T E C H N I C A L R E P O R T. N o. : L C A E C E R e g u l a t i o n N o. 109

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1 T E C H N I C A L R E P O R T N o. : L C A Inspection concerning the P r o d u c t i o n o f r e t r e a t e d p n e u m a t i c t y r e s f o r c o m m e r c i a l v e h i c l e s a n d t h e i r t r a i l e r s performed according to the E C E R e g u l a t i o n N o. 109 Manufacturer: ASMARA s.r.l. Via Milano 56/58 I CASTELNUOVO DEL GARDA (VR) FOLLOW UP audit 2014 Extension 01 to ECE Type Approval no.: E13*109R00*109R00*0030*00 Index: 1. General Page 2 2. Inspections and their results Page 3 3. Evaluation of test results Page Statement of compliance Page 13 A reproduction of this report and its annexes, except in full, is prohibited without the written permission of Luxcontrol s.a. - Luxcontrol SA 1, Av. des Terres Rouges BP 349 L-4004 Esch-sur-Alzette LUXEMBOURG Tél: Fax: info@luxcontrol.com Int.: N ident: LU RC Lux.: B15664 BGL BNP PARIBAS Luxembourg IBAN: LU BIC: BGLLLULL Dexia-BIL IBAN: LU BIC: BILLLULL

2 * LCA * ASMARA * --- * -- * R109 * Page 2 1. General 1.1. Test Provisions The inspection was carried out according to the requirements of the ECE- Regulation No. 109 including supplement 6 to the 00 series of amendments entered into force on March 17, Information concerning the approval of the production of retreaded pneumatic tyres for commercial vehicles and their trailers The statements below apply to the previous ECE type-approval as referred to on page () Numbering according to the communication following Annex 1 of Regulation No. 109 (1.) Retreader s name or trade mark: ASMARA s.r.l. (2.) Name and address of retreading production unit: ASMARA s.r.l. Via Milano 56/58 I CASTELNUOVO DEL GARDA (VR) (3.) If applicable, name and address of retreader s representative: not applicable (4.) Summarised description as in paragraphs and of this Regulation: Trade names or marks: ASMARA s.r.l. Range of tyre sizes: All tire sizes between 7.50 R15 and 445/65 R22.5 can be potentially retreaded. For details see manufacturer s information document.

3 * LCA * ASMARA * --- * -- * R109 * Page 3 Structure of tyres: diagonal, bias-belted, radial Category of use of tyres: normal, snow, special-use tyres System of retreading: top-capping, re-capping, bead to bead Method of application of the new materials to be used: camel-back, strip-wound, direct extrusion, pre-cured Maximum speed symbol of the tyres to be retreaded: M Maximum load index of the tyres to be retreaded: As original tires Nominated international tyre standard to which the range of tyres conform: ETRTO, TRA, JATMA, TRAA, ABPA, STRO (8.) Reason(s) for extension of approval: (9.) Any remarks: corrected in point (4.) system of retreading; method of application of new materials to be used not applicable 2. Inspections and their results 2.1. Tyres used for Load/Speed endurance test: Following tyres have been used for testing (if not stated in part of this report): - Main audit (Year of homologation 2005): 315/80R22.5 (ENERGECO) 385/65R22.5 (RZ12) 315/80R22.5 (RZ12) 315/80R22.5 (RZ12) 13R22.5 (XZY2)

4 * LCA * ASMARA * --- * -- * R109 * Page 4 - Yearly COP-tires: 2.2. Inspection items Production Test No: Date of test Tire size Tread pattern Remark Year 2006 A /07/ /80 R22.5 RZ12 Conform A /07/ /80 R22.5 ENERGECO 2007 A /03/ /80 R22.5 RZ12 Conform A /03/ /80 R22.5 RZ A /07/ /80 R22.5 RZ12 Conform A /07/ /80 R22.5 RZ A /06/ /80 R22.5 ENERGECO Conform A /06/ /80 R22.5 ENERGECO 2010 A /06/ /80 R22.5 ENERGECO Conform A /06/ /80 R22.5 ENERGECO 2011 A /05/ /80 R22.5 ENERGECO Conform A /05/ /80 R22.5 ENERGECO 2012 A /10/ /80 R22.5 ENERGECO Conform A /11/ /80 R22.5 ENERGECO 2013 A /12/ /80 R22.5 ENERGECO Conform A /12/ /80 R22.5 ENERGECO 2014 A78-14 A /09/ /10/ /80 R /80 R22.5 E-PZA E-PZA Conform Location of Date of receipt of Date of test: Inspector: test: test item: Main report See point [2.] April A. Tomasini January Ext. 1 See point [2.] Not applicable A. Tomasini Follow up See point [2.] 27 February February 2008 A. Tomasini audit 2008 Follow up See point [2.] 22 March March 2011 P. Vinciarelli audit 2011 Follow up audit 2014 See point [2.] 27 October October 2014 P. Vinciarelli Outline of the structure of the company producing the retreaded tyres: Address: ASMARA s.r.l. Via Milano 56/58 I CASTELNUOVO DEL GARDA (VR) Responsible Person: GIAMPIERO BA

5 * LCA * ASMARA * --- * -- * R109 * Page Legal Structure: Production: Limited liability company one production site 3000 tyres per year (prevision) Range of retreaded tyres: See item (4.) of this report Marking of retreaded tyres: Retreading system: See item (4.) of this report. A sufficiently large space for the approval is provided. All markings required by paragraph 3 of the Regulation are provided on the sidewall(s) as set out in annex 3 of the Regulation. see item (4.) of this report Method of application of the new materials used: see item (4.) of this report Nominated international standard(s) to which the range of tyres conform: see item (4.) of this report Description of the quality management system which ensures the effective control of the tyre retreading procedures Documented System The basis of the system is a quality manual from Marangoni. The language used is understood by the operators. Procedures, declined into work- and control-instructions exist for all workstations. For traceability each process step for each tire is documented on a checklist following the tire.

6 * LCA * ASMARA * --- * -- * R109 * Page Requirements of regulation Presence of E/e mark Only tires having e or E mark will be accepted in production under ECE R109 status. This is documented in control instruction at incoming inspection Reconstruction process The complete retreading process of the company is following the working instructions and procedure described in the Maragoni s Retread Process Manual. The process is mainly composed of the following steps: - Income and casing inspection - Buffing - Skiving (Buzz-out filling) and Cementing - Repairing - Filling - Building - Curing - Final Inspection Customer complaints and non-conform products in production are analyzed and documented in various analyses Incoming inspection 100 % visual inspection for incoming tires. Limits for acceptation are given in the documented system. During inspection tires are dry and proper. Acceptance is recorded in form of a checklist per tire.

7 * LCA * ASMARA * --- * -- * R109 * Page Preparation Buffing is being made according to work instruction. The process is recorded in the checklist (worker s initials) Retreading If necessary repair is being made according to work instruction. The process is recorded in the checklist. Repair material handling is documented.

8 * LCA * ASMARA * --- * -- * R109 * Page 8 Protection of steel is being made according to work instruction. The process is not recorded. Material is located in an adapted storage. Preparation of tire according to work instruction. The process is recorded in the checklist (name). Material is located in an adapted storage.. Marking will be made according to Regulation, following work instruction. The marking is given by metal inserts or by pre printed rubber plates and is according to requirements.

9 * LCA * ASMARA * --- * -- * R109 * Page 9 Curing is being made according to work instructions. The process is recorded in form of paper print outs reflecting temperature, pressure and time. Pressure, temperature and time are under automatic surveillance during the process. In addition all factors are registered for archiving. Marangoni technicians assure calibration of equipment. Example of finished tire

10 * LCA * ASMARA * --- * -- * R109 * Page Final inspection Final inspection is being made immediately after curing is finished, according to work instruction. The tire is / is not inflated during final inspection. If not, the tire has been inflated during following production steps: Buffering Preparation Load/Speed Endurance tests and measured dimensions of the tyres: 2.3. Remark General: The tests have been carried out with the tires listed under item 2.1. The tires withstood the test procedure for 47 hours and fulfilled the size requirements before and after the tests. The inspection results are only applicable to items, which have been tested Test facilities Calibration of measuring and test equipment used to carry out the inspections is in accordance with the EEC-Directive and/or ECE-Regulation stated in 1.1. of this report and with ISO Evaluation of test results 3.1. Variants and equipment covered 3.2. Remarks Main report: The tests carried out cover the following component variations and equipment as far as these are relevant for the approval of the production of retreaded pneumatic tires: - different tire carcasses - different tire sizes and tire tread not applicable

11 * LCA * ASMARA * --- * -- * R109 * Page Concerning extension 1: Corrected in Point (4.) of this report: System of retreading: Top-capping, re-capping, bead to bead Method of application of the new materials to be used: camel-back, strip-wound, direct extrusion, pre-cured Follow up audit 2008: No substantial change has been made in the quality system. Marangoni procedures are used trough the complete retreading process. Equipment and machines have been partially renewed. All requirements remain fulfilled Concerning follow up audit 2011 The follow-up audit, carried out by the technical service, has demonstrated that the retread production unit still satisfy to the requirements laid down during the initial assessment as far as the procedures, operation, instructions and specification documentation provided by material suppliers, are concerned. The holder of the approval has demonstrated for each year of production, and spread throughout that year, representative retreaded tyres samples of the range being produced, are checked and tested as prescribed in this Regulation. See the remarks in item (9.) and Annex A of this report. The prescribed yearly COP s on the tires have been successfully performed for the years: 2008; 2009; 2010 The approval certificate E13*109R00*109R00*0030*01 keeps its validity only if the required yearly COP (control of production) tests are performed. The next follow up audit is planned for Concerning follow up audit 2014 The follow-up audit, carried out by the technical service, has demonstrated that the retread production unit still satisfy to the requirements laid down during the initial assessment as far as the procedures, operation, instructions and specification documentation provided by material suppliers, are concerned. No substantial change has been made to the quality. Employed personnel have been trained in relation to the MARANGONI procedures. These are used trough the complete retreading process. The Quality manual has been updated to the latest revision 01/02/2011.

12 * LCA * ASMARA * --- * -- * R109 * Page 12 The holder of the approval has demonstrated for each year of production, and spread throughout that year, representative retreaded tyres samples of the range being produced, are checked and tested as prescribed in this Regulation. See the remarks in item (9.) and Annex A of this report. The prescribed yearly COP s on the tires have been successfully performed for the years: 2011; 2012; 2013, 2014 The next follow up audit is planned for 2017.

13 * LCA * ASMARA * --- * -- * R109 * Page Statement of compliance The inspections items and measurements carried out have shown the compliance of the technical unit described in this report and the attached Annex with the requirements of the ECE-Regulation No. 109 including supplement 6 to the 00 series of amendments entered into force on March 17, Esch-sur-Alzette, October 27, 2014 Luxcontrol s.a. Service Homologation-automobile Patrizio Vinciarelli Ingénieur-Inspecteur David Durazzi Ingénieur-Inspecteur

14 * LCA * ASMARA * --- * -- * R109 * Annex A Page 1 Index to the information package, including a summary in chronological order, concerning extensions and/or amendments ECE Type Approval no.: E13*109R00*109R00*0030*00 Main Report Technical Report No.: LCA Pages 1 to 6 Composition of the Annex: A: Index Page 1 B: Information folder Page 1 to 14 Index to the information folder: - manufacturer s information document (page 1 to 14) Extension 1 Technical Report No.: LCA Pages 1 to 6 Composition of the Annex: A: Index Page 1 B: Information folder No changes Page 1 to 14 Contents of the extension: To be corrected: System of retreading, top-capping, re-capping, bead to bead are used Method of application of the new materials to be used: camel-back, strip-wound, direct extrusion, pre-cured Index to the information folder: - manufacturer s information document (page 1 to 14)

15 * LCA * ASMARA * --- * -- * R109 * Annex A Page 2 Follow up audit 2008 Technical Report No.: LCA Pages 1 to 12 Composition of the Annex: A: Index Page 1 to 2 B: Information folder -- Follow up audit 2011 Technical Report No.: LCA Pages 1 to 12 Composition of the Annex: A: Index Page 1 and 2 B: Information folder -- Contents of the follow-up audit: To be added: - Follow-up inspection results Follow up audit 2014 Technical Report No.: LCA Pages 1 to 13 Composition of the Annex: A: Index Page 1 and 2 B: Information folder -- Contents of the follow-up audit: To be added: - Follow-up inspection results To be changed: - Supplement to Regulation (updated to supplement 6)