Weibold Academy: ISCC-EU opens a new door for TPO

Weibold Academy article series discusses periodically the practical developments and scientific research findings in the end-of-life tire (ELT) recycling and pyrolysis industry.

Claus Lamer

These articles are reviews by Claus Lamer – the senior pyrolysis consultant at Weibold. The reviews aim to give industry entrepreneurs, project initiators, investors, and the public a better insight into a rapidly growing circular economy. At the same time, this article series should stimulate discussion.

For completeness, we would like to emphasize that these articles are no legal advice from Weibold or the author. Please refer to the responsible authorities and specialist lawyers for legally binding statements.

Introduction

The tire pyrolysis industry has received an important and encouraging signal from the market's certification side. Recent developments in the ISCC EU Material List indicate a clearer route to recognizing the fossil fraction of end-of-life tires as a potential feedstock for recycled carbon fuels.

For suppliers of tire pyrolysis oil (TPO), this matters.

Until now, the certification value of ELT-derived TPO has often been discussed primarily in terms of its biogenic share. This share is primarily linked to natural rubber used in tires and can be supported by 14C testing. That pathway remains relevant. But it did not fully address the larger commercial question: what about the fossil carbon in tires that is not bio-based, but is nevertheless recovered from a waste stream?

The new development gives the industry a stronger basis to answer that question. It may allow the fossil-derived fraction of TPO to be considered under the recycled-carbon-fuel logic of RED III. If implemented successfully at the operator level, this could materially improve the value proposition of certified TPO.

It is good news. But it is not a free pass.

From bio-content to recycled carbon

ELT-derived TPO is not a simple product from a certification perspective. It contains carbon from different sources. Part of the carbon originates from natural rubber. Another part comes from synthetic rubber, carbon black, oils, and other petroleum-derived tire components.

The biogenic fraction could already be relevant under established certification approaches. For many operators, the more difficult question was the fossil-derived fraction. This is often the larger part of the TPO. If it could not be recognized as circular or recycled carbon under a credible framework, a substantial portion of the product’s potential compliance value would remain commercially underused.

That is why the development of the new ISCC EU Material List is important. It shifts the market discussion from a narrow question — how much of the oil is bio-based — to a broader, more commercially relevant one: can ELT-derived TPO be documented, certified, and sold as a qualified recycled-carbon product?

This is a meaningful shift. For refiners, traders, fuel suppliers, and industrial customers, certification is not just a label. It is part of the risk assessment. It influences procurement decisions, sustainability reporting, regulatory positioning, and price negotiations.

For TPO suppliers, the potential upside is therefore not only access to a larger certifiable carbon fraction. The more important opportunity is stronger market credibility.

Why does this strengthen the market opportunity?

A clearer certification route can support several developments that the pyrolysis industry has sought for years.

• First, it can make discussions with refiners and fuel market participants more concrete. Offtakers do not only want oil. They want a product with a defined origin, quality, traceability, and regulatory logic. A recognized recycled-carbon pathway helps structure that discussion.
• Second, it can improve pricing potential. TPO sold only as a substitute hydrocarbon feedstock is vulnerable to commodity logic. TPO sold with defensible recycled-carbon attributes has a different negotiation position, provided that the claim is credible.
• Third, it can support investment confidence. Many pyrolysis projects depend on long-term offtake assumptions. Stronger certification logic may help investors distinguish between operators that can deliver auditable, market-ready products and those that are still relying on broad circular economy narratives.
• Fourth, it can accelerate professionalization. Certification forces companies to connect feedstock sourcing, plant operation, laboratory control, mass balance, logistics, and customer documentation. That can be demanding. But it also creates a more mature industry.

In this sense, the new development is not only a regulatory update. It is a market-formation event.

Eligibility is not the same as compliance

The development of a material list does not mean that every TPO supplier automatically qualifies. It does not remove the need for individual certification. It does not replace greenhouse gas calculations. It does not remove the requirement to prove feedstock eligibility, chain of custody, mass balance, or final use.

The material list opens the door. The supplier’s evidence determines whether it can walk through it.

This is where some market expectations may become too optimistic. The certification opportunity is real, but the burden of proof moves to the operator. Each company will need to show that its own feedstock, process, documentation, and commercial pathway meet the relevant requirements.

For an industry that technology claims to have often judged, this is a different type of test. It is not enough to operate a reactor and produce oil. The company must be able to prove what it processed, how it processed it, what outputs were generated, how claims were allocated, and why the resulting product qualifies.

That is a higher standard. It is also a commercial filter.

The new compliance burden

The strongest operators will treat compliance as part of product development, not as a last-minute audit exercise.

This requires reliable systems for feedstock traceability. The operator must know where ELTs came from, how they were classified, how they were collected, and how they entered the production system. It also requires a credible mass balance. Volumes, yields, inventories, losses, co-products, and transfers must be documented consistently.

Plant data becomes equally important. Energy use, auxiliary fuels, process gas utilization, TPO yields, char and recovered carbon black streams, steel recovery, residues, emissions, transport, and downstream processing can all influence the lifecycle profile.

Laboratory and quality assurance systems also gain commercial relevance. Sampling routines, test methods, product specifications, tank management, batch control, contamination prevention, and customer certificates are no longer only technical housekeeping. They become part of the product’s market value.

The same applies to lifecycle evidence. If a TPO supplier wants to move beyond commodity pricing, it must be prepared to defend the sustainability claim behind the product. That means documentation cannot be scattered across spreadsheets, laboratory emails, weighbridge tickets, and informal supplier statements. It must become an audit-ready business infrastructure. This is the uncomfortable part of the opportunity. The new pathway can support better pricing and stronger offtake discussions, but only for suppliers that can produce the evidence.

From administrative burden to commercial tool

There is a positive way to look at this.

For many recycling and pyrolysis companies, certification has long been seen mainly as an administrative cost. Forms, audits, procedures, calculations, and document retention often feel far removed from the practical work of securing tires, running the plant, and selling product.

That view is becoming outdated.

In regulated and sustainability-driven markets, documentation is increasingly part of the product. A buyer does not only purchase molecules. The buyer purchases a defensible claim attached to those molecules. If that claim helps the buyer meet regulatory obligations, reduce exposure, or strengthen its own customer proposition, it has value.

This changes the role of QA/QC, chain of custody, mass balance, operating data, and lifecycle evidence. They are no longer just compliance overhead. They are commercial tools.

A supplier that can explain its TPO origin, quality, carbon logic, and audit trail in a disciplined way will enter negotiations differently from a supplier that can only offer a price and a product sample. The difference may not always be visible in the first conversation. It becomes visible when refiners, traders, auditors, banks, or strategic buyers begin due diligence.

That is where prepared companies can separate themselves from the market.

A stronger value proposition for prepared suppliers

For suppliers that prepare early, the opportunity is significant.

They may be better positioned to negotiate with refiners and traders. They may have stronger arguments in offtake discussions. They may be able to support differentiated pricing. They may also become more attractive partners for customers who need transparent circular-carbon sourcing rather than generic alternative feedstocks.

But preparation should start before the audit. It should start in procurement contracts, plant data systems, laboratory routines, operating procedures, product specifications, mass-balance controls, and customer documentation. In practice, this means the commercial team, technical team, compliance team, and management must work from the same evidence base.

The companies that do this well will not simply sell more TPO. They will sell TPO with a stronger and more defensible value proposition.

Those who cannot prove their claim may still find outlets. But they may remain closer to commodity pricing, with less leverage in negotiations and greater exposure to changing regulatory expectations.

Conclusion

The development of the new ISCC-EU Material List is a positive step for the ELT pyrolysis industry. It provides the market with a clearer basis for recognizing the recycled-carbon value of the fossil fraction of tire-derived TPO and may strengthen the role of certified TPO in fuel and chemical value chains.

However, the opportunity comes with a clear condition: evidence.

The certification value will not be determined by the material list alone. It will be created by operators that can demonstrate feedstock origin, traceability, chain of custody, mass balance, plant performance, product quality, and lifecycle logic in a credible and auditable way.

For the industry, this is a welcome but demanding moment. The direction is positive. The commercial opportunity is real. But the winners will likely be the companies that understand one simple point early enough: in the next phase of the TPO market, documentation is not paperwork. It is part of the product.

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