Upload
others
View
3
Download
0
Embed Size (px)
Citation preview
PART WORN TYRESPublic Consultation
Vehicle StandardsNovember 2013
Part Worn Tyres Consultation
In recent years there has been a large increase in the number of part worn tyres sold and fitted to vehicles in Ireland. The purpose of this document is to seek views from the public, industry and other interested parties on whether or not there is a need to introduce regulations for part-worn tyres. Proposals with regard to such regulations are set out and the option of raising public awareness as an alternative to regulating is also put forward.
Summary
Part worn tyres are tyres which were previously fitted to a vehicle and are
now being offered for sale ‘second-hand’ with less tread remaining that of a
new tyre. In recent years there has been a significant increase in the
number of tyre retailers and independent operators offering to supply and fit
part worn tyres. The Irish Tyre Industry Association (ITIA) estimates that
today, more than 20% of the total number of tyres sold in Ireland1 are part-
worn and that this figure is increasing year on year.
The appeal of part worn tyres has grown in recent years because their price
is normally much lower than new tyres. However, as tyres are the only
contact between a vehicle and the road, it is vital that they are fit for purpose
1 ITIA estimate that there are 2.7 million tyres in total sold in Ireland annually
3
Part Worn Tyres Consultation
and maintained in good condition. Tyres which are in a poor condition may
have an increased braking distance, an increased likelihood of under or
over-steer and a greater possibility of blowout, thereby posing a significant
safety risk to road users.
The Road Safety Authority (RSA) now wishes to establish whether or not
there is a need to introduce controls and minimum standards for part worn
tyres before they can be offered for sale and fitted to vehicles. Therefore, we
are now consulting with members of the public, industry and other interested
parties to get their views on this matter. If the consultation highlights that
there is a need for controls in this area, then proposals will be put forward to
the Minister for Transport, Tourism and Sport.
1. Background
Most part-worn tyres sold in Ireland originate from continental European
Member States and have been exported due to season laws. For example,
winter tyres are mandatory during the winter months in Austria, Finland,
Germany and Sweden. In these countries when winter approaches, vehicle
owners tend to trade in their summer tyres for winter tyres and often these
tyres end up being exported to countries such as Ireland. Whereas most of
these tyres could be considered fit for purpose (and are sometimes a better
quality tyre than some new budget tyres) there are no specific regulations
that part-worn tyres need to meet before being placed on sale in Ireland.
The attraction of part-worn tyres has grown, particularly in the current
economic climate, as part worn tyres may be purchased for around €30 as
opposed to a new equivalent tyre which may cost €80.
4
Part Worn Tyres Consultation
2. Current Legal Requirements for Tyres in Ireland
It is a key basic road safety requirement that all vehicles and trailers on our
roads, and all components of those vehicles, conform to a minimum
standard of construction. It is the legal responsibility of the owner and driver
of a vehicle or combination of vehicles to ensure that, when it is used in a
public place, it is in such a condition that it is not liable to endanger other
road users. The Road Traffic (Construction and Use of Vehicles)
Regulations 2003 (S.I. No. 5 of 2003) as amended, also known as the ‘C&U’
Regulations, sets out requirements with respect to tyre condition and tyre
tread depth for vehicles which are used on a public road. These regulations
include requirements that each tyre fitted to a vehicle has a tread depth of at
least 1.6mm is maintained in a condition so that it is fit for purpose, and is
free from defects which may cause damage to the road surface or endanger
other road users.
Enforcement of the C&U Regulations is a matter for An Garda Síochána and
on conviction; courts can impose a class C fine (up to €2,500), a prison
sentence or both, on both the owner and driver of the vehicle.
In addition when undergoing the the National Car Test (NCT) and
Commercial Vehicle Roadworthiness Test (CVRT), all vehicles have their
tyres inspected for; tread depth, condition and the presence of European
type approval (‘E’ or ‘e’) marks.
There are no specific regulations for part-worn tyres in Ireland and, as such,
they can be legally fitted and used on vehicles providing they meet with the
C&U requirements referred to above. On the other hand, there are EU
regulations which have been given effect in Irish law that set the standard
for new and re-treaded tyres;
2.1 New Tyre Requirements
5
Part Worn Tyres Consultation
New tyres placed on sale are required to meet with the latest type approval
standards (Regulation (EC) No. 661/2009) and carry an ‘E’ or ‘e’ mark. Type
approved tyres must meet with minimum requirements with regard to wet
grip, rolling resistance and noise. Further to this, a new Commission
Regulation EC No. 1222/20092 requires that new tyres are labelled at the
point of sale showing the tyre's wet grip, fuel efficiency and noise
performance. The tyre labels are similar to the labelling already in use for
household goods such as washing machines and dishwashers. The aim of
these labelling requirements is to encourage people to purchase tyres with
superior safety and environmental performance, and also encourage tyre
manufacturers to produce tyres whose performance exceeds the minimum
requirements specified in EU Regulations.
2.2 Retreaded tyresRetreaded tyres are older tyres that have been recoated with a rubber
veneer of tread. In Ireland the sale and supply of retreaded tyres is
governed by the Road Traffic (Retreaded Tyres) Regulations 2008 (S.I. No.
118 of 2008)3.
For a retreaded tyre that complies with these regulations to be placed on the
market, purchased, sold or fitted to a vehicle or trailer, it must conform to a
type that has been type approved and must bear the required ‘E’ or ‘e’ mark.
Once retreaded at an approved production unit, it must also bear the word
‘Retread’ on its sidewall. Tyre production units or retreading centres must be
approved by the National Standards Authority of Ireland (NSAI).
2 For information, please see the Department of Communications, Energy and Natural Resources website at the following link; dcenr.gov.ie/tyre labeling
3 These Regulations gave effect to Council Decision 2006/443/EC, requiring that retreaded tyres conform with UNECE Regulation 109 (retreaded tyres for commercial vehicles and their trailers) and UNECE Regulation 108 (retreaded tyres for private cars, light goods and light trailers).
6
Part Worn Tyres Consultation
3. Economic Considerations for Consumer
Buying part-worn tyres may offer substantial savings to consumers at the
time of purchase. However, when consideration is given to the shorter
lifespan and the cost per millimetre (mm) of usable tread on a part worn
tyre, new tyres may actually prove to be better value for money for the
consumer in the long term. Consider the example of a part worn tyre which
costs €30 and has 3.6mm of tread remaining. This tyre will have 2mm of
available tread wear before the minimum legal depth of 1.6mm is reached.
Therefore the cost of the tyre can be equated to €15 per mm of available
tread. On the other hand a new tyre costing €80 will have 8mm of tread or
6.4mm of available tread wear, which equates to €12.50 per mm or a 17%
cost reduction. In addition to the increased costs in the example above, the
vehicle owner will have to fit three sets of part worn tyres to get the same life
as one new set of tyres.
However, in contrast to the example above, a part-worn tyre which is in
good condition and with a significant amount of tread remaining may offer
better value to a consumer than buying a new tyre. Similarly, a driver who
does low annual mileage may find that fitting part-worn tyres makes better
economic sense than fitting new ones, as their tyre change intervals will be
less frequent.
4. Situation in the UK
Ireland and the UK are common destinations for part-worn tyres, primarily
because neither have seasonal laws and allow winter or summer tyres to be
used all year round. However, in contrast to Ireland, the UK has developed
regulations which make it illegal to supply part-worn tyre unless certain
conditions are met. In the UK, part-worn tyres must have at least 2mm tread
depth, marked 'PART WORN', any repairs must comply with British
Standards, and it is illegal to have unsafe tyres in possession for sale.
7
Part Worn Tyres Consultation
As a consequence of the UK having part worn tyre regulations, there is a
concern that Ireland may have become an effective dumping ground for low
quality part-worn tyres.
5. Options
As outlined in section 2, the C&U Regulations set the minimum standards
for tyres fitted to a vehicle used on Irish roads. However, as these
regulations are only enforced when a vehicle is in use, there is no regulatory
check on the condition of part-worn tyres before they are sold or fitted to a
vehicle. In light of this, the RSA is proposing three options for consideration
as follows;
5.1 Option 1 - Do NothingThe first option is to do nothing. It will continue to be legally possible to fit
part-worn tyres which have the minimum legal tread depth of 1.6mm. There
will be no additional obligations on retailers and therefore no additional cost
passed on to the consumer.
5.2 Option 2 - Introduce controls for part-worn tyres
The second option is to introduce regulations that control the standard of
part-worn tyres. By introducing regulations, the responsibility would be
placed on the part-worn tyre seller to ensure that tyres offered for sale have
a specified minimum tread depth and have condition checks carried out.
Only such tyres may then be labelled as ‘part worn’ thereby giving the
consumer peace of mind that a positive check has been carried out on the
tyre’s condition and tread depth.
If such regulations are to be developed, then a public awareness campaign
would be carried out in partnership between the RSA and the tyre industry.
8
Part Worn Tyres Consultation
This campaign would draw attention to the new requirements being
introduced – that all part-worn-tyres have undergone an inspection prior to
sale, therefore giving the consumer confidence that the tyres being
purchased are fit for purpose. In the following subsections, possibilities with
regard to the regulation of part-worn tyres are put forward;
5.2.1 Tread Depth
In any such regulations, a minimum tread depth for part-worn tyres would
need to be specified. The minimum legal tread depth for vehicles on the
road is 1.6mm, new tyres have about 8mm of tread and 2mm is the change
interval that most tyre manufacturers recommend. In order to ensure that
consumers achieve a reasonable lifespan from part-worn tyres they may
wish to buy, consideration should be given to setting their minimum tread
depth at 3mm before they can be offered for sale.
5.2.2 Tyre Condition
While the condition of most part worn tyres placed on sale may be
reasonably good, any regulations which are introduced should require that a
condition check is carried out on all part-worn tyres before being offered for
sale and fitted to a vehicle.
This condition check should ensure that tyres are ‘E’ or ‘e’ marked and do
not have;
any cut over 25mm which is deep enough to reach the ply or cord
any internal or external lump, bulge or tear
any ply or cord exposed internally or externally
penetration damage that has not been repaired
9
Part Worn Tyres Consultation
5.2.3 Inflation Test
A further measure that should be considered is that each part-worn tyre is
examined once it has been fitted onto the wheel rim and inflated in order to
ensure that it does not exhibit any of the external defects referred to in 5.1.2.
5.2.4 Labelling
Only when a part-worn tyre has met with all of the specified requirements,
can it be labelled as 'PART-WORN' and legally offered for sale to the public.
In order to achieve this, rubber labels can be cold vulcanised (similar to
applying a patch) to the tyre. These labels are inexpensive and widely
available from trade suppliers.
5.2.5 Certification to accompany part-worn tyres sold
A requirement could also be introduced through regulation that each part-
worn tyre sold is accompanied with a unique certificate. This certificate
would contain information specific to the tyre such as:
depth of tread remaining (compared that of a new equivalent tyre)
tyre size and aspect ratio
load rating
speed rating
year of manufacture
Winter tyre (yes/no)
Country of origin (where previously used)
5.2.6 Enforcement
If this option is agreed and regulations are introduced to control the
standard of part worn tyres, then enforcement options will be considered
and an appropriate enforcement scheme implemented. It is most likely that
enforcement will be at the point of sale and will comprise of inspection of
10
Part Worn Tyres Consultation
part-worn tyres, either at the distributor or tyre fitters place of business, to
make sure that they meet with the necessary provisions before being legally
sold or fitted to vehicles.
5.2.7 Cost implicationsOption 2 will most likely result in a slight increase in the price paid by the
consumer for a part-worn tyre. This is because the retailer will probably pass
on the costs associated with checking, labelling and certifying each
individual tyre. There will also be a cost associated with the awareness
campaign.
5.3 Option 3 – No new regulations, but instead raise public awareness The third option is to not introduce new regulations and just carry out a
public awareness campaign. With this option it will continue to be legally
possible to fit part-worn tyres which have the minimum legal tread depth of
1.6mm and there will be no additional obligations on retailers. The public
awareness campaign would highlight to the consumer the importance of
taking factors such as tyre condition, tread depth and economic factors into
consideration when purchasing a part-worn tyre. The public would be
encouraged to only purchase tyres from retailers that follow RSA
recommendations with regard to their inspection, labelling and certification.
There will be a cost associated with carrying out this awareness campaign.
6. Your views
The RSA believes that Option 2 (i.e. Regulation and awareness) is the
optimum approach as it introduces minimum standards to support both
industry and consumers and will also ensure that consumers are aware of
11
Part Worn Tyres Consultation
the criteria that a part-worn tyre must meet in order to be legally offered for
sale, including that each tyre has been inspected, tested, labelled and
certified.
12
Part Worn Tyres Consultation
The RSA wishes to hear from road users, industry and all other interested
parties who have views and suggestions on part worn tyres. It would be
helpful if, when you reply, that you complete the two tables that follow and
that you could focus your response on the questions put forward, though we
would, of course, also be pleased to consider any other comments that you
may wish to make.
PART 1 - Information about you
13
Part Worn Tyres Consultation
Name
Address
Company Name or Organisation
(if applicable)
Please tick one box from the list below that best describes you or your
organisation.
Member of the public
Company
Representative Organisation
Public body
Interest Group
Other (please describe):
Are you (or your company) involved in the supply or fitting of;
Part-worn tyres
only
New tyres only Both Neither
14
Part Worn Tyres Consultation
PART 2 - Your Comments
15
Part Worn Tyres Consultation
Question Response
Q1:
What is your preferred
Option for dealing with Part
Worn Tyres in Ireland?
Insert “X” as appropriate
Option 1 (Do Nothing)
Option 2 (Regulate andAwareness Campaign)
Option 3 (Awareness Campaign only)
If you chose Option 1 or 3 please explain why;
If you chose Option 1 or 3, please proceed directly to Q6
Q2:
Are there any tyres which
should NOT be included in
the regulation of part worn
tyres?
Insert “X” as appropriate
YES
NO
If your answer is YES, please explain which types of tyres should be omitted and the reasons why:
Q3:
Do you agree with the
suggested minimum tyre
tread depth of 3mm for part
worn tyres?
Insert “X” as appropriate
YES
NO
If you have alternative suggestions with regard to tread depth, please explain:
16
Part Worn Tyres Consultation
Q4:
Do you agree with the
suggestions with regard to
the condition check and
subsequent labelling and
certification of a tyre before
sale?
Insert “X” as appropriate
YES
NO
If you have comments or alternative suggestions with regard to these criteria, please put forward:
Q5:
Do you agree that any part-
worn tyre regulations
developed should be
enforced at the point of sale.
Insert “X” as appropriate
YES
NO
Have you any comments or alternative suggestions with regard to enforcement?
Q6: Have you any other comments?
17
Part Worn Tyres Consultation
7. How to Respond
The consultation period begins on 8 November 2013 and the closing date
for submissions is the 20 December 2013. Please ensure that your
response reaches us by that date.
Please send consultation responses to:
Part Worn Tyres Consultation,
Vehicle Standards,
Moy Valley Business Park
Primrose Hill
Ballina
Co. Mayo
E-mail to: [email protected]
Tel No: 096 25014
18