Proposal to allow, under certain conditions of traceability, the upgrading of the service description of a used casing, to align the provisions for retreaded tyres with recent development of UN R54 and R117, and to cover all the tread materials.

ETRTO detected an issue in document ECE/TRANS/WP.29/2022/7 with the insertion of paragraph 3.5.1. that is the consequence of the alignment between UN Regulation No. 54 and UN Regulation No. 109. This new requirement regarding the marking position in the sidewall for retreaded tyres is creating a burden for the retread industry that will potentially need to adapt all their moulds accordingly, without considering transitional provisions.