Unlike some other European countries the UK relies on a market-based recovery infrastructure for its end of life tyres (ELT’s). This was not only mandated by the UK government more than a decade ago but was the way forward preferred by many in the industry itself.
The UK market driven model is highly cost-effective and operationally efficient when compared with other European recovery models. The European ‘managed’ approach is where tyre manufacturers are required by national governments to pay an up-front fee into approved recovery schemes to meet the disposal and reprocessing requirements of the ELT’s. If a similar solution should ever be introduced here in the UK, the new tyre manufacturers would be faced with collective annual contributions of more than £50 million.
The UK’s ‘free market’ approach to used tyre recycling and recovery should not be confused with a ‘free for all’ approach, The UK under the stewardship of the Tyre Recovery Association (TRA) is a highly regulated association. Almost fifteen years ago the TRA launched the Responsible Recycler Scheme which has grown to be the largest collective recovery audit scheme in Europe. The scheme ensures that annually, TRA members are rigorously audited for regulatory compliance under what has become an industry best practice programme respected key government departments.
UK Used Tyre Recovery
The TRA’s Responsible Recycler Scheme continues to make progress with 38 UK collectors, processors and manufacturers now in active membership. This demonstrates a determined commitment to ‘best practice’ in which the industry can take some pride and this fact has not been lost in government. With new members joining in 2018 it is likely that the RRS collectively accounts for over 85% of collected and processed tonnages.
How the market works
End of life tyres are collected from retailers, users and others through an independent network of collectors who charge for this service. These tyres are then sorted, selected and their fates defined. Truck tyres are prized for finer size reduction and crumbing, and car tyres are more likely to be shredded for other purposes in particular to use as a co-fuel in cement and other types of kiln. Many are also exported for this purpose where permitted.
Expected outcome on the Exemptions consultation
Responses to the recent EA consultation are expected to be published this Autumn.
The balance of opinion is that the EA favour an end to exemptions for tyres similar to that already imposed in Scotland. The change to the current exemptions regime in England and Wales will require Parliamentary assent. This is due to the manner in which exemptions were originally introduced into legislation. We will be dependent on the availability of parliamentary time so this will take us into 2019 but the TRA will keep up the pressure.
Once approved there will be a transition period although we believe this may be kept as short as possible so we hope to see this entire process completed by the end of 2019 if not sooner.
Operators currently working under exemptions will have a choice, either to cease handling tyres or apply to be fully permitted. In the case of the latter option it should be remembered that achieving permitted status may take time, those who leave this until the last moment may well be caught out.
TRA Forum Day 2018
In May the association saw the return of our annual TRA Recycling Day Forum Day at the Belfry Hotel in Sutton Coldfield. We had speakers from Environment Agencies in both England and Scotland and Howard Leberman of England’s EA returned to update us on the proposed changes to the charging system and an update on permits and exemptions.
Howard announced plans for exemptions to change under new guidelines. This would mean exempt sites would be under more scrutiny and under more pressure to become a permitted site or face harsher penalties from the Environment Agency.
Gary Walker from SEPA spoke about the experiences Scotland has had in dealing with waste sites holding tyres who are no longer allowed to operate under exemptions. The TRA is very supportive of this change in Scottish law.
Arihant Singhi of Gemini Corporation and Stefan Hay of NTDA also spoke at the conference. Arihant offered a global perspective on export movements of tyre-derived materials, including shipping routes from the UK to Europe and the rest of the world.
Stefan provided welcome support for shared Producer Responsibility across the tyre industry. Stefan’s presentation included inspiration on how the tyre industry could work together to educate tyre retailers on the importance of using accredited waste carriers to benefit all parties.
The programme, which was strongly endorsed by Stefan Hay, Chief Executive of the National Tyre Distributors’ Association (NTDA), is designed to raise standards of professionalism in the part worn industry and ensure all tyres sold by participating retailers are legally compliant.
The audit-based initiative brings together best practice within the industry, something which all TRA members adhere to. Tyres that are part of the initiative will have a ‘pre-vulcanised label’ to provide traceability once they have been audited, something the current regulations on the resale of part-worn tyres do not provide for.
With over 50 attendees, there has been some very positive feedback regarding both speakers and the topics covered as well as the lively discussions that arose. We are already looking forward to next year’s Forum and to some even more challenging subject matter. The date of next year’s forum will be announced in the very near future.
The TRA Forum 2019 is expected to take place in March.
Visit the TRA website at www.tyrerecovery.org.uk
