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
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.

Abstract

Over the past 12–14 months, the regulatory landscape for tire pyrolysis oil (TPO) has changed more rapidly than at almost any point since TPO began moving from an alternative fuel into a serious refinery and petrochemical feedstock. RED III, revised ISCC rules, the recognition of the fossil fraction of end-of-life tires as a potential recycled carbon fuel feedstock, and new end-of-waste pathways in England and France have all moved the market forward.

Yet greater recognition has come with greater scrutiny. For producers, the challenge is no longer simply to manufacture an oil that meets a technical specification. Increasingly, they must also prove where the tires came from, how the carbon is accounted for, what greenhouse-gas savings can legitimately be claimed, how sustainability attributes transfer, and under what legal status the product reaches the customer.

For offtakers, the same change means that purchasing TPO increasingly involves regulatory and sustainability due diligence alongside conventional product qualification.

The TPO market has not become easier. It has become more mature.

From “Can we sell the oil?” to “What exactly are we selling?”

For many years, the central question surrounding tire pyrolysis oil was relatively straightforward: could a pyrolysis producer make an oil that a refinery or chemical company was prepared to use?

That question led naturally to discussions about sulfur, metals, solids, stability, distillation characteristics, and upgrading. Producers focused on improving product quality. Offtakers focused on qualification trials and compatibility with existing processes.

Then another layer was added. The natural-rubber content of tires meant that part of the carbon in TPO could be considered biogenic. As European climate policy evolved, that biogenic fraction began to attract increasing attention. Suddenly, TPO was no longer judged only by what was inside the tank. Its carbon origin also started to matter.

Over the last 14 months, that development has accelerated.

Today, an apparently simple shipment of TPO can carry several different identities at once. Physically, it is oil. Under waste law, it may still be a waste, or it may have achieved end-of-waste status. Under sustainability certification, part of its carbon may be biogenic and part fossil. Under RED III, some fossil carbon may contribute through the recycled carbon fuel route. Under chemicals law, further obligations arise once the material enters the product market.

The same tons of oil can therefore have very different economic and regulatory meanings depending on where it was produced, where it is sold, how the feedstock was sourced and what the final customer intends to do with it.

That is perhaps the most important change of the past year.

The industry is no longer dealing with a single TPO business case.

RED III changed the value discussion

The implementation of RED III moved recycled carbon fuels from a relatively specialist topic into the center of the European TPO discussion.

For tire pyrolysis, this was significant because end-of-life tires contain a substantial fossil fraction. If this fossil carbon can qualify under an RCF pathway, TPO may offer more decarbonization value than its biogenic fraction alone.

But RED III did not simply create a new premium.

It created a test.

For an RCF pathway to qualify, you must demonstrate the required greenhouse-gas savings. The 70% threshold therefore became one of the most discussed numbers in the European TPO market.

And this is where the issue became more complicated.

The result depends not only on the pyrolysis process itself. It can also depend on what would otherwise have happened to the tires. Were they destined for material recycling? Were they likely to be used as tire-derived fuel? Would they have been incinerated? What transport and processing steps occurred before they reached the plant?

Questions that once belonged mainly to feedstock procurement suddenly became relevant to the oil's carbon value.

For producers, this means that the environmental history of an end-of-life tire can become almost as important as its physical characteristics.

A plant may operate efficiently and still discover that its intended RCF pathway is difficult to defend because the underlying feedstock assumptions are weak.

Conversely, a well-documented supply chain can become a commercial advantage.

Then mass balance became much less abstract

At almost the same time, the rules governing sustainability claims became more precise.

ISCC EU’s revised mass-balance guidance made clear that mixed fossil and biogenic feedstocks such as end-of-life tires require careful treatment. Sustainability characteristics cannot simply be shifted freely between products whenever that would produce the most commercially attractive result. That may sound like a certification detail.

For a TPO producer, it is anything but.

It influences how inputs and outputs are recorded, how tanks and inventories are managed, how Proofs of Sustainability are issued and, ultimately, what can be promised to a customer.

It can also affect revenue assumptions.

A project that has built its economics around allocating a particularly attractive renewable attribute to a selected portion of its TPO output may find that the applicable certification rules impose tighter boundaries.

Mass balance has therefore moved from the sustainability department into operations, sales and financial modeling.

That is a recurring theme in the past year: issues once treated as administrative details increasingly reach directly into the commercial core of the project.

The fossil fraction gained a clearer route

The April 2026 ISCC EU Material List brought a more encouraging development.

For the first time, the fossil fraction of end-of-life tires was explicitly included as a potential recycled carbon fuel raw material. For the tire pyrolysis industry, this was an important signal. It strengthened the argument that the fossil carbon recovered from tires should not automatically be treated in the same way as newly extracted fossil carbon.

But the development also illustrated the market's new reality.

Recognition is only the beginning.

A producer still has to demonstrate that the feedstock and process fulfill the applicable requirements, that the biogenic and fossil fractions are properly measured and accounted for, that the greenhouse-gas pathway works, and that the downstream use qualifies.

In other words, the new rules did not turn TPO into a universally recognized low-carbon fuel overnight.

They created a route through which qualifying TPO can prove that value.

That distinction is important.

The second product leaving the plant is information

Perhaps the biggest practical consequence of these changes is not found in any single regulation. It lies within the pyrolysis company itself.

Historically, the plant’s primary output was obvious: oil, recovered carbon black, steel and gas. Today, another output has become increasingly important: information.

A producer needs to know where its tires came from. It needs reliable production data. It may need to demonstrate carbon balances, energy consumption, and transport distances. Sampling procedures need to be reproducible. Carbon-14 results must be linked to the relevant production volumes. Certification records must follow material movements. GHG calculations need auditable assumptions.

None of this improves the oil’s viscosity or reduces its sulfur content.

But it can determine whether the oil can be sold into the intended market.

That changes how the TPO business is organized.

The laboratory can no longer operate separately from certification. Feedstock procurement can no longer operate entirely separately from sustainability accounting. Sales teams cannot promise environmental attributes without understanding the evidence behind them. Financial models cannot treat regulatory premiums as certain before the underlying pathway has been demonstrated.

The physical production line and the information chain are becoming inseparable.

England and France made end-of-waste tangible

This became particularly visible in England and France.

England’s Tyre Pyrolysis Oil Resource Framework introduced a clearer pathway under which qualifying TPO can cease to be waste for refinery use. France followed with specific end-of-waste criteria for tire-derived thermolysis oil (TPO) destined for petrochemical and chemical applications. Both developments matter because they shift the debate away from the abstract question of whether TPO should become a product.

They show what achieving product status looks like in practice. And in practice, it requires evidence. Feedstock requirements, product specifications, testing, quality controls, traceability, documentation, and the relationship with the receiving installation all become part of the equation. End-of-waste is therefore not simply a stamp that transforms oil from one legal category into another.

It is increasingly a process that has to be maintained. That is particularly important for international suppliers.

A TPO producer may have solved the regulatory position in its home country and still find that the importing jurisdiction asks different questions. Product status in one country does not automatically remove waste-law considerations in another.

As international trade grows, producers will increasingly need to consider the oil's regulatory status not only when it leaves the plant, but also when it arrives at the customer’s gate.

The refinery is no longer just the buyer

The same development is changing the role of offtakers. In the early TPO market, a refinery could largely focus on one question: can we technically use this material? Today, a sophisticated offtaker may need to understand much more.

What exactly is the legal status of the incoming oil? Which sustainability attributes accompany it? How were those attributes calculated? Can they be passed through the refinery’s own certification system? Does the supplier’s GHG calculation stand up to scrutiny? Which party carries responsibility for REACH or other chemical requirements?

The buyer therefore becomes part of the compliance chain.

This is one reason why the most promising TPO relationships increasingly develop over months or years rather than through conventional spot-market trading.

Producers and offtakers often have to qualify not only the oil, but the entire pathway around it. Technical trials remain essential. But documentation, certification, and regulatory alignment matter too.

A business case now has more moving parts

The commercial consequence is straightforward, even if the calculation is not. TPO still has physical value. A refinery or chemical company will always compare the oil with alternative feedstocks and consider quality, processing requirements, and logistics.

But the material can now carry additional value based on its carbon characteristics and regulatory status. Those additional values are attractive because they can materially improve project economics.

They are also dangerous if treated as guaranteed. A renewable or recycled-carbon premium exists only if the relevant pathway can actually be demonstrated. End-of-waste value exists only where the conditions are fulfilled. Certification does not automatically mean that every sustainability attribute can be allocated to every ton.

The stronger business models are therefore beginning to separate the value of the physical oil from the value of its regulatory and sustainability attributes.

The same discipline is needed on the cost side.

Certification, laboratory work, GHG calculations, record-keeping, audits, and compliance personnel are not merely development expenses. For projects targeting the most sophisticated markets, they are likely to remain permanent operating costs.

That does not make the projects unattractive. It makes the assumptions more realistic.

One oil, several markets

The result is a TPO market that is becoming increasingly differentiated.

A ton sold to a European refinery under a successfully demonstrated RCF pathway is not commercially equivalent to the same ton sold into a market where the oil remains classified as waste.

Nor is oil intended for a chemical recycling route necessarily governed by the same rules as material sold for fuel use.

Even within Europe, England, France and the wider EU regulatory framework currently offer different pathways and conditions.

The implication for producers is significant.

Producers should no longer choose the destination market only after building the plant.

Where the oil will ultimately go can influence plant design, testing programs, storage, certification scope, upgrading strategy and even feedstock sourcing. A producer planning to supply several jurisdictions may effectively need several regulatory business cases for the same production facility.

More difficult — and more credible

It would be easy to look at all these developments and conclude that the TPO industry has simply acquired another layer of bureaucracy. That would tell only half of the story.

The other half is that regulatory uncertainty is gradually being replaced by defined pathways.

RED III recognizes recycled carbon fuels. ISCC has clarified how mixed fossil and biogenic feedstocks should be handled and has created a clearer route for the fossil fraction of ELTs. England and France now provide concrete examples of how TPO can move from waste into a product framework. These are substantial steps forward.

But clearer pathways also make it easier to distinguish between credible claims and optimistic assumptions.

That is likely to be healthy for the industry.

The strongest producers will increasingly be those that can demonstrate not just that they produce a technically acceptable oil, but that they understand where their feedstock comes from, what their carbon claims mean, how their product is classified, and what their customer can legitimately do with it.

The strongest offtakers, meanwhile, will be those that recognize that TPO qualification is no longer purely a laboratory exercise.

The next chapter

The past 14 months have therefore changed the TPO industry in a subtle but important way.

  • The technology itself has not suddenly changed.
  • The chemistry of tires has not changed.
  • Refineries still need oils that meet technical requirements.
  • What has changed is the framework around the product.

TPO is moving from an emerging alternative oil into a more clearly regulated circular and low-carbon feedstock. That development creates new opportunities, but it also makes the market less forgiving.

Future success will depend on more than reactor performance and oil yield.

It will depend on whether technical quality, feedstock strategy, sustainability accounting, product status, certification and customer requirements fit together.

That is a more demanding business than the one the industry was discussing only a year ago. But it also signals a maturing market.

The question is no longer simply whether tire pyrolysis oil can be produced and sold.

The more important question is whether its quality, origin, carbon value, and legal status can all be demonstrated at the same time.

And that is likely to define the next phase of the TPO industry.

This article is intended to provide an industry overview and does not constitute legal advice. Regulatory status and compliance requirements should be confirmed for the relevant jurisdiction, facility, product, and intended use.

Principal sources

This article synthesizes the Weibold Academy TPO series published between June 2025 and July 2026 and has been updated against primary regulatory and certification sources available as of 27 August 2026, including Directive (EU) 2023/2413, Commission Delegated Regulation (EU) 2023/1185, ISCC EU Mass Balance Guidance Version 1.2, the April 2026 ISCC EU Material List, the Environment Agency’s Tyre Pyrolysis Oil Resource Framework, the French Order of 21 July 2026 on end-of-waste criteria for ELT thermolysis oil, and current European Commission materials concerning environmental simplification and the forthcoming Circular Economy Act.

Copyright: ©2026 by Robert Weibold GmbH. This article is an open-access article distributed under the terms and conditions of the Creative Commons Attribution (CC BY) license CC BY 4.0. You must give appropriate credit, provide a link to the license and this article, and indicate if changes were made. You may do so in any reasonable manner, but not in any way that suggests the licensor endorses you or your use.