The association has argued that decisive action is needed to stimulate long-term investment in domestic processing capacity.
In a letter to Defra Minister Mary Creagh MP the TRA set out its case for a mandatory “shred-only” export regime, an approach the association says has already proven effective in Australia.
According to the TRA, persistent exports of unprocessed tyres continue to undermine legitimate UK recyclers while contributing to pollution in countries where environmental oversight is weaker.
The association argued that a clear, enforceable ban would provide the regulatory certainty needed for UK processors to expand capacity and establish a more resilient circular economy for ELTs.
Peter Taylor, Secretary General of the TRA, commented: “In recent months we have seen positive steps being taken by the Environment Agency to address the irresponsible export of waste tyres. The UK’s legitimate operators, however, need things to move faster.”
Australia’s tyre regulations
Australia implemented its tyre reforms through the Recycling and Waste Reduction Act 2020, followed by the Recycling and Waste Reduction Rules 2021.
Together, these changes introduced a licensing system for all waste tyre exporters and required that ELTs could only be exported if processed into shreds, crumbs, granules or tyre-derived fuel (TDF).
Whole and baled tyre exports were banned outright from December 2021.
The system also requires end-markets to be verified through Tyre Stewardship Australia’s Foreign End Market program, ensuring traceability and environmental accountability.
Rob Kelman, Executive Officer, Australian Tyre Recycling Association, explained: “Australia’s prohibition of whole waste car tyre exports in favour of a shred-only policy in 2021 has clearly had a restorative effect on our domestic recovery infrastructure.
“This policy initiative has led to improved market confidence and investment in new recycling projects in Australia.”
Ending the T8 exemption
The TRA stated that UK recycling capacity, estimated to have around 250,000 tonnes of unused licensed capability, remains underutilised due to the scale of baled tyre exports.
The association maintained that a shred-only mandate would help unlock significant private-sector investment in shredding, crumbing and advanced pyrolysis technologies, as well as support sectors such as asphalt, concrete and renewable fuels.
The association also called for:
- an end to the T8 exemption for the storage and processing of whole tyres
- full implementation of a digital, geotagged Annex VII system to track ELT exports
- mandatory reporting throughout the export supply chain
Defra has previously signalled its intent to end the T8 exemption, which currently allows limited treatment of end-of-life tyres without the need for a full environmental permit.
However, the TRA expressed frustration at the lack of a firm implementation timeline.
The Waste Tyres Bill, which will abolish the exemption, is currently going through the House of Commons.
Taylor added: “If the government is truly committed to a zero-waste circular economy the most efficient measures they could introduce are those introduced by Australia.
“The TRA is urging the government introduce these measures to the UK sooner rather than once it is too late.”
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