The Australian Tyre Recyclers Association (ATRA) is happy that tyre stewardship has made the federal environment ministers priority list, and is notionally supportive of a federally regulated used tyre product stewardship scheme with some caveats:
- It supports levelling the playing field for tyre manufacturers/importers in terms of levy payments.
- It also strongly supports the notion of utilising more used tyres domestically, including use of tyre derived fuels, domestically manufactured re-treads and rubber crumb in asphalt.
- The association also wants a nationally regulated product stewardship scheme for ‘Off The Road (OTR)’, used mine and earth mover tyres could reap significant environmental benefits.
In a press release, the association’s executive officer Robert Kelman said more complete exploration of all the options, benefits and liabilities is required however before Australia jumps from the existing used tyre regime to any kind of mandated national product stewardship approach.
He also said there needed to be a change to the current governance framework of TSA from a representative to a skills-based Board, including actual tyre recycling knowledge and expertise, would also generate beneficial environmental and industry outcomes.
Kelman also noted that to date the principal justification put for a mandatory national product stewardship scheme however has been largely limited to capturing ‘free riders’. The TSA recently commented, “Over 50 per cent of tyre importers are not currently contributing financially to the Scheme, but instead unfairly free-riding on the work that the Scheme is attempting to achieve”.
“This would seem insufficient basis to go down the path of a federally regulated scheme, and alternate customs-control or other mechanisms could be found to achieve the result of guaranteeing all importers are paying into the existing tyre stewardship scheme,” he said.
The scheme review for TSA by Arcoona consulting fails to provide a truly independent overview of the state of the industry and options for the future, for instance:
- The report fails to explore the existing state based regulatory regime overseeing used tyre collection, stockpiling and recycling and the value of these existing regulatory arrangements for the industry, i.e. most state regulations regarding used tyres have been substantially reformed in the past 6-8years resulting in significant positive changes to the industry.
- These state regulations, if properly enforced, can lead to every used passenger, truck and bus tyre in Australia being captured for recycling.
- The Arcoona report also jumps straight to a federally mandated product stewardship scheme for used tyres rather than exploring what alternate options might be available to address the issue of free-riders.
- ATRA remains open to discussions around the objectives, options and outcomes of any possible further federal intervention6 in the used tyre recycling market.