The Tyre Recovery Association (TRA) has urged the European Commission to reconsider proposed exemptions for exports of end-of-life tyres (ELT) to India, warning that the draft rules could undermine environmental protections and allow polluting recycling practices to continue
In a formal submission on the draft delegated act under Regulation (EU) 2024/1157, the TRA argues that country-level assurances and documentary checks are insufficient to ensure that exported tyres are processed through legitimate recycling channels. In its letter, TRA warns the Commission to consider a policy similar to Australia’s, which requires tyres to be shredded before export.
The draft rules would allow certain non-OECD waste tyre exports to India to continue beyond the May 2027 restriction deadline, subject to assurances from the destination country. The TRA argues that the approach risks repeating problems encountered in the UK, where enhanced post-shipment verification requirements reportedly revealed low compliance among exported tyre shipments.
In 2025, EU Member States exported over 605,000 tonnes of end-of-life tyres to India, led by Germany (93,200 t), Italy (90,600 t), France (74,500 t), Belgium (72,000 t), and Ireland (58,700 t). Combined with the UK’s export volume of more than 300,000 tonnes annually (over 1,000 tonnes per day), European ELT waste streams are central providers of the fuel used in the illicit, highly polluting back-street batch pyrolysis.
TRA points to concerns raised by India’s Automotive Tyre Manufacturers’ Association (ATMA) about imported tyres being diverted from formal recycling channels to rudimentary batch-pyrolysis facilities. It also refers to the BBC’s 2025 investigation, The Tyre Scandal, which documented unpermitted facilities burning whole tyres in crude furnaces without basic emission controls, discharging toxic dioxins, heavy metals and particulate matter into local communities and water supplies.
Peter Taylor OBE, Secretary General of the TRA, commented: “The challenges from European Union ELT exports are highly comparable to those we have in the UK. That is why we are taking the opportunity to formally contribute to the European Commission’s review of the recently published draft regulations.
“Anyone who has followed this story in the UK knows that paper audit trails and bi-annual facility checks cannot police whole-tyre shipments once containers reach foreign ports. The UK’s Environment Agency introduced an enhanced paper-and-photo verification regime just over a year ago and then watered down the new process earlier this summer. That was because post-shipment compliance was below 20%. The loosening of controls does not mean the problem has gone away.
“The change of EU rules is an opportunity to be seized; I really hope the Commission will grasp the nettle. We must keep asking why 600,000 tonnes of whole European tyres are being shipped halfway round the world to be disposed of in illicit, highly polluting processes.
“This trade does not just cause environmental damage abroad; it does economic harm at home. Domestic secondary industries are starved of feedstock; advanced circular chemical recyclers require the vital raw materials to scale. The solution is ready and proven: adopt Australia’s ‘shred-only’ model. By restricting exports to mechanically processed shred, we immediately eliminate the feedstocks used by illicit batch reactors while keeping strategic secondary resources circulating within our own economies.”
