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ECE104 Explained

From July 2011, all newly registered HGVs over 7.5 tonnes and trailers over 3.5 tonnes must have reflective conspicuity markings that clearly outline the rear and sides of the vehicle to make it visible for up to 1000 metres at night. ECE104 specifies the standard for the reflective materials used, and where an how it must be positioned on the vehicle or trailer.

About ECE104

  • ECE104 is a regulation that establishes guidelines for the use of retro-reflective safety markings on the rear and sides of heavy goods vehicles operating throughout Europe
  • It requires that homologated retroreflective markings be applied to rigid, curtain and tanker vehicles with a mass over 7.5 tonnes or trailers that have a mass over 3.5 tonnes
  • The reflective material must carry the “E-mark” which means the tape meets the minimum requirements of the regulation
  • Markings will be mandatory in the UK from July 2011, and may be full or partial, provided minimum requirements are met
  • Red or yellow markings must be used for the rear of the vehicle, as close as practicable to the edge of the vehicle
  • Yellow or white markings may be used for the side of vehicles, covering at least 80 per cent of its length
  • The reflective markings must be 'Class RA2' or 'microprismatic' (e.g. 3M™ Diamond Grade™ DG³ reflective sheeting) in the case of rear markings and 'high visibility fluorescent or non fluorescent yellow reflective' in the case of side markings

Why Mark?

  • Conspicuity markings reduce accidents and save lives. Studies conducted over a 10 year period show that well marked trucks are 30 times* less likely to be involved in a road traffic accident
  • Improve safety and increase visibility of vehicles. Other drivers are able to notice marked trucks 5 to 8 times faster**, allowing for considerably longer reaction time and safer driving/overtaking
  • Fewer accidents mean less downtime, less contracts missed and savings on repair costs
  • Improve corporate image through being more proactive about safety
  • Protect your company against potential legal action related to third party safety
  • Reassures and motivates drivers to know that your business takes their safety seriously
  • To meet the regulatory requirements under ECE104 from July 2011

*Technical University of Darmstadt, Germany, 2004 **Ludwig Boltzman Institute, Vienna, Austria, 2002


Technical Downloads

For detailed product information download our data sheets:

Regulation ECE104 - Guidance (PDF 157KB)

Regulation No 48 - Conspicuity Section (ECE104) (PDF 123KB)

Brochure Downloads

For a summary of features and benefits of our products, download our brochures:

Vehicle Conspicuity Brochure (PDF 422KB)


What is conspicuity?

Conspicuity enables a vehicle to be clearly seen, even when other road users are not actively looking for it

Is it easy to apply conspicuity tape and can it be applied by myself / in-house?

Yes, conspicuity tape is easy to fit and can be applied by yourself or in-house, For best results, follow 3M's Cleaning and Application Guide. (pdf, 174KB)

What is the expected durability of the 3M conspicuity tape?

The warranty for 3M™ Diamond Grade™ Vehicle Marking Film Series 983 when applied to rigid surfaces is 8 years. The warranty for 3M™ Diamond Grade™ Vehicle Marking Film Series 997 and 997S when applied to curtain sided vehicles 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 conspicuity tape and rear marker boards?

If a vehicle is fitted with conspicuity markings complying with ECE104 rear Marker boards (ECE70) will no longer have to be fitted, although they can still be fitted if the vehicle operator so wishes. 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 conspicuity tape should be used?

Front - White only
Sides - Yellow*/White (*UK Preference)
Rear - Red*/Yellow (*UK Preference)

What is the “E-Mark”?

The E-mark is proof that the product has been extensively tested and certified by an independent and authorised centre. The E-mark will be granted only when the marking tape has met the requirements of regulation ECE104. 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 permanently printed within the approved marking tape at least every 50 cm. Without the E-Mark printed within the marking tape, the product is not compliant with the regulation. 3M Diamond Grade Vehicle Marking Film Series have met all the requirements of ECE104 and the E-Mark can be found printed on the material. The E-mark gives you piece of mind that the product will perform to a high standard

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. VOSA will be instructed on the correct application requirements, colours & to look for E marked material.

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