The Waste Management (Tyres and Waste Tyres) Regulations 2007
Background to Waste Tyres Legislation
There are approximately 3 million tyres placed on the Irish Market each year. An estimated 35,000 tonnes of waste tyres are generated in Ireland each year though data on this waste stream is deficient; hence the need to put in place a system for tracking waste tyre flows. Waste tyres are not in themselves a hazardous waste, but have the potential to cause environmental pollution if disposed of incorrectly.
The Waste Management (Tyres and Waste Tyres) Regulations 2007 are designed to promote the environmentally sound management of waste tyres. They provide a regulatory framework for comparing quantities of waste tyres arising with the quantities placed on the market and in tracking the movement of waste tyres from the time they are discarded until they are either reused or processed for recycling and/or recovery. The Regulations came into effect on 1st January 2008.
Obligations of the Regulations
The Regulations impose obligations on persons who supply tyres to the Irish market, whether as manufacturers, wholesalers, suppliers, traders, or retailers and on the collectors of waste tyres. An exemption from these obligations is available to persons who participate in a voluntary compliance scheme operated by an approved body.
Manufacturers, retreaders, remoulders and importers are required to provide details of the quantities of tyres they place on the market. Wholesalers and retailers are prohibited from transferring waste tyres to anybody except an authorized waste collector. Wholesalers and retailers are required to provide details of tyres sold and waste tyres taken back and transferred to authorized waste collectors. Those that place tyres on the Irish Market must register with their Local Authority if they have not registered with an Industry Compliance Scheme. (see below)
Authorized waste collectors are required to register with their Local Authority from February 2008 if they have not registered with an Industry Compliance Scheme (see below). They are obliged to report on the quantities of waste tyres collected and transferred to third parties including farmers, recyclers, retreaders, remoulders and other recovery operators. Recovery operators will be required to issue "Certificates of Recovery" to authorized waste collectors depositing waste tyres with them.
Industry compliance system
Under the agreement negotiated with the tyre industry, the Irish Tyre Industry Association (ITIA) has established the Tyre Recovery Activity Compliance Scheme (TRACS). A network of producers, retailers and waste tyre collectors operate in the industry and the role of TRACS will be to audit the movement of tyres between the different parties involved.
As with other producer responsibility schemes, the participating tyre industry interests will fund the running of the TRACS system. The system not only will track the movement of tyres from when they are placed on the market until sold to end users, but more importantly to trace waste tyres from the time they are discarded until they are either reused or processed for recycling or reuse.To contact TRACS: Please telephone: 01 4100601
Benefits of a Tyre Collection and Disposal System
Waste tyres can be put to many beneficial uses when they reach end of life. Crumb obtained from recycled tyres has many uses, such as in playgrounds, as equine bedding or on football pitches. Furthermore the steel recovered from recycled tyres is a valuable resource. Tyres can also be retreaded - a retreaded truck tyre requires only 33% of the oil utilised in manufacturing a new one, a saving of up to 56 litres each time a truck tyre is retreaded. By implementing a well organized and traceable system for the collection and disposal of tyres, then this valuable resource is put to best use. It also prevents the environmental pollution associated with the incorrect disposal of waste tyres.
Registration with your Local Authority
An exemption from these obligations is available to persons who participate in a voluntary compliance scheme operated by an approved body (TRACS).
However, if you supply tyres to the Irish Market, whether as manufacturers, wholesalers, suppliers, traders, or retailers or you are involved in the collection of waste tyres and are not a member of TRACS, then you must register annually with your Local Authority, and pay annual registration and re-registration fees. Detailed reporting on quantities of tyres placed on the market or taken in since January 1st 2008 must be made to your Local Authority. Registration forms are available below or from the Environment Section of Leitrim County Council by contacting 1890 205 205.
Waste Management (Tyres and Waste Tyres) Regulations 2007
Registration Form for Producers.doc (size 374.8 KB)
Registration Form for Suppliers.doc (size 306.7 KB)
How do the Regulations Affect Farmers?
Provision has been made in the regulations to enable a farmer who requires waste tyres to anchor silage covering to store up to eight waste tyres for every square metre of the floor area of his or her silage pit, without the need to have a waste permit. An example of the quantities permitted is as follows:
8 for each square metre of your silage pit.
|Floor Area||No of Tyres Permitted|
Others requiring waste tyres for genuine reuse, such as marinas, will be able to source waste tyres subject to the approval of local authorities and compliance with the existing regulations governing waste permits. It will be a matter for each local authority to adjudicate each case on its own merits, having regard to best environmental practice. Alternatively, an application may be refused.
Farmers - Frequently Asked Questions.
At the moment I exceed the limit of 8 waste tyres per square metre on my silage pit. Do I have to get rid of the surplus?
You will only need to ensure that you do not exceed 8 waste tyres per square metre of your silage pit once you move waste tyres used for anchoring silage covering on or off your farm from 1 January 2008 onwards. You must, however, ensure that all waste tyres are stored at all times in an manner which would not endanger human health or harm the environment, and in particular would not:
o create a risk to waters, the atmosphere, land, soil, plants or animals,
o adversely affect the visual impact on the landscape,
o pose a fire risk by virtue of the manner in which the waste tyres are being stored,
o be mixed with other waste streams (e.g. farm plastics, empty containers) when stored.
Can I get waste tyres to anchor silage covering?
You have a valid herd or flock number issued by the Department of Agriculture, Fisheries and Food,
You obtain your tyres from a permitted collector who is a member of TRACS
or you are registered with your Local Authority or TRACS.
You are using your silage pit to store fodder, and do not store more than the permitted amount.
How do I get waste tyres?
You can only get waste tyres from an authorized waste collector with a permit to transport waste tyres. You cannot obtain waste tyres from a tyre fitter or retail outlet. If you are offered waste tyres you should check that the person offering them has a valid permit for transporting waste tyres. Waste tyres no longer suitable for use to anchor silage covering can be exchanged with an authorized waste collector on a one-for-one like-for-like basis.
How do I register to become a member of the approved body?Contact TRACS at 01 4100601
If the authorized waste collector supplying you with waste tyres is not a member of TRACS then you must, from 1 February 2008, be registered with your local authority. This costs €20 per annum. You can register yourself or the authorized waste collector can register you on your behalf.
Must I be registered straight away?
No. You will only need to be registered once you move waste tyres used for anchoring silage covering on or off your farm.
Do I need to register with the Local Authority or TRACS when I am obtaining tyres to anchor my silage pit?
You will only need to register if you are obtaining tyres from a permitted collector who is not a member of TRACS.
I do not use waste tyres for anchoring silage. Can I still store waste tyres?
Yes, provided they are incidental to your business as a farmer and do not exceed the number of tyres on your farm vehicles (e.g. a tractor and single axle trailer allows you to store 6 waste tyres).
I no longer use waste tyres for anchoring silage. What should I do with them?
You as the holder of the waste tyres are responsible for ensuring that waste tyres are disposed of in a responsible manner. You can only transfer waste tyres to an authorized waste collector with a permit to transport waste tyres. Make sure that the collector who collects or supplies you with waste tyres has a valid waste collection permit. For a list of permitted collectors in Leitrim contact the Environment Section of Leitrim County Council: Telephone: 1890 205 205.
This information does not act as a direct interpretation of the law and for full information the Regulations should be consulted. Regulations are available by contacting www.environ.ie