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The Independent Automotive Aftermarket Federation

GiPA overview on DFT consultation on banning 10 year+ part-worn tyres


Date: 16-Aug-2019

New laws banning older tyres on “large vehicles” to improve road safety could be introduced later this year. If supported, they will be coming into force at the beginning of 2020. Tyres aged 10 years and older would be banned from use on buses, coaches, lorries and minibuses in new proposals being consulted from the 23rd of June.
 
The consultation directly follows a campaign by Frances Molloy, whose son died in a coach crash caused by a 19-year-old tyre in 2012. Her work with the ‘Tyred’ campaign led to the consultation being launched. There is increasing evidence that tyre age affects the safety of tyres. Research conducted by the DFT published in June shows that aging tyres suffer significant corrosion which cause them to fail.
 
Bus operators have been advised not to use “old” tyres at the front of their vehicles by the DFT. Inspections of 130,000 buses by the Driver and Vehicle Standards Agency since 2017 showed 7,800 buses were in breach of the guidance. When the consultation concludes, the NTDA (National Tyre Distribution association) may respond with the following additional recommendations: 

  • Re-treading tyres is a safe and proven manufacturing process. The NTDA believes re-treading allows tyres to be “good as new”. This should be a practice that is encouraged to improve tyre safety and boost the economy.
  • Part-worn tyres should be banned on all paying passenger conveying vehicles (taxis, minibuses, private hire etc.), especially as many Local Authorities have already done so.
  • Under The Motor Vehicle Tyres (Safety) Regulations 1994 (reg.7.), it is already an offence for anyone to sell part-worn tyres that do not meet the principal requirements of testing, inspection and marking. Better enforcement of this offence will curb the proliferation of unsafe tyres.
  • Part-worn tyre dealers should be required to join a register, pay to be on that register and be licensed and inspected on a regular basis.

GIPA overview on part-worn tyres
The proliferation of part-worn tyres is well established at a national level. Tyre changes should occur in the UK around every 20,000 to 25,000, miles according to driving behaviour, demonstrating the high frequency of this operation. In fact, according to industry body TyreSafe, as many as 5.5 million used tyres alone are sold in the UK every year, and we believe that over half of these are used for passenger cars. 

In most European countries, tyre motivated workshop entries are amongst the most expensive operations, coming in just behind crash repair jobs. In the UK however, it is one of the cheapest workshop entry type. The figure below shows that tyre motivated workshop entries in the UK are on average 29% cheaper than the average cost in the EU-5 markets. 

The part-worn tyre industry in the UK has had some deflationary impact on the tyre motivated workshop costs relative to other EU-5 markets. Because of this, some players with higher overheads, such as franchised dealers, struggle to compete as they offer new high quality tyres only. Their challenge being to find the right balance between an attractive price and not selling at loss.
 
Nonetheless, for UK drivers, the cost of tyre operations has also risen compared to previous years and some drivers are worried about the economic uncertainties. There is therefore a strong incentive for drivers to save costs, and foot a smaller bill by buying part-worn tyres as the purchase of new tyres is more expensive. This is especially true in London where drivers are almost three times as likely to buy part-worn tyres, compared to the rest of the UK.

Although drivers being more involved in the process, we can see they are not well informed about the tyres they are using. In 2018, 87% of drivers did not know the legal tread limit in the UK. What is even more worrying is that out of drivers who purchased part-worn tyres in 2018, only 11% of them knew the limit. This was 15% for drivers purchasing new tyres.

This is concerning as the primary reason drivers quoted for changing their tyres in another survey carried out in 2018 was that they noticed their tyres were worn. This suggests that the tread was potentially dangerously low to have caught the attention of drivers. The second most common reason was a puncture. These are both reactionary and not preventive, suggesting a strong need for more common tyre checks to prevent issues arising.
 
A staggering 97% of fast-fits/ tyre dealers/ franchised dealers said they offer a free diagnostic check when drivers go to their workshops. This gives repairers ample opportunities to inform drivers of the importance of tyre maintenance, and how to spot signs that their tread is fading. Making drivers aware of the consequences of not meeting the limit can also help change behaviour.  

The pros and cons of part-worn tyres:

The only advantage of part-worn tyres is that they cost less than brand new tyres.
 
Some part-worn tyres are shipped over from Germany, where the minimum legal tread depth is 3mm. In the UK it’s 1.6mm, so a part-worn tyre imported from Germany should still have plenty of tread left and perhaps a couple of thousand miles still to run. For tyre suppliers, this is a good commercial opportunity to re-sell cheap imported tyres. However, for drivers, one must consider: If somebody has removed a set of tyres from their car, they have done so because they no longer consider them to be safe. Part-worn will generate less grip, particularly in wet conditions. That means a car will have less traction, breaking grip, and cornering capability. The cost savings of using part-worn tyres can quickly be overshadowed by the safety risks drivers put on themselves and others around them when not taking care in selecting quality tyres.
 
GiPA conclusions

GiPA welcome the consultation raised by the DFT, due to its willingness to support road safety. The NTDA recommend extending to passenger cars too, this is is key for safety.
 
GiPA’s 2019 driver survey demonstrates that drivers in the UK are not as informed as they should be about the tyres they use on their cars. Too often drivers wait until the tyre tread is dangerously low before changing their tyres, suggesting they do not perform regular checks often enough, and when they are, probably are not performed correctly by the driver. This should be done by a professional who can explain the process to them.
 
Whilst a blanket ban on all part-worn tyres may be viewed as an overreaction from tyre dealers and drivers, a better enforcement of existing regulation is needed, as well as the implementation of new regulation. 
 
Too often in the UK, tyre vendors pop-up overnight, sometimes selling part-worn tyres as a wider part of a service such as a carwash. Such business tends to not join trade bodies, and are usually not VAT registered, dealing in cash only, and in some cases are a ‘front’ for other illegal activities. Creating a register of part-worn tyre dealers that are required to meet certain conditions is a positive step to reduce the proliferation of dangerous tyres from improper suppliers. Critics of this idea would argue that it would effectively kill the part-worn tyre market, but this will seed out the “bad” dealers, ensuring what is left are safe, part-worn tyres suitable for use – which is at the benefit of society, and that’s the main goal.

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