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Transmitted by the expert
from the Russian Federation Informal Document TYREGTR (Geneva, 23 January 2017, agenda item 5) Discussion Document Proposal for Introduction of Tyre Global Marking in UN GTR No. 16 January 2017
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Background UN Regulations contain marking provisions; E-marks are mutually recognized by the CPs to the 1958 Agreement. For the CPs to the 1958 Agreement UN GTRs are implemented via UN Regulations. Consequence: All the provisions of UN GTR No. 16 shall be aligned with those of the relevant Tyre UN Regulations and vise versa 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.
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Two cases for consideration
Assumption Let’s assume that the tyre “Global Marking” would indicate that a tyre meets all provisions of UN GTR No. 16. 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. G Two cases for consideration CPs to the both 1958 and 1998 Agreements CPs to 1998 Agreement only
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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
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CPs of the 1998 Agreement - non-1958 Agreement countries…
… would transpose tyre global marking provisions in their national legislation once those become adopted in UN GTR No. 16 A decision could be made to substitute a domestic compliance assessment mark by a tyre global mark 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: The reference list of non-1958 Agreement Countries (ECE/TRANS/WP.29/1073/Rev.15): E = Canada San-Marino China Tajikistan India US Moldova
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G E 22 XYZ 012439 ABC123 Integration of type approval numbers
in Tyre Global Mark (The best way to be decided) Optional solutions ABC123 E 22 XYZ 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).
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More attractive solution: Use of UN DETA Unique Identifier (UI) may simplify Tyre Global Marking
G UI (the number is shown as an example) 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 SG Rev.1) All CPs will have an access to DETA
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Consequent steps forward
Introduce provisions for global marking in UN GTR No. 16 Transpose those provisions into the relevant UN Regulation(s) 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 CPs to the 1998 Agreement recognise in their territories tyres bearing global marks Global mark is considered as equivalent to national/regional compliance assessment mark provided that national/regional compliance assessment procedures are fulfilled
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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
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Thank you for your attention!
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