The headline belies the fact that the TRA has been doing this for at least 10 years and successive government have done nothing to help the UK recycling sector

In the wake of the BBC File on 4 revelations – let’s be clear, they were revelations to those outside the industry. Even that is not true, they were not even revelations to the Environment Agency, nor DeFRA because the TRA had been in discussion with both entities for many years, both directly and through other quangos.

However, post BBC revelations on the tyre trade to India, the opportunity is being used to put pressure on the government to finally act to restrict the illicit trade operating, largely, through abused T8 Exempt sites.

The Letter to Steve Reed, Secretary of State for the Environment stated:

Last week’s BBC investigation, “Millions of UK tyres meant for recycling sent to furnaces in India,” has starkly evidenced the profoundly irresponsible consequences of the current exporting of UK waste. The programme revealed the significant damage inflicted on the environment and the health on local populations in India due to these practices. The programme’s framing of the ineffectiveness of our current regulatory approach is particularly alarming to see. As the TRA has sought to highlight to you and your predecessors, UK regulations are failing to prevent the export of ELTs for burning in India. This is despite the illegality of importing tyres into India for pyrolysis.

For years, the TRA has been attempting to convey the gravity of this situation to British government ministers. The BBC’s findings unequivocally validate our concerns and the urgent need for immediate action. Action that will properly protect the environment and preserve out UK processing capability (under terminal threat, with TRA members now seeking advice on managing the decline and closure of their operations).

Responsible UK tyre recycling operators possess the capacity and willingness to process these materials domestically. There are currently at least 150,000 tonnes of idle shredding capacity within the UK. However, the continued export of whole ELTs is pushing the UK tyre recycling industry towards collapse – members of the TRA have started seeking advice on closing down their operations, so we are on the brink if we are to preserve domestic capability

The UK government can no longer afford to delay addressing this issue. The industry cannot survive indefinitely under the current conditions, and its failure would severely undermine the government’s own policy objectives of achieving zero waste and a circular economy. 

Furthermore, there are numerous projects that could bring substantial value and economic growth to the UK which are currently stalled, awaiting improved market conditions and government regulations that align with the needs of both industry and the environment.

In light of the BBC’s investigation, the Environment Agency (EA) has acknowledged that the time for inaction on illegal tyre exports has passed, as it announced it will conduct a review of its approach to waste tyre shipments. In doing this the EA effectively admits its past shortcomings, their minds no doubt sharpened now they face the prospect of legal action from Leigh Day if they do not rectify the situation.

The TRA, along with the responsible UK tyre recycling industry, has been right to raise the alarm. The EA is also right to now acknowledge the necessity for immediate intervention to bring an end to the export of 1,000 tonnes of tyres a day – with the vast majority bypassing their designated destination.

Therefore, the TRA urges the government to implement an expedient and effective solution without further delay. A crucial first step would be the imposition of a size reduction qualification on ELT exports, a policy successfully embraced by Australia. This measure would ensure that tyres are properly shredded before export, promoting responsible processing and utilizing existing UK capacity. As well easing the market transition away form T8 operators to more robustly permitted operators.

The UK tyre recycling industry is ready and able to contribute significantly to the UK’s environmental and economic goals. Most immediately, to assist with the EA review and deliver the meaningful outcomes needed by government and industry, we can provide a task force of expert advisors. 

Our members possess the solutions and the capacity to handle this challenge effectively. It is now time for action to straighten up just a couple of crucial regulations. Existing latent shredding capacity (150,000 tonnes) is currently in position to absorb the volume increase predicted from the removal of the T8. The government would benefit from providing clear direction that from the start of October 2025 that the UK will only allow export of shred below 150mm. Should the EA want to take advantage of putting tyres under interim notifiable (amber list) controls and raise the equivalent of £750k per annum pro rata in notifiable fees, the EA would have the full support of the tyre recycling industry.

The TRA stands ready to support your drive along the path to the circular economy, a zero-waste future that will also allow UK tyre recyclers to thrive and contribute to our sustainable future.

Given that Steve Reed gave a speech on the Circular Economy just three days after the BBC revelations, and that speech made absolutely no reference to end of life tyres, one might be forgiven for thinking that, once again, the Minister has not been briefed on the subject.

Maybe instead of asking for something to be done, the industry should be demanding an inquiry into why DeFRA and the Environment Agency have not acted in the best interests of the UK tyre industry?

In the only other comparable market to the UK, Germany, there is an increasing tide of exports flowing to India, ostensibly for granulation. Last year the figures created by WKD showed a shortfall of somewhere around 80,000 tons. Industry commentators suggest that this is just the tip of the iceberg, and the figure of tyres “missing” may be as high as 200,000 tons.  Anyone care to guess where they are going, illegally?