service bulletin 1210

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Copyright ©NTDA 2010

NEWSwww.ntda.co.uk SERVICE BULLETINPart Worn Tyre surveyIn the past, surveys of part worn tyre dealers have consistently shown that the vast majority of part worns on sale are illegal. The laws relating to the sale of part worns are very clear and cover a number of points, including the condition of the tyre, tread depth and sidewall markings required.

In September, the NTDA invited member companies to take part in a nationwide survey of part worn tyres to see if the situation had changed. An employee from each participating company purchased a part worn tyre from a local dealer, posing as a member of the public, and the tyre was then checked against a brief supplied by the NTDA, based on the legal requirements. This brief and the results are given below.

CoNDITIoN

Part worn tyres are NOT permitted to have any of the following defects, when either defl ated or infl ated to the highest pressure at which they are designed to operate. Please indicate whether the tyre has any of the following:

1. Any cut over 25mm or 10% of the section width of the tyre (whichever is the greater) on the outside of the tyre, deep enough to reach the ply or cord.

Yes 10% No 90%

2. Any internal or external lump, bulge or tear caused by separation or partial failure of its structure.

Yes 15% No 85%

3. Any ply or cord exposed internally or externally.

Yes 10% Yes 90%

4. Any penetration damage that has not been repaired.

Yes 20% No 80%

When infl ated, the tyre must not exhibit any signs of the defects as listed above and, in addition, part worn tyres MUST BE in such a condition that:

5. The base of any groove that showed in the original tread pattern of the tyre must be clearly visible.

Yes 83% No 17%

Need we say more!!!!!

A repair which is clearly on the sidewall and does not comply with BSAU 144?

If there are any topics that you would like to see included in future service bulletins please contact the Editor Peter Gardner by email at: [email protected] or NTDA direct at: [email protected] or call 0889 67 07 07.

Issue 12/10

Season’s Greetingsto our all members

and Best Wishes for a Happy and Prosperous 2011

NEWS www.ntda.co.ukSERVICE BULLETIN

6. The grooves of the original tread pattern of the tyre must be at least 2mm deep across the full width of the tread and around the entire outer circumference of the tyre.

Yes 90% No 10%

MARKING

7. The words ‘PART WORN’ in upper case letters and at least 4mm high must be permanently, and legibly, applied to the tyre. It is not permitted to do this via hot branding or by cutting into the tyre.

Yes 3% No 97%

8. The appropriate EC approval mark.

Yes 93% No 7%

9. A speed category symbol and load capacity index, these being the marks that were moulded on to or into the tyre at the time of manufacture.

Yes 98% No 2%

NB Failure to comply with these regulations is an offence. Conviction of such an offence could render part worn tyre dealers liable to a penalty of six months’ imprisonment or a fine of up to £5,000.

Prices Paid

£10 12%£11 - £14 5%£15 27%£16 - £19 2%£20 37%£21 - £30 10%£31+ 7%

CoNClusIoNs

The first thing to mention is that 97% of the part worns examined were illegal, due to the fact that they were not marked as part worn. While this is strictly not a safety issue, it does perhaps give a pointer towards the dealers’ attitude towards part worn legislation in general.

On the subject of safety, the tyres do not come out of the survey well, with 15% having cuts, bulges or tears (points 1 & 2) and 15% having the ply or cord exposed (3). The really worrying statistic, however is point 4, which reveals that more than one in four of the tyres examined had unrepaired penetration damage, greatly increasing the chances of a blow-out.

One of the accusations levelled at part worn tyres is that it is impossible to be certain about their previous history; how they have been maintained or treated, or even where they come from. This latter point is neatly illustrated by the response to point 8, which shows that 7% of the tyres were not even originally destined for the European market, as they did not carry the E-mark.

Another factor to consider alongside the safety and provenance issues is that of value for money. A part worn tyre can have as little as 2mm of tread remaining, which means 0.4mm above the legal minimum – probably just enough to get you to the shops and back. Looking at the ‘Prices Paid’ section above, more than half (54%) of the respondents paid at least £20 for a part worn tyre and, while it is true that few new tyres are that cheap, you do get at least 6mm of usable tread on a new tyre. 7% of people paid more than £31 for their part worn and this definitely brings it within the price range of a new budget tyre. To add further weight to the value for money argument, according to the answers to point

cold, wet and snowy conditions and should lead to fewer insurance claims. Little wonder that the reader referred to earlier thought that he might be entitled to a discount!

Not all insurance companies are hiking up premiums for cold weather fitment – one contributor to the forum was commended by his insurer for reducing the risk of an accident (no discount though!). The consensus of opinion on the forum is that the insurance companies are suffering from a lack of knowledge and have the mindset that change invariably = modification. “Look for the more intelligent companies and try to speak to someone who knows something about the subject” is the advice from some unhappy and bemused motorists.

And it is not just motorists, as Neil Greig, director of policy and research at the Institute of Advanced Motorists, is quoted on the Auto Express website as saying: “I’m surprised – [cold weather] tyres’ safety benefits are clear, I think they’d outweigh any additional costs.” Leaving aside the question, ‘what additional costs?’, perhaps we should start lobbying for cold weather tyre discounts on our insurance premiums, although the signs are not hopeful.

Government’s inaccurate cold weather tyre adviceFollowing a statement in the House of Commons yesterday by Secretary of State for Transport, the Rt Hon Philip Hammond MP, the Tyre Industry has expressed its disbelief and concern over the Government’s lack of understanding about the added safety benefits of winter weather tyres. Despite many independent tests proving that winter weather tyres are the safest option for drivers across the entire winter period, Mr Hammond incorrectly claimed they were not appropriate for UK situations.

Following the announcement by the Minister the Tyre Industry Federation has written to him saying that

the statement was “erroneous and needed urgent correction”, the Industry awaits his reply…!!!

TyreSafe chair Stuart Jackson commented in a press release issued soon after the comments were made “Mr Hammond’s comments show a complete lack of understanding about modern winter tyres which are the ideal solution to the type of weather we are currently experiencing.”

He went on to explain that studless winter tyres are designed to provide much better grip over the entire winter period, not just for when people are driving for long periods on compacted snow as he implied. They do not damage road surfaces in any way and are wholly appropriate for the UK situation.

Winter weather tyres can be used all year round but their performance is notably better when temperatures fall below seven degrees Celsius. In these conditions ‘standard’ tyres begin to harden and lose their ability to grip the road surface properly. Winter weather tyres contain more natural rubber and advanced silica compounds to reduce the hardening process and improve grip. Tests conducted by the British Tyre Manufacturers Association found that a car braking at 60mph on a wet road at five degrees Celsius stopped five metres shorter, equivalent to more than one car length, when fitted with winter weather tyres. On ice and snow covered roads the difference was even more remarkable. The car equipped with winter tyres stopped 11 metres sooner on ice and eight metres sooner on snow, from just 20mph.

Mr Hammond also stated that “winter tyres wear out very quickly on normal road surfaces” but this is not the case as in winter conditions, winter tyres do not wear any more quickly than conventional tyres and are manufactured with a deeper tread to improve performance.


Cold Weather TyresThe recent cold snap has led to a marked increase in the number of calls from members of the public to the NTDA, with queries about cold weather tyres. At the same time, the NTDA’s Technical Helpline says that it has received lots of calls from tyre dealers, mainly about the availability of cold weather tyres.

Last winter’s snowy weather, combined with the efforts of the tyre trade to spread the word, have resulted in greatly increased awareness of the advantages of cold weather tyres and subsequent demand for the product this time around. Consequently, many tyre dealers are experiencing difficulty in sourcing cold weather tyres.

Going back to the public’s enquiries, one of the most common questions has been “how do I recognise a cold weather tyre?” The correct answer is that the sidewall will include a pictogram of a three-peaked mountain plus a snowflake. It may also bear the initials M+S, but this does not denote a cold weather tyre, even though the M+S stands for “mud and snow”.

This has been made clear in recent legislation passed in Germany, which makes it an offence to drive on summer tyres in ice, snow or slush. Drivers

face a fine of 40 Euros, which rises to 80 Euros if a traffic delay is caused.

German authorities have indicated that tyres marked M+S will satisfy the statutory requirements, but it is made plain that this is a temporary measure.

This opens up the question (also a popular one for the NTDA) about what are the regulations in Continental Europe about fitting cold weather tyres. The last issue of the TWG Newsletter contained a map showing where cold weather tyres were mandatory, where they should be fitted if indicated by road signs, or where there were no regulations relating to these tyres.

The situation is very complicated and although some organisations have tried to come up with a comprehensive list, Continental recently published such a list and have kindly given us permission to send it to members however, the advice of the Technical Helpline is for members of the public to contact the tyre manufacturer with details of their journey and to seek their advice.

Cashing in on the Cold WeatherLast winter’s snows and the current inclement weather have greatly increased awareness of cold weather tyres among the motoring public. An article on the website of leading car magazine Auto Express acknowledges this fact, while at the same time bemoaning the shortage of cold weather tyres in the market place.

The article also highlights a trend which is both worrying and, frankly, more than a little bizarre; the fact is that, far from rewarding responsible behaviour, some insurance companies are actually charging increased premiums for customers who are fitting cold weather tyres.

Not surprisingly, the message forum on the Auto Express website has much to say on the subject, with phrases such as “rip off” and “it beggars belief” being bandied around.

One Auto Express subscriber phoned his insurance company to tell them out of courtesy that he was going to fit cold weather tyres on his Renault Laguna and was told that the “modification” would mean an insurance premium increase of £230! Another rang his insurer (a different company) to see if he could get a discount and was told that his premium would go up by £22. Neither was best pleased.

Yet another reader was told that changing from alloys to steel wheels is a modification and that there would be a premium increase, plus an admin charge of £17.50. This charge would also be levied when the cold weather tyres were changed back for summer tyres. Actually, this story had a happy ending, as the motorists got to speak to a complaints advisor, who eventually agreed that the modification was for safety reasons and there would be no charge, although it took some time to convince him.

What possible justification can there be for these increases? Fitting a tyre hardly count as a “modification”, although it could be argued as such if the size of the wheels is changed. But fitting a cold weather tyre of the same size is surely like fitting a new tyre when the old one is worn out – and who tells their insurance company every time they change a tyre?

One contributor to the forum suggested that going from a W-rated summer tyre to an H-rated cold weather tyre could be viewed as a modification, but so what? After all, if your car is fitted with, say, V-rated tyres and you decide to replace them with H- or T-rated tyres, then you are not doing anything illegal (at least, not in the UK, but the same isn’t true for Germany). The handling probably won’t be as good, but you are not breaking the law, neither do you have to inform your insurance company.

The safety advantages of cold weather tyres have been thoroughly explained – indeed, Auto Express recently ran an eight-page test feature on the subject – and fitting them to your car means safer driving in

6, 10% of the buyers were even worse off, as their tyres didn’t even have the legal 2mm tread depth.

The final point is that of the penalties for non-compliance (six months’ jail or a £5,000 fine). When was the last time you heard of an errant part worn dealer going to jail? Indeed, has it ever happened? Or has a four-figure fine ever been imposed? In the NTDA survey, at least 97% of the tyres did not comply with legislation. If the information were to be made available to the appropriate authorities, I wonder what percentage of the dealers would be prosecuted?

Based on this definition, today’s winter tyres really are not M+S winter tyres at all. The popular ContiWinterContact TS 810 Sport with its sophisticated asymmetric tread design is a rather delicately-designed high-tech link between the car and the road. The M+S definition makes no mention of the important tread compound suitable for winter conditions. The snowflake symbol, which can be found on nearly all high-performance winter tyres, shows that a tyre has a ‘winter’ compound. Tyres with the snowflake symbol when tested were shown to be at least seven percent better when ABS braking on snow than a reference standard tyre with M+S marking.

Thanks to Continental Tyre Group plc


Below is Continental’s latest winter tyre rule information, listed country-by-country.

Austria: From 1 November to 15 April it is illegal to not have winter tyres, which must have a tread depth of at least four millimetres. In addition, snow chains can also be mandated for certain stretches of road. Studs are permitted on vehicles up to 3.5 tonnes; speed limits apply.

Czech Republic: Winter tyres are mandatory from November 1 until March 31 by law, but only on certain highways, indicated by special road signs.

estonia: Winter tyres are mandatory from December 1 to the end of February, although this can be shortened or extended, depending on weather conditions. Studs are not permitted.

Finland: Winter tyres are mandatory from December 1 through the end of February for both foreign and local vehicles.

Germany: According to German road traffic regulations (StVO), motorists are required to adapt the equipment of their car to the weather conditions, so it is a “situation-based winter tyre requirement”. Motorists who violate this regulation are subject to fines and may have punitive points added to their driving licence. An amendment is likely to be made to the law this winter, specifying the weather conditions and tyre qualities in greater detail. An increase in fines is also expected in coming years.

latvia: Winter tyres are mandatory from December 1 through the end of February.

lithuania: Winter tyres are mandatory from 1 November to 1 April.

slovakia: Winter tyres are mandatory.

slovenia: Winter tyres are mandatory from 15 November to 15 March, with a minimum tread depth of four millimetres. But according to Slovenian law,

two winter tyres per vehicle are sufficient. However, experts say that winter tyres must be fitted on all wheels to avoid handling and braking problems.

Guidance for other European countries:

Belgium, Netherlands and luxembourg: While winter tyres are not mandatory, it is advisable to fit vehicles with winter tyres. In the hilly regions along the German border, snow is nearly a certainty with temperatures below freezing common in winter. Without winter tyres, the braking distances become longer. Studded tyres are forbidden so winter tyres are a good option to keep you moving in the BeNeLux region.

Denmark: The Danes are not required to have winter tyres, but a large percentage do change them. Studs are permitted, but are hardly ever used. In view of the cold temperatures alone, winter tyres are recommended.

France: Winter tyres are not mandatory. Snow chains may be obligatory for certain stretches. Studded tyres can be fitted on cars as well (from the beginning of November to the end of March, with speed limits of 55 mph out of town, 30mph in town). The car must have a sticker indicating that it is equipped with studded tyres. Despite the fact that winter tyres are not mandatory, it is safer to use them in areas such as the French Alps.

Italy: The use of winter tyres is not a requirement, although they can be specified for certain stretches of road. There are no specific regulations regarding the use of snow chains. Anyone choosing to fit studded tyres must comply with the speed limits (55 mph out of town and 30mph in town)

Norway: Foreign vehicles in Norway are not required to have winter tyres, but it is highly recommended. In general, all motorists are required to equip their vehicles with tyres that are suited to the weather conditions and - if necessary - to carry snow chains.

Of the European countries in the following list – the UK, along with Ireland, has remained in winter tyre splendid isolation – specific cold weather tyres are mandatory in just over the half, although several countries do not require foreign registered vehicles to have them fitted.

Over half of UK motorists have never even heard of winter tyres, according to a survey by Continental Tyres. There are no regulations or even guidance for winter tyres in this country, so it’s not surprising that most drivers are unaware of the winter tyre laws that exist in other European countries. In order to educate motorists, here is a guide from Continental Tyres, the European market leader in winter tyres.

Poland: It is not a legal requirement to have winter tyres. However, since there is hardly any snow removal in the countryside, driving without reliable winter tyres is a major risk.

Romania: There are currently no regulations regarding winter tyres in Romania. The Ministry of Transportation has announced that the government will approve an emergency ordinance in December 2010 requiring motorists to equip their vehicles with winter tyres from 1 November to 31 March. The new regulation will go into effect in 2011.

sweden: Foreign vehicles are not required to have winter tyres. Winter tyres are however mandatory for Swedish vehicles. But driving in Sweden without winter tyres is not recommended since grit is not spread on many roads.

switzerland: Winter tyres are not mandatory. However, winter tyres are recommended since if there was an accident which is proven to have been caused by summer tyres, the driver may be held jointly liable, which can have significant consequences. The Swiss collision insurance does not cover such cases. Snow chains and studs are optional. They may however be mandated by signs (also on all-wheel-drive vehicles). Studs are not permitted on most motorways in Switzerland. A speed limit of 50 mph out of town and 30 mph in town applies when driving on studded tyres. It is therefore a good idea to use winter tyres in Switzerland.

Know the rules but what defines a winter tyre?There are no Europe-wide regulations for the sidewall markings of winter tyres. The EU defined what an M+S winter tyre should look like in 1992 (92/23 EEC, Amendment II). This was ‘tyres with a tread and structure designed to provide better handling characteristics in slush and fresh or melting snow than normal tyres. The tread of M+S tyres is in general characterized by larger tread grooves and/or lugs that are separated by larger gaps in the tread than is the case on normal tyres.’

The Cold Weather Tyre laws across Europe...

REd = winter tyres required

GREEn = no legal requirement

ORanGE = required if indicated by road sign

DE

LU

IS

NO

FI

LT

LV

EE

AT

CZSK

SI

BA

HR

NLGB

IE

DK

FR

ES

PT

PL

IT

CH

BY

HU

UA

ME

RS

MD

BE

RO

MK AL

GR

TR

BG

AD

SE

Untitled-1 1 04-10-2010 13:41:33

service bulletin 1210

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