The Department of Trade and Industry (DTI) has issued a consultation paper on tyres, in which it proposes that a system – similar to the Packaging Recovery Note (PRN) – is used to ensure that tyres are recycled. The paper outlines how the government plans to meet the Landfill Directive, which bans the disposal of whole tyres from 2003 and shredded tyres from July 2006.
The paper describes a scheme based on car and commercial vehicle tyres, which account for the majority of used tyre arisings. However, the landfill ban applies to all tyres except bicycle tyres and those with an outside diameter above 1400mm. So any scheme also needs to include motorbike tyres and solid industrial tyres although these are not referred to in the government's paper.
The government has said that to meet the targets of the Landfill Directive, the UK needs to reuse and recover an additional 120,000 – 150,000 tonnes of material. To do this, the government is looking at placing an obligation on manufacturers and importers of tyres and they will have to obtain evidence that the tyre has been recycled.
The government hopes to increase the number of tyres that are retreaded as well as the number that are recycled and the practicalities of doing this could lead to a complicated evidence system. The government says that differences in the treatment of tyres would need to be recognised in the evidence and has proposed that evidence of recovery would be issued by reprocessors and evidence of reuse by retreaders.
Evidence
Retreaders – because they are only prolonging the life of a tyre – could issue recovery notes that indicate that the used tyre had been reused, but rather that getting evidence for its recovery, retreaders would issue evidence of reuse. Retreaders could therefore issue Temporary Tyre Notes (TTNs) because a retreaded tyre will re-enter the waste stream and so a TTN would not demonstrate permanent evidence of recovery. TTNs would enable obligated parties to defer obligations from one reporting period to the next.
Tyre recovery notes (TRNs), however, would be issued by reprocessors who recover the material and would demonstrate permanent evidence of recovery. As with the Packaging Regulations, a firm would have to have evidence of tyre reuse and recovery for their total obligation. But obligated companies would not be expected to secure evidence for exactly the same tyres that they placed on the market, but a weight equivalent to those tyres.
And as with similar producer responsibility schemes, minimum thresholds are likely to be applied which would mean that companies placing less than a certain level of tyres on the market would be exempt.
Written comments on the paper should be sent by July 12 2002 to: Paul Hallett, Department of Trade and Industry, Sustainable Development Directorate, tel: 0207 215 1860, email: paul.hallett@dti.gov.uk
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