In September 2025, the Environment Agency told the TRA Briefing day that things were changing, there would be tighter controls on exports and T8 operators
The new regulations regarding the Annex VII certificates and the return of the Annex VII along with geotagged photo-location of the final destination was initiated in October. All exports were to be submitted with an Annex VII, and all were supposed to have a returned geotagged proof of delivery within 8 weeks of export.
In a response to Ms Tessa Munt MP, DeFRA explained that between the 1st October and the 15th December, the Environment Agency had received 112 Annex VII returns from receiving sites, and this number was expected to rise as the 8 week deadline comes into effect.
Of the 112 Annex VII documents received from the destination sites, only 79 were accompanied by geotagged photographs.
The official response from DeFRA was that those with no geotagged images would see further action being taken.
Ms Munt then asked DeFRAwhat action was to be taken against those who failed to submit geotagged images at the final destination?
Here, Defra responded that the EA would work to bring people into compliance, and would act to disrupt criminal activity. Failure to submit the geotagged evidence would likely result in further action being taken, such as prohibiting future shipments to that destination. Or, potentially taking enforcement action.
However, earlier in February 2026, Ms Munt again asked DeFRA about waste tyre exports.
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.
This gives some credence to the anecdotal reports from tyre recyclers that essentially, little has changed since the 1st October 2025.
On the 20th February 2026, Ms Munt again asked DeFRA about waste tyre exports; “To ask the Secretary of State for Environment, Food and Rural Affairs, with reference to the Answer of 12 February 2026 to Question 111664, how many exporters or brokers who have failed to provide the required post-shipment Annex VII information have been suspended from making further shipments or issued with stop notices to prevent the risk of further non-compliant exports.”
The response to this will come as no surprise to those in the tyre recycling sector.
Mary Creagh MP responded; “The Environment Agency (EA) is yet to suspend or issue a prohibition (stop) notice on any exporters or brokers who have failed to provide post shipment information.
“It has issued 14 warnings on exporters who have failed to provide the required information and is closely monitoring the returns.
“The EA is assessing the feasibility of responding within 8-weeks as evidence from exporters is highlighting delays beyond their control.”
In a further response, Ms Creagh added; “Of the 50 approved receiving sites, the EA has post shipment information outstanding beyond the eight-week deadline from 16 sites.
“Exporters have informed the EA that shipments are not arriving at the intended destination within eight weeks’ notice period which is why the post-shipment information is delayed. Delays at Indian Customs, container handling sites and onwards transport have been cited as reasons. The EA is now considering extending this time period to ensure it is achievable.
“It is the responsibility of the exporter rather than the receiving site to provide the required information to the EA.
“The EA has issued 14 warnings on exporters who have failed to provide the required information.”
So, we have a scenario where, to date, little has changed and the exporters are arguing about delays at customs in India, combined with onward transportation issues. One has to ask, if the final destination of these exports is known, why would there be logistics issues in India? India is not a backwards country when it comes to business. Could it possibly be that the final destination of tyres being sent to India is actually indeterminate? That containers are still being opened and the contents auctioned at the ports?
Asked about action taken, Ms Creagh responded “The EA is yet to remove sites from its acknowledged list to prevent them from receiving future consignments. At this point there is no evidence to show that any receiving sites are deliberately not supplying the information needed to exporter which would be grounds for their removal.
“The Waste Shipment Regulations put legal duties on the exporter. The EA will therefore focus its regulatory efforts on the exporter rather than the receiving site.”
This acting against the exporter makes sense, at least, but for the tyre recyclers in the UK, the movement here is unbearably slow.
When the change in regulations was announced last September they were received with a mix of satisfaction, tempered with cynicism. For some, the clock is ticking on how long they can continue as recyclers, or do they just become part of the exponentially growing Indian tyre recycling collection service?
