Five months down the line since the Environment Agency introduced new rules on waste tyre exports, the evidence is accumulating that little has changed. Consequentially, the TRA has called for immediate introduction of ‘shred-only’ exports.
Parliamentary questions revealed the scale of non-compliance with new enhanced verification requirements. TRA wrote to Mary Creagh MP, calling for meaningful action to stop UK waste from fuelling pollution overseas and secure investment in domestic industry capability.
The Tyre Recovery Association (TRA) has warned that the UK’s new enhanced verification system for waste tyre exports is failing. Government data released confirms compliance rates are below 25%. Tyre and Rubber Recycling has been told, unofficially, that there are 77 non-compliant operators.
Writing to the Minister for Waste and Recycling, Mary Creagh MP, the TRA praised the minister for the action she instigated last year after it had been demonstrated that enforcement activity on end-of-life-tyre (ELT) exports was deficient. Illegally imported waste tyres from Britain were acknowledged to be a core source for highly polluting batch pyrolysis plants in India.
New data revealed in answer to Parliamentary questions, tabled by Tessa Munt MP, show however, that the overwhelming majority of tyre export consignments continue to fail to meet basic environmental tracking requirements.
According to a written Parliamentary response from the Minister on 12th February, 3,281 Annex VII documents have been authorised for tyre exports since October 2025. However, of the 1,891 consignments that have passed their eight-week reporting deadline, 1,370 have failed to return any post-shipment information at all. Of the number that did respond, only 458 met the required standards. This means more than 75% of recent whole ELT exports continue to be undocumented.
Further details highlight a lack of activity to bring brokers and receiving sites into compliance with the requirements. The TRA say that there is no evidence that the Environment Agency has removed receiving sites which have not complied with the requirements from the approved list.
Meanwhile further information is required to understand if brokers who have failed to provide the necessary post-shipment documentation are being issued with stop notices by the Environment Agency until they come into compliance.
The TRA is urging the UK to replicate the legislative success seen in Australia, which banned the export of whole and baled ELTs in December 2021. Under the Australian model, tyres must be processed into shred or crumb of no more than 150mm before they can be exported. Introducing this model to the UK would provide the regulatory certainty to enable the expansion of domestic ELT reprocessing operations by unlocking multi-million investment in UK processing, leading to the expansion of secondary industries and ending the dumping of environmental waste overseas.
Currently there are at least 150,000 tonnes of idle domestic recycling capacity in the UK, capacity that is not engaged because of the ongoing flaws in enforcement.
Alongside the shred-only mandate, the TRA is calling for the immediate ending of the government’s now ill-judged T8 waste tyre exemption, originally intended as a low cost measure for those handling small volumes of tyres. This long-standing loophole has allowed irresponsible operators to abuse this light touch exemption at almost zero cost, creating an uneven playing field for legitimate UK recyclers.
Peter Taylor OBE, Secretary General of the TRA, said: “A new system with a 75% failure rate is not a solution. Despite the Government’s best intentions to sharpen the Environment Agency’s teeth, the new enhanced verification measures are being ignored by brokers and operators who continue to fuel unregulated pollution overseas.
“The only way to secure the integrity of our waste stream and protect the environment is to move beyond paperwork and mandate a ‘shred-only’ export policy. A model with proven success in Australia.
“We now know recent efforts to improve enforcement of existing rules still have a long road to travel before signs of success. The legitimate operators in the UK continue to be disadvantaged and significant domestic capacity lies idle.
“2026 must be the year that the UK stops exporting its environmental responsibilities – bring in the Australian model and build a robust, truly circular UK economy for tyres.”
The flaw in the argument is that whilst shred only exports will drive business to recyclers with shredding equipment, the material will still be exported and there is little at the Indian end of the chain to prevent its misuse.
One erstwhile importer told Tyre and Rubber Recycling that his business had not imported tyres in the past year. However, in a completely separate discussion, it came to light that the imports he was using were coming from a business based in the USA, where he was a partner.
Until a truly robust and independent verification system is put in place, players will continue to abuse the system, both here in the UK, and abroad.
