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TRA ‘Road to Reform’ Strategy

Ewan Scott
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TRA ‘Road to Reform’ Strategy

The TRA Policy paper sets out five steps for enforcing responsible export of waste tyres

The Tyre Recovery Association (TRA) has released a five-step action plan, titled ‘Road to Reform’ to provide a clear and systematic approach to remedying the shortcomings identified in the Environment Agency’s (EA) recent review of waste tyre exports.

The TRA welcomed the report’s release last month, as a significant milestone and is committed to working with the government to deliver on these reforms and stop the illegal diversion of British waste tyres to damaging pyrolysis plants in countries like India.

Peter Taylor OBE, Secretary General of the Tyre Recovery Association, said; “The EA’s report is a clear diagnosis of the sickness in the current regulatory framework and we welcome the recognition of the shortcomings in its ability to meaningfully enforce regulations.

“Our ‘Road to Reform’ paper provides a constructive and practical five-step action plan, using technology to strengthen existing powers and ensure the UK’s responsibility for waste tyres does not stop at our national borders.

“We need to see the EA respond to their review and the action promised by the Waste Minister, in spring, to ensure we both bring an end to irresponsible waste exports and sustain our own tyre reprocessing capabilities.

 “The EA has the tools and the policy lead to make a real difference now. The technology exists and our industry stands ready to assist the British government in rolling out these measures to ensure compliance.”

The TRA’s road to reform plan clearly sets our five steps for enforcing responsible export of waste tyres. It calls for ‘Enhanced Verification’ by leveraging contemporary technology to transform the Annex VII process.

The five steps cover:-

• Update Annex VII technology, introduce mandatory geotagged evidence: Use contemporary technology to enhance the Annex VII verification process.

• Digital Chain of Custody: Implement some simple checks as a pre-cursor to Digital Waste Tracking, with a verifiable chain of custody for all waste tyre shipments.

• Cross-Referencing, Compliance and Blacklisting: Using their powers under Article 50 of UK Waste Shipments regulations the EA must outline the penalties for any party found to have submitted incomplete or fraudulent paperwork.

• Federated Data and Transparency: A simple central digital portal will provide the EA and its international partners with federated, live data feeds. This will improve transparency and allow regulators to monitor the movement of waste tyre shipments more effectively and at a lower cost.

• Enforce Site-Specific Rules: Actively enforce the existing policy that a pyrolysis plant [In India] cannot legally accept imported tyres. Enhanced verification is crucial to prove that tyres arrive at licensed and “environmentally sound managed” (ESM) recovery facility, rather than being diverted for illegal pyrolysis.

In parallel to these immediate steps for enhanced verification, the TRA continues to champion the ultimate solution for long-term stability and environmental assurance: the introduction of a “shred only” policy for waste tyre exports. This policy, already adopted by Australia, provides a simple and effective means of addressing environmental concerns and ensuring a sustainable UK domestic processing capability.

Comment: In all of this, the weak point will always be the verification at the final destination. We already know that tyres get diverted from their stated source. There is nothing to say that would not continue with falsified documentation at the final destination.

Rubberised Asphalt Focus in SLTC Symposium

Ewan Scott
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Rubberised Asphalt Focus in SLTC Symposium

The SLTC Rubber Conference in Bogota in November will see the second Rubber in Roads symposium

The symposium, entitled – “Reality and Challenges of Sustainable Roads with End-of-Life Tire (ELT) Rubber Powder in Colombia“, will look at sustainable road infrastructure with recycled end-of-life tyres. It will take place at the Agora Bogotá Convention Centre, on Wednesday November 12th between 2:00pm and 6:00pm

The agenda for the Symposium is as follows:

  • ELT management system — shredding technology, traceability, and requirements for end-of-life tire rubber powder. Speaker: Eng. Cindy Ortega — 4R Environmental Solutions.
  • Technical specifications of asphalt mixtures with ELT from the IDU in Bogotá. Evolution, lessons learned. Speaker: Eng. Sully Rojas Bayona — Institute of Urban Development (IDU).
  • Experiences modifying asphalt with ELT. Technologies used. Speaker: Eng. Iván Paba — MPI.
  • Production, installation, and monitoring of sections installed with asphalt mixtures containing ELT in the city of Bogotá by the UMV. Speakers: Dr. Mónica Eloísa Rueda Peña — General Director of the Bogotá Road Maintenance Unit (UMV).
  • Technical and environmental challenges in the responsible use of MBR with ELT rubber powder in pavement layers: a comprehensive vision for road sustainability in Latin America. Dr. Manuel Ocampo — Pontifical Xavierian University. Head of Laboratory — Area of Materials and Civil Works. Associate Professor. Senior Researcher — CECATA Research Group. Civil Engineering Department.
  • The use of ELT rubber powder in asphalt mixtures through the lens of life cycle analysis. Dr. Gilberto Martínez — Universidad del Norte.
  • The reality of ELT rubber powder technology in Ibero-America. The wet process and pre-treated or digested rubber. New technological horizons. Dr. Gerardo Botasso — National Technological University, Argentina. Director, Doctorate in Materials. LEMaC Road Research Center UTN La Plata — CIC PBA. Secretary of Science, Technology and Postgraduate Studies at UTN La Plata. Road technologist with innovations in several Latin American countries.

Following Dr. Mónica Eloísa’s presentation, there will be a short coffee break before part 2 begins. As well as this, both sections of the symposium will conclude with a short question and answer session.

Hosokawa Micron Tell All on Size Reduction

Ewan Scott
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Hosokawa Micron Tell All on Size Reduction

Powderising specialists Hosokawa Micron released a new website that is a guide to size reduction in all its stages

The new Hosokawa Micron website contains a detailed guide to all you need to know about size reduction when you are considering, for example, a pyrolysis project.

Hosokawa Micron is one of the world’s largest players in the pharmaceutical/ chemicals sector and provides everything from milling to containment services ensuring a high quality, consistent and safe operation processing post pyrolysis carbonaceous materials.

The website takes readers through the various technologies and processes in a step-by-step guide, and conveniently, the whole guide is available to download as a PDF file.

Investing in pyrolysis is never going to be a cheap option, the risks are high and the success rate is not always as the PR message might suggest. However, those who are successful all repeat the message about quality and consistency, and the handling of the output is all part of that quality and consistency.

Hosokawa Micron can deliver the processes and services to ensure that the product leaving the factory gate is supplied in a format that is to specification and consistency, at least in its physical format. The chemical format has to be down to the producer.

One point that is made in the guide is that Hosokawa Micron can assist in building Toll manufacturing processes. This is where the post pyrolysis processing is contracted out. This may be an option for smaller pyrolysis operators whose focus is on getting the process correct. Rather than setting out to refine and package from the outset, Toll manufacturing takes the CAPEX for the processing out of the calculation and the pyrolysis operator might just opt to have the packaging sub-contracted.

More Than 500 Tyres Dumped in Springbrook National Park on the Gold Coast

Naida Jahić
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More Than 500 Tyres Dumped in Springbrook National Park on the Gold Coast

Around 550 tyres were dumped in three separate locations inside Springbrook National Park within 48 hours, with Queensland’s environment department saying a clean-up operation is on the way

Dumping more than 550 used car tyres in Queensland’s national park could cost drivers twice as much. According to the state’s environment department, there may have been three separate piles of tyres dumped inside the Springbrook National Park on the Gold Coast last week. The department also called for public assistance to help find those who did it.

Jackie McKeay, head of waste and enforcement services for the department, said the dumping was “extremely serious” and could cause harm to sensitive environments. “Tyre dumping is not just an eyesore, but they really do pollute our soil and waterways and threaten our native animals,” she said. 

Ms McKeay said removing the tyres meant the state would also be hit with a bill, even though consumers pay disposal fees to automotive retailers. She emphasised that the fines of up to $330 for individuals or $12,000 for corporations exist for those who get caught dumping. She said she suspected a commercial operator could be responsible for it. “It’s incredibly frustrating,” she said. “When there’s many options available to people to do the right thing.”

According to Lina Goodman, CEO of Tyre Stewardship Australia, the dumping was a “waste crime” and the story was not unfamiliar. She stated that retailers often charge between $7.60 and $15 to take tyres away for recycling or disposal.

Ms Goodman said operators could exploit these fees by offering to dispose of tyres cheaply and dumping them instead.  “The people that lose out are the people who live in the [area] that are not only paying for the disposal of the tyre when they’re taking it to a retail shop but then they’re having to pay for it again … to clean the mess up when it’s in a national park,” Ms Goodman said. 

She said the organisation’s research had found it could cost Queensland councils up to $32 per tyre to clean it up and called on the federal government to intervene.  

“That’s where the problem lies,” she said.”If we have a government that steps in, like in many places in the world, with a mandatory [disposal] scheme … this can all go away if we were regulating the collection and processing of tyres.” 

Rec Kos Receives €6 Million to Expand Its Capacities

Naida Jahić
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Rec Kos Receives €6 Million to Expand Its Capacities

The European Bank for Reconstruction and Development (EBRD), alongside the Enterprise Expansion Fund II (ENEF II), is providing €6 million loan to Rec Kos, a recycling company located in Kosovo

The project will be co-founded on a pari passu basis between the EBRD and the ENEF II, each providing up to €3 million, aiming to help Rec Kos with its expansion plans, including the construction of a new processing facility and related equipment purchases. This includes the construction of a new processing facility near Drenas Industrial Park near Pristina, a wastewater treatment plant and the acquisition of advanced recycling equipment to process tyres, aluminium, cables, batteries, and more. “The project aims to enhance operational efficiency and environmental sustainability in Kosovo’s recycling sector,” the bank said.

Alongside the EBRD and ENEF II, which provide €3 million each, €1 million of the EBRD’s funding is provided by the government of Taiwan.

Adriatik Shaqiri, owner of Rec Kos, says: “The new facility and advanced equipment will significantly improve our processing capacity and environmental performance. We are proud to contribute to the country’s transition towards a circular economy, while strengthening Kosovo’s position in regional and European recycling markets.”

Sergiy Maslichenko, EBRD head of Kosovo, says: “This investment demonstrates our commitment to strengthening local small and medium-sized enterprises and promoting sustainable industrial development through green finance.”

Established in 2008 and based in Kosovo, Rec Kos operates in the “collection, processing, sorting, and conditioning/grinding/compacting, and trading of ferrous and non-ferrous metals, electronics, waste plastics and waste oils,” according to EBRD. The company is also the second-largest exporter in Kosovo.

TRA Statement on EA’s Review of Waste Tyre Exports

Ewan Scott
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TRA Statement on EA’s Review of Waste Tyre Exports

The Tyre Recovery Association (TRA) has issued a statement on the Environment Agency’s report following its review of waste tyre exports from the UK

British industry recognises the report as a significant milestone on the road to reform but highlight further steps are needed to create a circular economy and secure UK capacity.

Following the release of the 170 page internal review into the Environment Agency’s regulation of waste pneumatic tyres and their export, focussing on the export of this waste to India, Peter Taylor OBE, Secretary General of the Tyre Recovery Association, said; “The TRA welcomes this report, it is a clear and helpful analysis of UK waste tyre exports. It sets out the shortcomings of the current regulatory framework and the EA’s ability to meaningfully enforce these regulations. This is a true step forward after several years of inaction. It includes welcome initiatives on tracing and tracking UK export of waste tyres, the TRA will work with DEFRA and EA to deliver on these.

“It is important, however, that the policy creators and enforcers [DEFRA and the EA] recognise this is just a staging post on the road to the full reforms needed. We will continue to work with the Government to achieve a zero-waste circular economy and sustain the UK’s capability to process end of life tyres.”

The TRA will shortly issue ‘The Road to Reform’, a recommendation paper setting out the clear programme of actions necessary to deliver the steps the Environment Agency recognise in their internal review into the regulation of waste pneumatic tyres and their export, this will include:-

o Strengthening Annex VII process for truly ‘Enhance Verification’

o Steps to increase the responsibility on TFS shipping lines who carry waste exports

o The introduction of geo-tagging and EA active management of the paperwork process

o The need for the EA to manage waste exports from UK and not rely on third country partners to do their job form them

• The TRA continues to call on the Government to update two pieces of regulation:

• Ending T8 exemptions (announced some years ago, but no action has followed.

(Scottish authorities ended T8 exemption in 2018)

• Ending exports of whole end-of-life car tyres (ELTs) (as Australia has demonstrated, a simple and effective means of addressing environmental concerns and ensuring domestic capability)”

A Focus on the Impact of Tariffs from Gradeall

Ewan Scott
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A Focus on the Impact of Tariffs from Gradeall

Gradeall speaks of the impact of tariffs on its trade with the USA and the threat to employment in the UK

“When tariff uncertainty makes customers hesitant to invest, it affects not just our business, but the broader goal of improving waste management infrastructure across America,” states Conor Murphy, director at Gradeall International Ltd

Northern Ireland based Gradeall is a globally recognised leader in tyre processing equipment, its baling presses are renowned as the best in the market.

Over the past six years, Gradeall has established strong US relationships and a significant customer base, making this market essential to its revenue. However, unpredictable US trade policies now threaten the stability and growth of exporters like Gradeall and the broader manufacturing sector. The main problem is not just tariff rates, but the damaging uncertainty surrounding them.

Tyre and Rubber Recycling‘s sister publication, Commercial Tyre Business has written about the impact of tariffs and reflected oon the impact on US-China trade, however, the effect of higher prices in the USA has hit closer to home, as Gradeall’s Conor Murphy explains.

Gradeall MK III

The vacillation of the US government’s approach to tariffs has left both exporters and importers in a state of flux, I the case of Gradeall, the company has seen US customers delaying of postponing purchases in the hope of changes on tariffs in the future.

Uncertainty is a direct impact on trade and investment. No-one wants to invest in a market that faces negative actions.
According to a recent survey, 61% of manufacturing businesses expect turnover to decrease as a result of ongoing US tariffs, with 55% anticipating lower profits by the end of the year

Gradeall Sidewall Cutter
Gradeall Sidewall Cutter


A particularly frustrating issue for Gradeall and its customers has been the inconsistent application of tariffs at different US ports. There have been documented cases where identical shipments of Gradeall machinery have attracted vastly different tariff rates – ranging from 10% to as high as 46% – depending on the port of entry, such as Savannah, Georgia versus Norfolk, Virginia. These discrepancies often arise from administrative errors or misinterpretation of customs documentation, but the end result is the same: confusion, extra costs, and a loss of confidence in the purchasing process.

This lack of clarity extends to the customs process itself. US customers are often left unsure of the exact amount they will be required to pay until their goods arrive at port, making it difficult to budget and plan for new equipment purchases. The administrative burden on both customers and suppliers is significant, with additional paperwork and communication required to resolve tariff disputes and navigate the customs maze.

Beyond the tariffs themselves, delays in customs processing can lead to substantial demurrage fees – charges incurred when containers are held at port beyond the agreed free period. Companies have experienced situations where customers faced significant demurrage costs simply because US customs were unable to process tariff payments quickly enough to release containers. In one instance, the company could not even pay the tariff because the designated bank account was not yet operational, compounding the delay and cost.

Demurrage and detention charges at US ports are among the highest in the world. Reports show that average demurrage fees can range from $50 to $250 per container per day, depending on the port and container size. These costs quickly add up, placing additional financial strain on customers and making Gradeall’s products less competitive in the US market.

The cumulative effect of these issues is a deterioration in the customer experience. For US buyers, the process of importing machinery from Northern Ireland has become fraught with uncertainty, extra costs, and administrative headaches.
For Gradeall, this means not only a direct impact on sales and turnover, but also a significant diversion of resources towards helping customers navigate the new trade environment. Smaller manufacturers, in particular, struggle to absorb these additional costs and administrative burdens, putting them at a competitive disadvantage compared to larger firms.

The challenges faced by b are emblematic of the wider difficulties confronting manufacturing exporters across the UK and Northern Ireland. Recent analysis by the Department for the Economy suggests that a 10% US tariff on UK goods could cost the Northern Ireland economy £85 million and lead to the loss of 800 jobs over the next 15 years. The machinery sector, in which Gradeall operates, is identified as particularly vulnerable to these trade barriers.

Moreover, the uncertainty created by the tariff regime is prompting many businesses to review their profit margins, scale back production, and reconsider investment plans. Nearly half (49%) of surveyed manufacturing firms are exploring entry into new markets or regions to reduce their dependence on US-linked trade. This shift not only threatens the growth prospects of individual companies, but also has potential knock-on effects for regional employment and economic output.

Despite these formidable challenges, Gradeall International Ltd continues to lead by example. With a reputation for innovation, durability, and customer service, Gradeall’s range of waste compaction and recycling equipment remains in high demand around the world. The company’s commitment to supporting its US customers – helping them navigate complex customs procedures, providing transparent pricing, and offering remote monitoring solutions – sets it apart as a market and industry leader.

Gradeall’s experience highlights the resilience and adaptability of Northern Ireland’s manufacturing sector. By maintaining close relationships with customers, investing in product development, and advocating for fairer trade practices, Gradeall is not only weathering the current storm but laying the groundwork for future growth.

The ongoing uncertainty and complexity of US tariffs are inflicting real and measurable harm on manufacturing businesses in Northern Ireland and beyond. From inconsistent tariff rates and mounting demurrage fees to delayed purchasing decisions and lost sales, the costs are both immediate and long-term. For Gradeall International Ltd, these challenges underscore the importance of clear, stable trade policies and the vital role of exporters in sustaining economic growth.

As policymakers on both sides of the Atlantic work towards a more predictable and equitable trading environment, Gradeall stands ready to continue serving its customers with the same commitment to quality and innovation that has made it a global leader in recycling machinery.

Despite facing significant trade barriers, Gradeall International Ltd continues to manufacture world-class recycling and waste management equipment that serves customers across five continents. The company’s comprehensive product portfolio demonstrates the innovation and engineering excellence that Northern Ireland brings to global markets.

Gradeall’s flagship products include the MK2 and MK3 Tyre Balers, which can process up to 6 PAS108-compliant bales per hour, reducing tyre volume by 80%. These machines have become essential equipment for recycling facilities across America, where approximately 280 million tyres reach end-of-life status annually.

The company’s Truck Tyre Sidewall Cutter represents cutting-edge technology for processing large commercial tyres, whilst the OTR (Off-The-Road) Tyre Splitter tackles the massive tyres used in mining and construction industries. These specialised machines address critical waste management challenges in sectors vital to the US economy.
“Our OTR equipment processes tyres that can weigh up to 600kg each,” explains Conor Murphy. “When mining companies in states like Nevada and Wyoming face delays and uncertainty over tariffs, it affects their ability to manage waste responsibly and plan for equipment replacement.”


Environment Agency Review of Waste Tyres – in Brief

Ewan Scott
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Environment Agency Review of Waste Tyres – in Brief

The Environment Agency has produced the findings of its review of the waste tyre export industry and there are changes coming as a result

There are arguments for and against exporting waste tyres for disposal/ recycling in third party destinations. Essentially, if recycling of a waste can take place in a third party country with a lower carbon footprint, and to at least UK/ European environmental standards, and at an economic advantage, then any argument against exports becomes null and void. However, we are a long way from that point.

However, in waste matters there is always a race to the bottom and this can result in waste being exported without consideration of the carbon footprint, and with no surety of the final destination of that waste – this is an issue that Tyre and Rubber Recycling and the Tyre recovery association have been highlighting for over a decade. It was only when the BBC File On Four Investigates Tyre Scandal documentary hot that DeFRA and the Environment Agency sat up and took action.

After a rather brief consultation period, the Environment Agency has published its Waste Tyres Internal Review (Redacted). It runs to 170 pages but here we focus on the proposed actions.

Action 1 – The Environment Agency  will implement enhanced verification checks for waste pneumatic tyres going to India. The review has identified that the Environment Agency should take further steps to ensure we are fulfilling our legal obligations under the UK WSR when exporting waste pneumatic tyres to India and deliver against our objectives under the UK Waste Shipments Inspection Plan.

The Environment Agency now believes that it is highly likely that a proportion of UK waste pneumatic tyres are being diverted for illegal pyrolysis on arrival into India. We have a much clearer understanding of the information that we hold to make the assessment of whether waste pneumatic tyres exported from England are being handled in an environmentally sound manner. Having fully considered this information against our legal duties, we accept there is a lack of sufficiently credible information which would entitle us to assume, for the purposes of Article 49(2) UK WSR, that waste pneumatic tyres exported to India are reaching the destination recovery facility named on the movement form (Annex VII), or are being treated for recovery in an environmentally sound manner. We have an obligation to prohibit exports of waste under Article 49(2) of the UK WSR if we have reason to believe that the waste will not be managed in an environmentally sound manner.

The Environment Agency admits that it has not been able to verify the destination of waste tyres because, in part, they do not regularly receive Annex VII paperwork.

Furthermore, the Environment Agency agrees that the Annex VII forms that accompanied the bales of waste pneumatic tyres tracked by industry, the forms appear to have been falsified to suggest the waste was received at the intended destination, when the tracker data showed that this was not the case.

The Environment Agency will bring into force improved verification checks as from the 1st October 2025. The rules will be implemented using powers under Articles 49 and 50 of the UK WSR and The Transfrontier Shipment of Waste Regulations 2007.

Under this approach, all exporters of waste pneumatic tyres to India will be required to provide information to the EA that gives confidence that waste is being recovered in an environmentally sound manner.

There is a longer-term plan to obtain information through regulatory reform and the introduction of the Digital Waste Tracking System (DWTS). However, in the interim, the Environment Agency will serve Information Notices on brokering organisations, and exporters directly involved in moving waste pneumatic tyres, to obtain this information.

Action 2 – The Environment Agency  will provide additional training to its staff about the requirements of the UK WSR and how they apply to waste pneumatic tyres

In the coming months, targeted training and resources will be provided to build capability and support confident implementation.

The training will cover the detail of the UK WSR and TFS regulations and it will also cover the  limitations of officers’ powers.

However, there is a clear recognition that the export of end of life tyres to India for pyrolysis is prohibited – as Tyre and Rubber Recycling has reported many times.  The wording from the Environment Agency states: The prohibition India implemented in July 2022 on importing waste pneumatic tyres for pyrolysis, renderis these exports as prohibited under Article 36(1)(f) of the UK WSR.

There will also be a strengthening the recording of information about exports of waste pneumatic tyres across the Environment Agency, including information on exports obtained during both routine and incident inspections at T8 sites.

Action 3 – The Environment Agency  will improve how it carries out horizon scanning activities for changes in waste controls and improve its knowledge of the research available on waste pneumatic tyres

During the review, stakeholders stated that they believed that waste pneumatic tyres should be reclassified to require a notification to move internationally. Some stakeholders believe they should be hazardous waste, which would require a notification to be in place prior to any movement. It is also the case that where wastes are classified as hazardous, they are prohibited from being exported for disposal (subject to the exceptions within the UK plan for shipments of waste) to other OECD countries. Hazardous waste cannot be exported for recycling, recovery, or final disposal to non-OECD countries.

This means that the export of waste pneumatic tyres to India would be prohibited if waste pneumatic tyres were classified as hazardous.

 The Environment Agency has identified that it is possible to implement notification controls on waste pneumatic tyres by:

● Requiring a notification, where prior informed consent between all the competent authorities of dispatch, destination and any transit countries is needed prior to the movement.

● Reclassifying waste pneumatic tyres as hazardous, which would automatically apply the need for a notification to be in force prior to any movement.

Of course, the Environment Agency also states that any reclassification would need careful impact assessment to avoid adverse and unintended consequences of such a decision. For example, an assessment of UK recovery capacity and appropriate transitional arrangements would be required.

For those who followed “Yes, Minister” there follows an example straight out of Sir Humphrey’s playbook regarding the Indian ban on the import of waste tyres for pyrolysis. The statement was there, from the launch of the Indian EPR regulations that the import of waste tyres for pyrolysis was banned – “The Environment Agency took the correct action when we were made aware of the amended controls prohibiting the export of waste pneumatic tyres for pyrolysis to India, in that we understood the movement of waste pneumatic tyres to India for pyrolysis would be prohibited under Article 36 (1)(f). The amendment came into effect in July 2022. However, there was a gap of 6 months before we were made aware, which may have allowed some waste pneumatic tyres to be exported to India for pyrolysis during this period. It then took time to confirm the position through correspondence with the British High Commission on 2 May 2024, and directly during a virtual meeting with the Indian Ministry of Environment, Forest, and Climate Change (MoEFCC) on 19 June 2024 (Appendix 4.6).”  So, actually reading the Indian EPR regulations took almost two years … go figure.

There is more to come on waste controls and there will be a new Strategic Intelligence Unit sitting within the National Environmental Crime Unit.

More details on how waste management will be monitored and controlled will be announced no later than December 2025, according to the Review.

Action 4 will see improved partnerships with stakeholders to ensure a better understanding of the challenges in future.

There will be a meeting with the Indian Ministry of Environment, Forestry and Climate Change in the Autumn of 2025 to build a positive working relationship to give all parties better confidence in the treatment of waste tyres.

T8 Removal

The review gives feedback from its drop-in session and other data fed to the Agency. There is a clear understanding across the industry that many of the problems arise through the abuse of the T8 Exemption

In July 2025, the Government committed to removing the T8 exemption due to widespread non-compliance, with businesses handling tyres in volumes far beyond permitted limits. Requiring operators to hold environmental permits will strengthen regulatory control by introducing operator competence standards, management systems, fire prevention plans, and mandatory waste reporting. This will enhance Environment Agency oversight of waste tyre movements, including exports. The Agency supports the removal of the T8 exemption and has helped businesses to prepare by publishing standard rules permits for tyre storage and treatment. These offer a quicker, more cost-effective transition for current T8 operators compared to bespoke permits.

You can read the review in full – here

Argentina’s Mendoza Excludes Large Mining Tyres from Controls

Ewan Scott
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Argentina’s Mendoza Excludes Large Mining Tyres from Controls

Since 2019, Mendoza has implemented Provincial Law 9143, which regulates the management of used tyres (ELT) and seeks to reduce their environmental impact

At the end of July, the Deliberative Council of Las Heras officially ratifying the local commitment to strengthen a more sustainable waste management.

The regulation bans the abandonment, burning, or open-air accumulation of tyres, except for those used in mega-mining machinery, which are exempt.

According to the Ministry of Environment and Climate Change of Mendoza, the exclusion of ELT from the mining sector results from the presence of internationally recognised management protocols, such as the NI43-101 standard, which incorporates specific treatment plans for this category of waste.

Although Mendoza does not currently have operational mega-mining projects, the provincial government is supporting their potential reactivation, and this exclusion indicates a regulatory gap if such ventures become active. Mining companies are required to include a tyre management plan in their Environmental Impact Declaration (DIA); if it is missing, the government requests its addition as a condition for approval.

Off-road truck tyres used in mega-mining can exceed 1,000 kilograms in weight, and their lifespan is limited to about a year. Improper disposal represents a serious environmental risk.

Provinces such as San Juan and Catamarca have begun setting up recycling plants for tires as part of their circular economy strategies. Regionally, Chile is developing an Extended Producer Responsibility Law (EPR) that covers this type of industrial waste.

The PSJ Cobre Mendocino Project (San Jorge) could begin operations by 2027, pending legislative approval and compliance with environmental requirements. However, Law 9143 does not specify management criteria for ELT from mega-mining machinery, leaving this issue unresolved.

From the environment sector, they acknowledge that “there are still no mining projects in operation, so the implementation is pending.” Meanwhile, conventional tyres are the only ones regulated by the current law, and those from the mining sector would be covered by general international regulations.

Environment Agency Admits Issues with Waste Tyre Exports

Ewan Scott
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Environment Agency Admits Issues with Waste Tyre Exports

After years of industry lobbying on waste exports, it took the BBC File on 4  Tyre Scandal article to light a fire under the Environment Agency

In a 170 page review of the state of the waste tyre export situation, the Environment Agency has admitted that there are shortcomings in the system.

With some 86.9 per cent of the UK’s waste tyre exports going to India, the EA has focused on the challenges in that particular trade. Exports to India appear to have peaked in 2024 at 386,100 tonnes, figures for 2025 to date at the time of the review stood at 128,880 tonnes

In brief, the Annex VII will become a mandatory requirement BEFORE any exports take place – this is already in force in Scotland by SEPA, although as there is a transparent border between Scotland and England, Scottish arisings often just get shipped out through a middleman and an English port.

The requirement for the Annex VII will bring an end to that practice, at least. Also coming is the end of the T8, which is now recognised as playing a huge part in the questionable export trade.

The export figures interestingly show some surprising destinations, some in Europe, but also Pakistan.

Tyre and Rubber Recycling will have a more in-depth article on this shortly.

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