that it is necessary to form a retread industry interest group, in order to proactively define potential future legislative content on matters like noise, wet traction and rolling resistance, and work in close co-operation with legislative bodies. BIPAVER and BLIC should, perhaps, take the joint initiative to the creation of such a group.The need to recruit new members to BIPAVER, including supplier members was emphasised by RMA secretariat, Sheila Ikin. This is especially relevant now that BIPAVER is focused on the interests of the retreading industry. One of the causes taken up is the unjustified ban on the importation of retreaded tyres, currently operative in 11 countries known to the RMA. There is a definite need to protect the retread industry against damaging legislation, hence the moves by BIPAVER to persuade Brussels to transpose ECE 108 and 109 from a recommendation to a directive.