European countries are considering new requirements to require the fitment of snow tyres for use in severe snow conditions on specific axles of heavy duty vehicles. New tyres are approved under UN R117; however, a large percentage of heavy duty vehicles are fitted with retreaded tyres which are outside the scope of UN R117. This proposal would transpose the relevant requirements for new snow tyres into UN R109 in order of avoid the exclusion of retreaded tyres from such applications/markets.