Transmitted by the expert from the Russian Federation Informal Document TYREGTR-16-04 (Moscow, 7-9 June 2017, agenda item 7) Discussion Document Proposal for Introduction of Tyre Global Marking in UN GTR No. 16 June 2017

Background UN GTR No. 16 Statement on technical rationale and justification, para. 27: 27. Consideration was given to harmonize the approval markings (both type approval and self-certification markings) and discussions on this issue were elevated to WP.29 and AC.3 meetings. It was concluded as not possible currently to adopt a harmonized approval marking since the compliance assessment procedures are not yet harmonized worldwide. So this gtr contains no administrative provisions on approval markings. In the absence of a harmonized marking, the Contracting Parties retain the option to assign markings to tyres, especially markings for a "global tyre", and these can be introduced within their national / regional compliance assessment systems.

Assumption Let’s assume that the tyre “Global Marking” would indicate that a tyre meets all provisions of UN GTR No. 16*. * No variation of “Global Marking” means that in a case when a requirement exists in several options, compliance with only one option could be confirmed; such an option has to be selected. If such a provision were transposed in national/regional legislation of the CPs to the 1998 Agreement, and in UN Regulations, that provision would fix a status that a tyre bearing such marking is in compliance with national/regional law of the particular counties/regions. For CPs to the 1958 Agreement the GTR provisions are transposed via UN Regulations, so complete alignment of UN GTR 16 and the relevant UN Regulations is needed. G

Two cases for consideration CPs to the both 1958 and 1998 Agreements: UN Regulations contain marking provisions; E-marks are mutually recognized by the CPs to the 1958 Agreement. If G-mark were in UN Regulations with the relevant provisions, it will be mutually recognized by the CPs to the 1958 Agreement CPs to 1998 Agreement only: UN GTR No. 16 provisions should be directly transposed to relevant national regulations The reference list of non-1958 Agreement Countries (ECE/TRANS/WP.29/1073/Rev.18): Canada San-Marino China Tajikistan India US Moldova

Е22 G Е22 How that would work for Tyre UN Regulations? UN GTR No. 16 All the provisions of UN GTR No. 16 have to be transposed to Tyre UN Regulations, some of them may become optional (this is in line with 1998 Agreement) UN GTR No. 16 Physical dimensions Strength test Bead unseating test Rolling sound test Low inflation test etc. A set of tyre UN Regulations or one new UN Regulation? Physical dimensions Rolling sound test etc. Bead unseating test Low inflation test Е22 G Е22 Regional Marking Global Marking The provisions for marking to be established in the UN Regulation, where the GTR provisions to be transposed E22 is present as an example only Compulsion of provisions is not established Compulsory provisions Optional Provisions

Legal obligations for putting G-mark on a tyre CPs to the both 1958 and 1998 Agreements: Marking provisions in (a) relevant UN Regulation(s) oblige for putting G-mark on a tyre A tyre manufacturer assumes the obligation to provide compliance with (a) relevant UN Regulation(s) and, as a consequence, with UN GTR No. 16 CPs to 1998 Agreement only: Marking provisions in relevant national regulations oblige for putting G-mark on a tyre A decision could be made to substitute a domestic compliance assessment mark by a tyre global mark A tyre manufacturer assumes the obligation to provide compliance with relevant national regulations and, as a consequence, with UN GTR No. 16

Global Mutual Recognition of a G-mark Actually global mutual recognition could not be foreseen Indirect mutual recognition will be followed as all CPs to 1998 Agreement would accept tyres with G-mark Practical Solution A positive example refers to the Customs Union Technical Regulation “Concerning Safety of Wheeled Vehicles” (CU TR 018/2011), where E-mark substitutes EAC-mark: E =

Consequent steps forward Global mark is considered as equivalent to national/regional compliance assessment mark provided that national/regional compliance assessment procedures are fulfilled CPs to the 1998 Agreement, in fact, recognise in their territories tyres bearing global marks CPs to the 1998 Agreement (non-1958 Agreement countries) transpose all the provisions of UN GTR No. 16 in their national law including those for global marking thus making them applicable at national level Transpose those provisions into the relevant UN Regulation(s) Introduce provisions for global marking in UN GTR No. 16

Questions to the CPs to the 1998 Agreement Whether the approach for tyre global marking can be supported? Would that be reasonable to recognise tyre global marking as an alternative to your national compliance confirmation marking? Please send your feedback to Mr. Andrei Bocharov (ab@satrfond.ru)

Thank you for your attention!

Back-up

G ABC123 E 22 XYZ 012439 Integration of type approval numbers in Tyre Global Mark (The best way to be decided) Optional solutions ABC123 E 22 XYZ 012439 G The space for marking corresponding to the approval numbers granted by the countries, which are not the Contracting Parties to the 1958 Agreement, and the auxiliary marking (if any) used by the countries applying the self-certification procedures (the number is shown as an example). The space for marking granted in accordance with the mechanism of the 1958 Geneva Agreement (the number is shown as an example).

More attractive solution: Use of UN DETA Unique Identifier (UI) may simplify Tyre Global Marking 0000012439 G UI UI is generated by the UN secure internet database (DETA) and linked to UN type approvals stored in DETA (Reference: Draft Revision 3 of the 1958 Agreement, Schedule 5 – document ECE/TRANS/WP.29/2016/2) Thus UI refers to a particular type approved product Type approvals to Regulations other than UN (e.g. CCC) may be linked to the same UI as well (Reference: Draft Guidelines for application of the UI – document SG58-22-10-Rev.1) All CPs will have an access to DETA