More than WISH-ful thinking

Tyre Recovery Association annual seminar considers state of market, forthcoming laws and current auditing regime

The Tyre Recovery Association (TRA) held its annual seminar at the Ardencote Manor hotel, Claverdon, Warwickshire on 16 May. It featured sessions on the state of the market and the forthcoming WISH code of practice review by Peter Taylor, further talks on the Responsible Recycler Scheme audit process plus PAS107QP from Gary Nelson of Abricon Ltd, plus an update from Environment Agency National Waste Enforcement Campaigns manager Paul Keay, a best practice case study from Apollo Vredestein (UK) Ltd managing director Stuart Jackson and introductory and closing remarks from association president Mike Wilson of Michelin Tyre Plc.

There isn’t space to cover all that was said, so it is best to highlight two of the most salient and broadly accessible sessions which happened to be presented by the same individual. TRA director Peter Taylor’s first session raised interesting questions about how comprehensive existing market statistics actually are. Are the counting methodologies used in country compatible? Are they even counting the same product types in every country?

The fact the whole and shredded tyres have been banned from landfill sites (except for one or two exceptions) since 2006, is unlikely to be news to anyone. But this fact provides import context for understanding what is currently going on in the market. The introduction of the landfill directive nine years ago prompted the development of two quite different solutions to the tyre collection and disposal/recycling question. These can be broadly categorised into two groups – producer responsibility models and free market approaches. There is probably more variance within each of these two groups than some would like to mention, but the fact that they are broadly speaking two contrasting solutions to the same challenge – two sides of the same coin in you will – is important for understanding the current state of the market.

Producer responsibility has proved to be relatively popular with some of the largest markets on the continent signing up to this approach. A quick look at a map of Europe highlighting the differing approaches reveals that many of the mature markets have gone down this route. Many, but certainly not all. The two largest markets (Germany and the UK) haven’t subscribed to this thinking at any point in the last decade since the rules were introduced. Instead, according to Peter Taylor, the UK has opted for a “free market with oversight “model while German market has gone for the free market option. With the UK successfully collecting north of 80 per cent of tyre arisings each year without imposing models of such as producer responsibility.

So what are the potential effects of this development? First off, the free markets are demonstrating that tyres can be successfully collected and recycled without needing producer responsibility-type models. And with this approach there is likely to be more choice. However, choice is coming to the producer responsibility markets as well giving options to customers looking to safely dispose of their end of life tyres in producer responsibility where they have previously only really been the choice of one dominant power. Markets such as France, Spain and the Republic of Ireland are already witnessing the emergence of competitor processing options within producer responsibility markets. Anecdotal evidence suggests has made an impact already and is precipitating the diversification of markets that comes with such a move.

Counting questions

At the same time that there is diversity within and between the different approaches, there is also diversity in the way that the relative success of each is measured. One well-known market for example, apparently doesn’t count commercial vehicle tyre arisings in their totals while virtually every other European country does. The net result is that the recovery tonnage provided represents an unduly positive figure and other markets that are more forthcoming with their data actual look worse.

However as long as there aren’t any clear agreed methods of calculating these figures, it is likely that we are undercounting by some 10 per cent. According to Peter Taylor, such a flaw is problematic for two reasons. Firstly because it is in danger of driving illicit activity by virtue of the lack of clear accountability and secondly it could drive away promotional investment and support that may otherwise improve the performance of the sector.

The need for a pan-European and transparency counting method is ably demonstrated by the huge disparity between existing reporting figures – both of which leave the whole story untold. For example if you compare ETRA and ETRMA tyre arising statistics for 2012 you can instantly seem massive variance between the sources (see table on page 1 for more on this).

Overall you can see that there is roughly 5 per cent between the total figures. However, this doesn’t take account for the fact that there are variances of nearer 50 per cent in some cases. When you take into account the reports of inconsistent national counting methods (such as the failure to include all product types) were referred to earlier, you can see how problematic this can be when it comes to compliance, policy making and promotional investment.

The new WISH protocol

Finally, towards the end of the TRA seminar, Peter Taylor’s second session addressed the new WISH protocol. This follows the PPG20 storage standard which was proposed and which the TRA steadfastly lobbied for the modification of as the reality was that the requirements were impractical and could lead to folding of otherwise stable and dependable business.

As everyone can understand the importance of good storage – especially when it comes to minimising fire risk and maximising security, the fruit of this lobbying was the mutual development of the standard. In the word’s Peter Taylor “we were almost there”. Then in transpired that the WISH protocol is about to dawn on us. According to the TRA this is being driven by the rescue services who basically want sites to be organised and managed in particular ways. To this end the wood industry is facing similar pressures to the tyre recovering and reprocessing business. And that’s why, while no decisions have yet been made, the TRA has schedule a joint meeting with the wood industry and emergency services representatives in order to re-open talks on this important subject. Back to square one, you might be thinking, but it is a lot better than wishful thinking.


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