The proposal formed part of the response to the government's second consultation into possible statutory measures to meet the UK's tyre requirements under the European Landfill Directive.
From July 2003, the Directive bans the disposal of whole tyres to landfill, and from July 2006 the disposal of shredded tyres via landfill will also be banned.
Four tyre industry trade associations responded jointly to the Department of Trade and Industry consultation paper – the British Rubber Manufacturers' Association, the Imported Tyre Manufacturers Association, the National Tyre Distributors Association and the Retread Manufacturers Association.
The main proposals of the tyre industry included:
- Setting a statutory obligation for manufacturers and importers to recover tyres related to market share.
- The setting up of a statutory reporting requirement for tyre recovery data whether a statutory obligation is set or not.
- The creation of a non-profit arms length body to act as a compliance scheme through which obligations are collectively discharged.
- Used Tyre Working Group reconstituted to fit the circumstances of a producer responsibility regime.
The setting up of a statutory obligation is seen as vital by the tyre industry to create a level playing field in a market of very low profit margins. Although the government has indicated it would like to see a voluntary approach, the tyre industry report said: “A fully 'voluntary' approach by the industry is not a realistic goal as an effective realisation of the concept of producer responsibility.”
In a complex industry like the tyre industry, the report said that only an obligation to recover tyres enshrined in UK law will force all the producers to comply.
This obligated system would be based on market share and would be regulated by the Environment Agency, the proposal stated, which would receive the relevant fee. There should be no “de minimis” threshold of companies too small to be obligated, as there is in the packaging waste system.
Compliance scheme
A statutory reporting requirement would be vital to ensure the data from the recovery system would be transparent and accurate, the tyre industry believes. But another key component to strengthen and simplify both the reporting and the enforcement of the the system would be to create a compliance scheme, the report said.
This compliance scheme would collectively discharge the obligations of its members, demonstrating compliance to the Environment Agency on behalf of each member. Obligated companies would be free to join the scheme or remain self certifying.
The report added: “It is, however, unlikely that the size of the industry could support several schemes without diluting the advantage of economy of scale.”
The scheme would not be responsible for volume or weight of tyres above and beyond its members' obligations, the report said.
The exact form of a compliance scheme was not agreed by all sides of the tyre industry, however. There were two suggestions made:
- A “free market” scheme – existing collection and reprocessing infrastructure would be retained, with the compliance scheme purchasing “Used Tyre Certificates” to demonstrate its members' obligations.
- A “managed market” scheme – the compliance scheme would manage the collection and reprocessing of its members' used tyre obligations. Reprocessors and collectors would be under contract with the scheme to process the required amount of tyres.
Free market
The free market scheme would be a simpler form of the packaging waste recovery note (PRN) system for packaging, with the Environment Agency auditing and enforcing the system.
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