Essential information for end of life vehicle dismantling, depollution and recycling

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Coming down the tracks

In the previous part of this series on the state of the tyre recycling in the UK, we have dealt mostly with the present issues, but in this fourth and final piece, we will be peering into a not-so-distant future. Peter Taylor, Secretary General of the Tyre Recovery Association in the UK, concludes his series on the tyre recycling sector.


Coming down the tracks f
Peter Taylor

Defra and the Environmental Agency recently launched major consultations on:

  • The reform of waste carrier, broker, dealer registration in England
  • Mandatory digital waste tracking across the whole of the UK

Needless to say, the implications of both documents are potentially very far-reaching for everyone in the recovery chain, from new tyre retailer and vehicle dismantler through to ultimate re-user or reprocessor.

Waste handler permitting

Taking the first of these two documents, we see a number of radical proposals. The idea is to create a two-tier system for those who generate or carry waste

A ‘Tier one’ or ‘Lower Tier’ obligation would apply to all those carrying waste produced by their own business and would involve a formal registration process.

A ‘Tier two’ or ‘Upper Tier’ obligation would apply to anyone carrying the waste of others or who acts as a broker, dealer or collector.

Importantly, a ‘technical competence’ element will be introduced for both tiers so that in future, only technically competent people will be in control of waste within any business or organisation.


The EA plans to introduce the new concept of ‘waste controller’.

Generally, this person or entity will have to assume ultimate responsibility (i.e., a legal Duty of Care) for classifying waste and deciding where and by whom it is taken. Yes, quite a responsibility!

Interestingly, this could also apply to all those who import waste, the trade in which is almost exclusively of part-worns which legally do not re-acquire product ‘status’ until they have been re-accredited under our UK part-worn tyre regulations.

Now for an insight into the potential implications of:

Digital waste tracking

The aim of this set of proposals is to replace most existing forms of waste tracking and compliance with a simple, all-encompassing digital approach that will track waste, i.e. tyres, in our case, from the point where it arises through to the moment it is reused, recycled, recovered or disposed of. In other words, a virtually watertight ‘cradle to grave’ approach. There are numerous implications of such an approach, but here are just a few to ponder:

  • Waste will require unique identifier codes
  • Will require details of ‘end fate’ of any waste together with any contaminants it might contain.
  • Will require basic information to be provided on the volumes/ weights of material with an indication of specific end uses (eg, TDF crumb, pyrolysis in the case of tyres)

Moreover, much more information than just this may be required, such as:

  • Name of the waste operator
  • Waste description
  • Carrier/ broker details
  • Movement dates
  • Carrier vehicle registration details
  • Waste volume/ load data
  • Waste destination
  • Strict reporting timeframes

Inevitably, such mandatory requirements will require significant changes to existing working practices, and of course, the final version of all of this, especially as it may relate to tyres, cannot yet be known as indeed the exact timescale. What is fairly certain however, is that these new legislative ambitions will form the backbone of the regulatory requirements we will need to work to in the very near future, so we need to ready ourselves for the challenge and for this further professionalisation of the tyre recycling in Britain.

To read Peter’s previous articles, click on the links below. Alternatively, visit

Link to How UK tyre recycling is changing when available

About the TRA

A cornerstone of the body is its support for the Responsible Recycler Scheme.  All TRA members are fully accredited by the scheme, which ensures that all tyres collected, recycled or reprocessed by them are disposed of or reused in an environmentally friendly or acceptable methods. However, markets for tyre recovery continue to grow and develop, and as the EU Landfill Directive is applied right across Europe, a new international dimension will evolve. The Tyre Recovery Association has the independent ability to pursue its broader objectives at both industry and government levels, generate performance data specific to its member’s interests as well as develop stronger links across the tyre recycling world.

See more at:

Previous articles on ATF Professional by Peter Taylor:

1 – Europe’s end-of-life tyres – a veritable mountain of rubber

2 – Our end-of-life tyres and what happens to them

3 – How UK tyre recycling is changing


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Owain Griffiths

Owain Griffiths

Head of Circular Economy at Volvo Cars

Owain joined Volvo Cars in June 2021 to lead Circular Economy in the Global Sustainability Team. The company has committed to being a circular business by 2040 and has financial, recycled content and CO2 based targets for 2025, all of which Owain is working across the company to make happen. Owain previously worked for circular economy consultancy Oakdene Hollins where he advised businesses on evidence led circular economy implementation. 

Turning into a circular business and the importance of vehicle reuse and recycling.

The presentation will cover the work Volvo Cars is doing to achieve 2025 but mainly focus on the transformational work towards 2040 and the business and value chain changes being considered. Attention will be paid to the way vehicles are being dealt with at the end of life and the complexities of closing material and component loops. Opportunities and challenges which Volvo Cars is facing will be presented including engagement with 3rd parties and increasing pressure from stakeholders.

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e2e Total Loss Vehicle Management [e2e] is the UK’s only salvage and automotive recycling network with nationwide, environmentally compliant sites delivering performance resilience and service reliability to the insurance and fleet markets.  The network’s online salvage auction drives strong salvage resale values and faster sales.  e2e’s salvage clients have access to the network’s stocks of over 5 million quality graded, warranty assured reclaimed parts. 

The power of the network model means e2e has the ability to influence industry standards and is committed to continually raising the bar whilst redefining the role and perceived value of the salvage operator.  Network members adhere to robust service level agreements, against which they are audited, in order to ensure performance consistency and a market leading customer experience.  

The salvage and recycling operating environment is evolving rapidly, and e2e is anticipating, listening and responding to changing market needs.  Regulatory compliance, ESG, reclaimed parts, customer experience, EVs, new vehicle technologies, data and reputation risk are just some of many considerations linked to the procurement of salvage services.  e2e will drive further added value to clients and members through the adoption and application of emerging technologies, continuing to differentiate its proposition and position salvage services as a professional partnership. 

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