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ECE 104 and Regulation 48

ECE 104

ECE 104 is the regulation outlining the technical requirements to approved retroreflective marking tapes for trucks and trailers in Europe.

The materials are divided in 3 classes:

  • Class "C": Material for contour marking
  • Class "D": Material for distinctive markings/graphics intended for a limited area
  • Class "E": Material for distinctive markings/graphics for an extended area In terms of reflectivity, Class "C" is the highest grade and Class "E" the lowest.

ECE 104 does not include any details about the actual application of the tapes on the vehicles - this information is found in Regulation 48.

ORAFOL, with the Reflexite brand, is the original inventer of the technology used for ECE 104 approved safety marking tapes, and today  is one of the world's leading producers in this market.

Note: When ECE 104 was included into Regulation 48, Annex 9 which previously contained application guidelines, was deleted from the regulation.

Regulation 48

Regulation 48 includes the mandate for Regulation ECE 104 markings, and specifies the conditions for this, i.e. which vehicle types must comply, which colours should be used, etc. In other words, all of the technical aspects relating to the application of the tapes, which must be approved according to the technical requirements in ECE 104.

Regulation 48 only includes the Class "C" conspicuity markings.

Because Regulation 48 deals with lighting and light-signalling devices, the classes "D" and "E" of ECE 104 are not included into, or dealt with, in this regulation. The use of these materials is left to the National authorities. Previously, when ECE 104 included application guidelines, it was a requirement that graphics made with Class D or E materials had to be placed within a full contour marking. Today, this is not a requirement in Regulation 48, but something which is decided at a national level. This means that it is something you will need to check in your own National Lighting Regulation.


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Date of Enforcement, 10th July 2011

What happened with ECE 104 on 10 July 2011?

Through implementation of the Lighting Regulation 48-03, the European Union made ECE 104 Class C conspicuity marking compulsory*. The Reflexite® VC104+ series is specially designed to fulfil this new requirement.

From 10 July 2011, conspicuity markings have been compulsory for new types of trucks (for which the manufacturer requests approval) with a maximum tonnage over 7.5 tons (N2 and N3) and for trailers with a tonnage of more than 3.5 tons (O3 and O4).

The 10 July 2011 requirement is contained in the revision (Directive 2007/35) of the Lighting Directive 76/756 which governs the installation of lighting and signalling equipment on motor vehicles in the EU. Directive 2007/35 states that date in Article 2 as below

Article 2
With effect from 10 July 2011, if the requirements laid down in Directive 76/756/EEC, as amended by this Directive, are not complied with, Member States, on grounds related to the installation of lighting and light-signalling devices, shall consider Certificates of Conformity which accompany new vehicles in accordance with the provisions of Directive 70/156/EEC to be no longer valid for the purposes of Article 7(1) of that Directive.

For clarity on what requirements needed to be met by 10 July 2011 by vehicle OEMs, Directive 2007/35 also stated in par. 3 the reference to Reg 48, 03 series of amendments as published in the EU Journal as below:

(3)In order to take into account further amendments to UN/ECE Regulation No 48 (3) on which the Community has already voted upon, it is appropriate to adapt Directive 76/756/EEC to technical progress by aligning it to the technical requirements of this UN/ECE Regulation. In the interest of clarity Annex II to Directive 76/756/EEC should be replaced.

Like in any Directive, there is also a requirement given in Article 3 for all members of the EU to transpose and publish the text of this Directive for reasons of notice and transparency by 9 July 2008 in their national RVLR regulations.

Download Directive 2007/35

*) Exceptions being Denmark , France and Russia. You should always check your National Road Authorities for specific details relevant to your country.

Download the Regulations

We recommend that you always check the UN-ECE website, to ensure you have the most recent updates of the regulations.

Click the logo above to go the website.

Regulation ECE 104

Uniform Provisions Concerning the Approval of Retro-Reflective Markings for Vehicles of Category M, N and O (revision date: 25 March 2010)

Which vehicles must comply

Side Marking

Partial contour marking on vehicles exceeding 6,000 mm in length of the following categories:

  • N2 with a maximum mass exceeding 7.5 tonnes and N3 (with the exception of chassis-cabs, incomplete vehicles and tractors for semi-trailers)
  • O3 and O4

Full contour marking may be applied instead of the mandatory partial contour marking.

The retroreflective marking tapes must be approved according to ECE 104 Class "C".

Rear Marking

Full rear end contour marking on vehicles exceeding 2,100 mm in width of the following categories:

Trucks: N2 with a maximum mass exceeding 7.5 tonnes and N3 (with the exception of chassis-cabs, incomplete vehicles and tractors for semi-trailers)

Trailers: O3 and O4 However, where the shape structure, design or operational requirements make it impossible to install the mandatory contour marking, a line marking may be installed.

The retroreflective marking tapes must be approved according to ECE 104 Class "C".

Overview of Vehicle Categories

If you need an overview of what the different vehicle categories cover (i.e. M1 / N2 / O3 etc), you can download this here.

Partial contour marking
Full contour marking
Full rear end contour marking

Where to apply the tapes

Side Markings

Minimum 80% of the length of the vehicle (excl. the length of the cabin must be marked. In special cases this can go down to 60% for difficult applications or 40% for especially difficult applications.

The lower line of the marking tape must be placed minimum 250mm from the ground, and in a height of maximum 1500mm. This can in special cases be extended to 2500mm.

The length of the upper corner markings must be minimum 250mm. Upper corner markings should be applied as high as practical, but within 400mm of the upper extremity of the vehicle.

In cases where a top corner marking is not possible due to the construction of the vehicle, a line marking on its own is allowed.

A full contour marking is required to the rear, unless this is impossible due to vehicle construction.

Maximum height requirements for the lower horizontal line are the same as indicated for the markings to the side (see above).

Which colours should be used

Yellow: Can be used to the SIDE and/or REAR

Example: VC104+ Rigid Grade, yellow

Red: Can be used to the REAR

Exmple: VC104+ Rigid Grade, red

White: Can be used to the SIDE

Example: VC104+ Rigid Grade, white

*) Note: Special marking requirements in Poland and Ireland

  • Poland: Only yellow to the rear
  • Ireland: Only red to the rear

It is advised always to check with the National Road Authorities, for special national requirements regarding colours to be used.

The E-Mark - What It Is

The key is to look for the so-called “E-Mark” – a marking which is permanently printed within the approved reflective tapes at least every 50 cm.

You want to mark up your HGV with reflective tapes, but how can you be sure that the reflective tape you have bought actually has been approved?

There are many reflective tapes on the market place, and the quality as well as the price differ very much between them. Many of the tapes are available in the required 50 mm width and in the colours stated in the new law – yellow, red and white.

But that is not enough! The key is to look for the so-called “E-Mark” – a marking which is permanently printed within the approved reflective tapes at least every 50 cm.

How do the tape manufacturers get the E-Mark?
In order to get the approval mark, the reflective tape must fulfil all of the minimum requirements in the regulation. This means that as a user, you can be certain that the tape performs, both in terms of reflectivity, the right colours, durability in all weather conditions etc. The approved tapes have undergone extensive testing at certified European test institutes, and only when a tape has passed all of the tests is it granted the E-mark.

This means that it is certified to Class C of Regulation 104.
Class C is the correct class for the line / contour marking tapes.

E+ number:
This indicates in which country the test house has been located where the tape was approved. For instance, E4 means that the tape was approved at an institute located in Holland.

104 R + number:
104 R means that the tape was approved according to Regulation ECE 104. The last digits are the actual approval number for this particular tape.

What does the elements in the E-mark actually mean?
The approved tapes display a mark identical or similar to the one in the photo (this specific one is for the VC 104+ tape approved for application onto rigid surfaces).

So - make sure that the tape you buy for your truck bears the e-mark. This is your guarantee not only of quality and high performance – but also of conforming to the law.

Good reasons to mark your HGV

There is one main objective - reduce the number of accidents during low light conditions which involve trucks and trailers.

The guideline provides for greater road traffic safety through visibility, with improved recognition and conspicuity at night - which is good news for drivers and their vehicles. Since July 2011, all commercial vehicles are required to be fitted with prominent retroreflective marking tapes. The life-preserving measure represented an important step in terms of reducing the risk of accidents still further and making road transport even safer.

With Italy, Romania, Poland and Slovakia having led the way, marking tapes became mandatory in Germany and many other countries in July 2011. The ruling applied to all newly registered commercial vehicles of 7.5 tons or more, and to trailers of 3.5 tons and above. Reflective materials, which must comply with regulation ECE 48-03 of the United Nations Economic Commission for Europe (UNECE), now has to be applied to the sides and rear of all relevant vehicles. The move finally acknowledged that marking tapes significantly reduces the numbers of accidents for long articulated vehicles and lorries - a fact demonstrated in several surveys, including the Darmstadt study in Europe. For ORAFOL, combining safety with the needs of users in order to maximise the benefit to the client is top priority.

Several studies have been made, documenting the positive effects of the conspicuity markings. The NHTSA study estimated no less than a 41% potential reduction in the above type of accidents.

Being seen is being safe.