Frequently asked Questions and Answers
What is conspicuity?
Conspicuity enables a vehicle to be clearly seen, even when other road users are not actively looking for it.
Who is responsible for compliance with the regulation (i.e. vehicle owner, manufacturer, etc)?
These regulations apply at the time the vehicle is ‘type approved’. Periodically vehicle and trailer manufacturers design new vehicle types and/or alter existing ones to incorporate new features and are required to get them type approved.
At type approval, the applicant must ensure compliance and must correctly mark a vehicle in accordance with ECE104. Thereafter any company that manufacturers’ vehicles of this “approved type” must ensure that conspicuity markings are applied in accordance with the regulations.
Where can I find more information on products compliant with regulation ECE104?
Information on products compliant with the regulation can been found in the ECE104 Approved Product Range section.
Is it easy to apply contour markings and can they be applied by myself / in-house?
Yes, contour markings are easy to fit and can be applied by yourself or in-house. For best results, follow the Cleaning and Application instructions.
What is the expected durability of the 3M™ conspicuity markings?
The warranty for 3MTM Diamond GradeTM Vehicle Marking Film series 983 when applied to rigid surfaces is 8 years. The warranty for 3MTM Diamond GradeTM Vehicle Marking Film series 987 when applied to curtain areas is 3 years which is akin to that for the curtains themselves. This durability does not extend to the types of physical damage (scraping, gouging, etc) that adversely affect vehicles.
Do I need to apply both contour markings and rear marker boards? And if I can apply both, are there any guidelines on how to apply them?
The UK government has consulted and will soon decide whether to require both or to require conspicuity only (and if the latter, whether to allow market boards in addition to conspicuity). 3M believe that the use of rear marker boards in addition to conspicuity markings will help to further increase the visibility of HGVs and improve safety.
What colour marking tape should be used?
| Position on vehicle |
Colour |
| Front |
White |
| Sides |
Yellow*/White (*UK Preference) |
| Rear |
Red*/Yellow (*UK Preference) |
What is the “E-Mark”?
This regulation requires that the conspicuity products used are approved. The certification approval process for conspicuity products is done to ensure that they meet requirements for colour, reflectivity and durability set out in Regulation ECE104.
The E-Mark is a proof that the products have been tested and certified by an independent and authorised centre and meets all the requirements of ECE104.
Without the E-Mark, the product is not compliant with the regulation. The material has to be homologated retro-reflective category C film with the reflective area being no more than 55mm wide. Category C materials are the brightest materials permitted for vehicle markings and may only be used for contour/conspicuity markings.
What is the minimum requirement for compliance when operating the vehicles (i.e. how do I know I'm not compliant anymore after parts of the tape have been damaged?)
Once in use, damage may occur to vehicles due to incident and accident. Conspicuity markings should be renewed to the extent originally installed on the vehicle.
What do I do if my vehicles are unusually shaped?
The regulation allows for some flexibility in the completeness of conspicuity markings to make it easier to deal with more unusual vehicle types. Even the easier, uncomplicated flat sided vehicles are allowed some flexibility – needing to mark 80% of a vehicle’s length.
If it can be proved to the satisfaction of the authority responsible for type approval that it is impossible to achieve 80%, the cumulative length may be reduced to 60%. Remember, it is safer to be seen (even a little) than to be exempted!
How is compliance with the regulation enforced? What are the penalties for non-compliance?
The plan is to include these markings in annual HGV and trailer inspections. No timing for its inclusion in this process has been announced yet. Probably these markings will be treated in the same way as other areas of non-compliance (number plates, marker boards) during inspection and in regard of penalties.
ECE104 Regulation > Research & Benefits > Approved Product Range > Cleaning & Applications Instructions >
