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

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TRA Forum Day 2019 Review

The Tyre Recovery Association’s (TRA) annual Recycling Forum Day welcomed two new landmark industry initiatives and were briefed on the advantages of the existing tyre recovery programme compared with Extended Producer Responsibility (EPR) equivalents. The Forum took place at the Ardencote Manor Hotel on Tuesday 18th June with over 90 delegates in attendance.

Tim Stott, TRA President, summarised the TRA’s position on EPR:

Tim Stott President TRA
Tim Stott

“Simply hoovering up our waste tyres without them properly fully valorising them is just not enough and like many other countries we too want to face up to that challenge but to do so effectively we must engage with the market, investors and entrepreneurs. The ‘command and control’ approach sometimes termed ‘eco-fee’ is severely constraining when it comes to the promotion of genuine market development, and it comes at a cost. EPR is no quick fix, just a start. 

“No, we need something better than that.”

Instead, said Stott, “For industries like recycling to take root and grow they need a conducive commercial environment in which to do so. The message to government is we in industry cannot achieve that without their help.” 


The key areas where support from government was needed were outlined as:

  • A level playing field where everyone has the same compliance obligations
  • Our current Exemptions regime must end
  • Effective and targeted compliance 
  • An investment-friendly environment for those investing in recycling which fully acknowledges the Proximity Principle 

Howard Leberman, EA Senior Policy Advisor discussed regulatory updates, with exemptions being the main focus, including the restrictions on S2 waste exemption (store waste in a secure place) and the withdrawal of the T8 waste exemption (mechanically treating end-of-life tyres), changes which are due to occur after 31st October. A consultation response document is due to be published in the coming weeks.

On behalf of the tyre recovery sector, Stott announced further innovation from the TRA, including a tyre industry specific Fire Prevention Plan, which has taken nearly four years to achieve. Having worked alongside the Environment Agency, the result is an invaluable waste stream specific standard for the safe storage of end of life tyres (ELTs) and tyre-derived rubber materials (TDRMs). This was required due to the unique requirements of and circumstances of tyre recovery businesses. 

Results of a successful trial (conducted with TRA member, Fraser Evans & Sons Ltd, and technology partner PragmatIC) using Radio-Frequency Identification (RFID) to improve traceability of tyres was presented by Alastair Hanlon, Chief Commercial Officer, PragmatIC. Small tags are permanently fixed to tyres at the point of collection, making their further distribution easily traced. This not only offers benefits for businesses but also reduce the blight of rogue activity. 

Tyre retailers were identified as having a key role to play in this with 70% of ELTs passing through their organisations. Stefan Hay, Chief Executive, National Tyre Distributors Association (NTDA), outlined the association’s support of the TRA’s Responsible Retailing Scheme.

TRA Forum 2019
Left to right: Peter Taylor OBE – TRA Secretary General, Peter Buckley – EA Senior Fire Advisor, Howard Leberman – EA Senior Policy Advisor and Tim Stott – TRA President

Further information on the TRA’s Responsible Recycling Scheme and its recently announced initiatives can be found at


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