News You Can Use

RTA NEWS YOU CAN USE

May 23, 2019

To all of our RTA Members and Associates:
and especially our friends in Canada:

WHEN IS A RETREAD Not A Retread?
When Is A Retread A BRAND NEW TIRE?
Transport Canada Does NOT Seem to Understand the Difference.

Earlier this year, we at the Retread Tire Association
we're contact by an RTA Member in Québec Canada
with a problem that was looming at the time
and has now has developed into a real dilemma.

We are asking all Retreaders, Manufacturers and Importers
to take a look and give us your feedback on this issue detailed Below:
(we realize this is a long post,
but we hope you will read it and weigh in with your opinion).

In January of this year, we were contacted by one of our member companies in Québec Canada alerting us to the fact that Transport Canada was creating a new definition for Bead to Bead Retreaded Tires, that could define these RETREADS as brand new tires.

Transport Canada based this decision on the fact that the tire is rebuilt from sidewall to sidewall and rebranded in the process. This designation of course, then affects significantly and re-defines the characteristics and trade definition of these retreaded tires.

We received this letter in January:

"Dear RTA,
We, are in need of your position on bead to bead, remolded tires. Please explain in detail your position on whether these tires are: New tires, Retreaded tires, or Used tires.

The purpose of this question is that Transport Canada has a misunderstanding with this issue. They claim: "The original casing is significantly altered during this process, and the completed tire is considered as a newly manufactured tire for the purpose of the Act."

So from RTA's perspective, in other words, Transport Canada has defined a bead to bead remold tire as a brand new tire, and taxes and regulates the import and export of these tires accodingly. The problem here of course, is that Retread Manufacturers in Canada, Importers and Exporters now have to contend with (what we believe is) a faulty definition of their product.

While bead to bead retreaders make a quality and like-new product, our position at RTA is that these bead to bead retreads cannot be sold as "new" by prior definitions and standards of the industry.

An example of this mischaracterization would be, if you refurbished a used iPhone, or another product, and sold it as a New product, it would be unacceptable to all consumers, merely by the standard definitions of "new" vs. "used or refurbished products.

MORE RECENTLY, this week we received the following letter, of which we believe you should take notice:

Dear RTA, See what Transport Canada is considering as a retreaded truck tire. For them retread B2B is a NEW tire… Same as Passenger B2B retread they consider as a new tire… (tsd 139)

From Transport Canada: "To clarify that retreaded tires for motor vehicles with a GVWR of more than 4536 kg are not expected to meet new tire testing performance standards, we are proposing clarifications for Technical Standards Document (TSD) No. 119 – New Tires for Motor Vehicles with a GVWR of More Than 4536 kg and Motorcycles. These proposed changes would introduce a new definition for retreaded tires, and would insert "except a retreaded tire" after each reference to "the tire [except…] shall" throughout the TSD."

Retreaded tire means a tire, on which only the tread has been removed and replaced and whose original markings remain. This definition excludes tires not designed by the manufacturer of the original tire to have the tread removed and replaced.(Pneu Rechapé)

Following is our response from RTA in a letter to Transport Canada in January, in which we try to clarify out position on why a Retread is a Retread, and not a NEW tire.

Subject: Bead to bead remolded tires
To whom it may concern,
We are the Retread Tire Association, a member based, retread tire industry association based in California. We are dedicated to serving our 365 industry members around the globe. We get regular inquiries from our members and the public regarding the use of retreaded tires in Canada and the US.

We would like to bring some clarity, and facts to the discussion on the designation of bead-to-bead, remolded/retreaded tires for the information of Transport Canada.

It appears that Transport Canada has made the following statement regarding bead-to-bead remolded tires: "The original casing is significantly altered during this process, and the completed tire is considered as a newly manufactured tire for the purpose of the Act"

This is a false statement, and needs to be re-addressed. In actuality, a properly produced, bead to bead remolded tire is a retread, or in other words a rebuilt, or refurbished product, made from used/recycled and new original tire components, and is re-manufactured for reuse as a recycled/rebuilt product. It is not ever represented as a "new" tire.

Following are the reasons why it is incorrect to call a bead-to-bead remold tire "New":

First of all, any bead-to-bead remolded tire starts with one major component: a quality used tire casing. That casing is analyzed for retreading suitability before it is put through the remolding process. A bead-to-bead retread, addresses the complex structure of the tire including the sidewalls, and rebuilds the outer structure of the used tire to bring it to a roadworthy, reliable standard.

To make the remolded tire, the retreader removes the existing rubber tread and leaves approximately 3-6mm remaining on the premium recycled casing, from the inside bead, across the sidewall of the tire, across the tread of the tire, all the way to the outer bead.

Then, the rubber is replaced from bead to bead (the inner steel cord bundles that secure the tire to the wheel), applying rubber on the sidewalls and rubber on the tread. To finish, the tire is remolded to provide a new tread, and also usually re-brands the sidewalls with a new logo. This provides a finished look. After retreading, the finished tire is still mainly comprised of approximately 75-80 percent of the original recycled/used tire casing.

As you can see, the used tire casing is the starting point, and remains the main bulk of the finished tire when the remold is completed. That same casing, once it has been put back on the road as a quality retread, will give, many thousands of miles of reliable service.

We would recommend you take a look at the process of creating a bead-to-bead remolded tire. Here following is a good example of a YouTube video that shows the bead to bead, remold process of both truck and passenger tires very clearly.
We encourage you to watch it at:
https://www.youtube.com/watch?v=J842ZsvE3aw

Here you can see that these bead to bead remolds are a reused/recycled product in all of its aspects, and though it should perform and look as well as a new tire, it is by no means "NEW", and cannot be sold or represented as such.

To represent a remolded tire as new would be false, and in reality would be like looking at a refurbished appliance or smart phone, and then presenting it to a buyer as "new". That would not be acceptable to any consumer.

If you need more information about quality retreads, here are some more points that reinforce these facts:

The quality, safety and manufacturing integrity of a well made bead to bead remolded tire is by no means inferior to the quality of most new tires. In other words, a retreader supplies a product that performs well, and can be as good or better than some of the new tires that are imported regularly from China, and sold at less than market value. That is one of the reasons why the retreading industry is so vital. It supplies just about every aspect of the transport industry with a viable alternative to "New" tires.

Perhaps Transport Canada is not aware that it takes approximately 22 gallons of oil to manufacture one average size truck tire. Since most of that oil is used in the tire casing, which is reused in the retreading process, only about 7 gallons of oil are needed to retread that same tire. Approximately 15 million commercial truck and passenger tires are retreaded each year, which can help save up to 225 million gallons of oil annually. And, because a casing is being reused several times, fleets who opt to retread are helping to keep millions of tires out of landfills.

RTA would be happy to supply Transport Canada with any more detailed information that you need to help you make your designation for a retread, but the bottom line is this: A bead to bead, remolded/retreaded tire is a quality used/recycled product, that is one of the only completely, truly recycled rubber products that you will find in use on millions of vehicles. The retreading industry is dedicated to producing these quality-recycled products at a significant savings both economically and environmentally.

We hope that Transport Canada will always encourage the use of retreads as an alternative to new tires, and urge your citizens to use retreads for safety, economy and environmental benefits.

Thank you for you attention to this matter.
Sincerely, Jeffrey Parks, Managing Director, Retread Tire Association

-------------------------------------------------

Ultimately, Transport Canada chose to unfortunately designate these well-made retreads, as New tires, which as you can see creates problems for all retreaders trying to get through the import/export process from Canada.

We at RTA also believe that designating these retreads as "new" is detrimental to the retreading industry as a whole, especially in the current climate of random import tarriffs that are widespred and ill defined, creating more confusion in the public about the everyday use of retreads and the resulting economic, environmental and recycling benefits.

We are asking you (our members and associates) to give us your opinion and expertise about this issue. We will include your opinions in out next followup letter to Transport Canada, and see if we can help clarify the fact that a bead to bead retread, as good as it is, should have it's own categaory as a used or retreaded tire, and not NEW.

We would like your opinion on this. Please let us know your thoughts about this by responding to this Memo to us here at RTA, info@retreadtire.org

You can always reach Jeffrey Parks at RTA by phone at 831-620-5345

or email: jeffrey@retreadtire.org

•     •     •

THOUGHT FOR THE DAY

"What we do today, right now,
Will have an accumulated effect
on all our tomorrows."
~ Alexandra Stoddard