Part worns, vehicle dismantlers and the EA take centre stage at TRA Forum day
At the end of May, eight years after it began hosting such events, the Tyre Recovery Association held its annual Forum day in Warwickshire. This year’s was entitled “a commitment to excellence” and saw speakers representing everyone from Michelin Tyre Plc to the Environment Agency and ATS Euromaster share their perspectives of how excellence can be achieved.
Michelin UK Plc’s government and public affairs representative Darren Lindsey kicked off proceedings with an introductory address raising questions about what the transfer of power from West to East means for Europe and specifically for the UK tyre collection business. This, he explained need not only present us with challenges like oversupply and lack of appropriate casings for retreading, but rather with the opportunity to seize the initiative in terms of thought leadership. According to Lindsey, China looks to Europe for innovation and by the same token to the UK for ideas. At the same time leading long-term forecasting economists have predicted that the UK will overtake Germany as Europe’s largest economy…by 2050. So what does this mean for UK tyre recycling and the TRA specifically between now and then?
Bringing things much closer to home, Lindsey alluded to the fact that currently more than 80 per cent of the UK’s total annual used tyre arisings (which equate to some 540,000 tonnes) are recycled via the industry’s responsible recycler scheme. His point was that this is good news that the wider industry and those involved in tyre recovery in particular need to focus on. “Too much time is spent on the rogue element” within the UK, he explained, pointing out that the 80 per cent is clearly the majority and that their efforts should be what we pay attention to. Referring to the other 20 per cent, he simply said: “we are better than that.”
What about part worns?
It wasn’t long before the subject of part worn tyres, which have once again been brought into the spotlight by TyreSafe’s recent anti-part worn campaign, was raised. In fairness to TyreSafe, whose efforts were no-doubt part of the impetus for this discussion, their campaign doesn’t really complain about legally distributed part worns. But with few of those selling these tyres keeping to the letter of the law, that pretty much means all of them.
Some would say that this lack of clarity is the problem itself. On the one hand it is technically true that the vast majority of the estimated 3 million or more part worns sold in the UK each year are illegal (as TyreSafe points out) because they are not marked as such; on the other hand this is not the same as saying that all part worn tyres are dangerous. Of course tests show that fully treaded tyres perform the best, but interestingly enough the data often shows that brand new tyres only perform at their optimum once they have bedded in. No-one is saying that this logic could ever form the basis of a recommendation of part worns on performance grounds, but it does make the point that it is perhaps not as simple as it first seems. As Dr Charles Ambrose, chairman of the Motor Vehicle Dismantlers Association (MVDA) said during his presentation on “Tyres and End of Life Vehicles”, when was the last time you bought a second hand car and immediately replaced all four tyres on the basis that they were part worn tyres. His point was of course that as long as there is enough tread and they appear OK visually, no one bats an eyelid.
Conflicting expectations such as this are not uncommon when it comes to tyre industry legislation, but once again the problem is not the concept. Instead the regulation and enforcement of the rules make all the difference. At this point it is worth highlighting Darren Lindsey’s remarks relating to the part worn debate. Towards the end of his opening address he pointed out that the part worn tyre regulation, upon which the UK bases its relevant laws, is in fact Europe-wide in its scope. However, in practice the UK is the only market where such quantities of part worn tyres are sold because the other member states generally shied away from going down this route. Their reticence was due to perceived difficulties relating to the enforcement of any comparable local ruling. Based on the overwhelming numbers of part worns in the market and the almost total lack of compliance associated with their sale, you have to conclude that these fears did have foundation.
But is the problem with the people or with the rules? The question of whether or not the authorities or tyre retailers in general were to blame was a repeating motif at this year’s TRA forum day. Surprisingly some of the more vocal attendees who have built their reputation on links to the “sharp end” of the tyre market were the quickest to point the finger at tyre retailers in general.
This, it can be argued, is a mistake for two reasons: firstly, there are many within the market that don’t sell part worns (the NTDA membership for example forms the basis of an influential quorum of opinion in this respect, but there are others too), and secondly because the opacity of the rules and enforcement behind them create an atmosphere where non-compliant sales are allowed to continue. Then there is the fact that there are some 20,000 garages, tyre specialists and fast fitters selling tyres. Only half of these consider themselves to be tyre dealers, so blaming all of them for a trade that is legal but is virtually unregulated is a straw man argument. Set all this against a backdrop of declining disposable incomes and a double dip recession here in the UK and is it any wonder that part worn sales have increased?
To drill or not to drill – should dealers/recyclers put tyres beyond use?
That said, there are a number of tyre businesses and some recyclers that are going far further than any legislation requires them. These businesses, such as the Stapleton’s retail operations (STS, Tyre Pros and Central), Micheldever retail (Protyre) and Sapphire Energy Recovery facilitate the destruction of tyres by drilling the sidewalls, boltcropping the beads and stapling the shoulders of tyres respectively. All three methods aim to stop the worn out tyres taken off during replacement re-entering the market. All three methods have negative environmental associations and cause logistics problems for what remains of the passenger car retreading business.
While this part of the market is the smallest it has been for a generation, some sources suggest that raw material cost and exchange rate effects have actually led to some degree of resurgence in this trade. Of course retreading means better use of the raw materials that went into producing the original tyre and the performance benefits of better tread depths for consumers, but demand for casings also means there is room for a part worn market. Retreaders would probably rather sell them a remanufactured product, but not destroying cases means they can be reused (legally or otherwise) without being retreaded too.
There is another problem too: if you are not going to obey the rules relating to testing and marking part worns, who’s to say that an unscrupulous dealer wouldn’t also illegally repair a worn tyre? This is a far less common practice than failing to mark a used tyre, but again it clearly does happen. Repairs are probably hardest to get away with on the sidewall, but that doesn’t mean people won’t try. Stapling tyres in the shoulder is likely to receive the most criticism in this respect as the diameter of the holes created by any staples might be sufficient to pierce a tyre’s inner liner, but they are also easiest to repair. The point is that if repairs can be made at all we are back to square one, with arguably more dangerous part worns being sold.
The only other option is upping the auditing of closed loop collecting routines as some of the largest retailers have done. To this end Columba Zaal, ATS Euromaster’s retail operations director, spoke on best practice and the tyre retailer and how the UK’s second largest equity has improved and streamlined its systems to mutually beneficial results. According to Zaal 100 per cent of their tyres are recovered. 80 per cent go to energy recovery, 17 per cent are granulated and the remaining three per cent are exported. It could be argued that this last three per cent could re-enter the chain. But we have to remember that there is nothing illegal about either reusing or exporting used tyres.
Those Tyres & Accessories spoke with during the course of the forum day pointed out that all this makes marking essential. A trusted part worn marking should demonstrate compliance and safety and also allow the safe flow of casings to retreaders. This, however, needs a clear enforcement policy and for a degree of unity amongst the different parts of the tyre industry if it is to work at all.
End of life vehicles and part worns
Something else that must be noted when considering this issue is entry point. Drilling tyres may stop at least some tyres collected at replacement from re-entering the cycle, but this assumes that retailers are the sole source. In fact part worn tyres come from a number of sources including import, replacement and end of life vehicles. But none of this takes account of exactly where tyres are re-entering the chain.
As has already been mentioned, Dr Charles Ambrose, chairman of the Motor Vehicle Dismantlers Association (MVDA) said during his presentation on “Tyres and End of Life Vehicles” that no-one thinks twice about the tyres on their second hand – or should we say part worn – car. His view is that professional operations dismounting undamaged tyres and using tyre changers like you would see in garages to do it, should be considered a legitimate market entry point for these products. Cars arriving at dismantlers have an average of roughly five tyres per vehicle amongst MVDA members. These tyres are taken off at the depolution stage, ensuring that no inappropriate heavy machinery is used to do this. Something like 25 per cent of tyres are described as “reusable”.
With somewhere between 1.1 million and 2 million cars (the number of new registrations) exiting the UK parc each year, this would suggest that anywhere between 5.5 and 10 million tyres are removed from scrap cars. If a quarter are described as reusable, 1.375 to 2.5 million tyres could re-enter tyre markets this way. According to the MVDA, removed tyres are sorted before going to exports, retreading and disposal depending on condition.
There are reportedly 1,700 vehicle dismantlers in the UK. About 200 are MVDA members. These represent the lion’s share of the market, but sadly not the rough end. All of which, like many of the topics discussed above, suggests that there is a degree of preaching to the converted going on relating to issues of compliance, collection and recovery. In addition it was noteworthy to observe that, apart from Columba Zaal from ATS Euromaster, there was no-one at the Forum officially representing retailers. All of which brings us back to the question of representation in the market. For things to improve all parties need to be involved and then collectively reach out to improve, or lay sanctions at the non-compliant. Could this be the best way to achieve excellence?