Valpak's response to the Department of Trade and Industry's consultation on a possible producer responsibility model for used tyres, which was announced last April (see letsrecycle.com story).
Drawing on its experiences of 2001-2, the UK's largest compliance scheme advised against the packaging system in which a number of schemes compete against each other, stating that a “monitored single scheme would be preferable”.
Valpak's report said: “The potential benefits of having many schemes are offset by the significantly increased cost of ensuring uniform enforcement of the regulations. There are also widely varying standards of operation and operational scale in the schemes which means that it is very difficult for the Government to keep track of the overall position nationally and ensure we meet our obligations.”
The landfill directive ban on tyres is due to apply to all tyres save bicycle tyres and those with an outside diameter above 1400mm, which will amount to around 40 million tyres a year – over 450,000 tonnes of material. The government is looking to reuse or recover 120,000 to 150,000 tonnes used tyres above present levels by placing an obligation on manufacturers and importers of tyres in the UK.
Mandatory
Valpak's response suggested a mandatory compliance scheme for obligated companies to avoid “free-riders” who might gain a financial upper-hand on competitors avoiding their recovery requirement. But according to Valpak's advice, the tyre industry is not large to support more than one compliance scheme.
From lessons learned from the Packaging Waste Recovery Note system, the compliance scheme stated there will be a real need for accurate data reporting, a firm system of penalties for non-compliance and the tracking of funds gained from any proposed single fee or 'Tyre Recovery Notes' and 'Temporary Tyre Notes' system.
Valpak advised the government to share out responsibility between different sections of the industry to avoid handing the whole cost to one section of the industry and ensure that there was some amount of 'polluter pays'. This would be similar way to the packaging system in which obligations are distributed between the raw materials producers, packaging manufacturers, product manufacturers and retailers.
The original DTI discussion paper on a possible producer responsibility model for used tyres is available here.
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