Biffpack condemns producer responsibility model for tyres

Responding to a Department of Trade and Industry consultation paper, Biffpack's compliance manager, James Butler, said he believed that a producer responsibility model for tyres would be duplicating existing legislation such as Duty of Care, landfill regulations and the ELV Directive.

“A producer responsibility system would be an unnecessary addition of a further regulatory burden or administrative system that would purely be a means to achieving something already required by other legislation,” Mr Butler wrote.

The government has been interested to learn from the experience of those involved in packaging waste recovery since the mid 1990s. However, Mr Butler believes the fact that tyres face an outright landfill ban from July 2006 rather than a system of ever-increasing recovery targets means the strategy for compliance needs to be different than their system.

“Commercial operations that become last-owners of tyres (such as tyre fitting premises or vehicle dismantlers) have an awareness of the likelihood of their need to dispose responsibly of tyres and should therefore build this into their own costing and planning,” he said.

Simplify

Mr Butler's advice to the government was to keep the system for tyres as simple as possible. Echoing Valpak's response (see letsrecycle.com story), he told the DTI that if producer responsibility is brought in, the “egalitarian” distribution of obligation over different sections of the industry should be avoided, as should the free-market, competitive model experienced in packaging.

He wrote: “The system should be managed bv a sole body, ensuring full compliance and cost recovery can be met. This has disadvantages in the sense that accepted wisdom suggests lower cost in a competitive market, but these are outweighed by the benefits of one co-ordinating body being able to manage data, arrange capacity and manage revenue flows to achieve optimum activity.”

Mr Butler went on to suggest that the Waste and Resources Action Programme would be a suitable candidate to take on the responsibility.