Tyres Europe and Recycling Europe are urging the European Commission to introduce harmonized EU-wide End-of-Waste criteria for rubber recovered from end-of-life tires, arguing that fragmented national rules are restricting trade, investment and wider use of recycled tire materials. In a joint position published on July 31, 2026, the two organizations said clear and binding criteria are needed to determine when ELT-derived rubber ceases to be classified as waste and becomes a product. They argue that a common framework would reduce administrative barriers, improve legal certainty, support quality assurance and make it easier for tire and rubber manufacturers to incorporate recycled materials into new products. The initiative is also linked to wider EU circular economy objectives, including the Clean Industrial Deal, the forthcoming Circular Economy Act and the Ecodesign for Sustainable Products Regulation, which are expected to increase demand for recycled materials and strengthen Europe’s internal market for secondary raw materials.

Lack of harmonization creates barriers across EU markets

Tyres Europe and Recycling Europe identify the absence of common End-of-Waste criteria as a persistent obstacle for the European tire recycling sector. While several Member States have already introduced national rules, differences between those systems can complicate cross-border trade because a material recognized as a product in one country may still be treated as waste in another.

The organizations say this uncertainty increases administrative burdens, reduces market confidence and makes it more difficult for recyclers and manufacturers to establish stable European supply chains for recycled tire rubber.

Joint position calls for binding EU-wide framework

The two associations are calling for a harmonized legal framework applicable across all Member States. Such criteria would establish common conditions under which rubber recovered from end-of-life tires can move from waste status to product status.

According to the joint paper, the framework should create equal conditions for trade, reduce administrative burdens, enable manufacturers to use more recycled material and ensure that secondary raw materials meet relevant safety and quality requirements.

Product status can trigger additional regulatory requirements

The joint position notes that some product-related regulatory requirements only apply once recycled rubber is no longer legally classified as waste. Examples include Declarations of Performance for construction products and requirements linked to REACH restrictions on chemical substances.

Harmonized End-of-Waste rules could therefore provide greater clarity for manufacturers and users by defining when recycled tire rubber enters the product regulatory framework and which quality and safety requirements must then be met.

ELT rubber ranked among top candidates for EU criteria

Rubber from end-of-life tires was previously identified by the European Commission’s Joint Research Centre as one of the leading candidate waste streams for development of EU-wide End-of-Waste criteria.

The joint paper says progress has nevertheless stalled for more than three years despite the tire value chain having already developed technical work assessing how ELT-derived rubber can satisfy the conditions established under Article 6 of the Waste Framework Directive.

Several Member States already use national criteria

National End-of-Waste frameworks for ELT-derived materials have already been introduced in countries including Portugal, Spain, France, Italy and Lithuania. Tyres Europe and Recycling Europe acknowledge that such rules can support domestic markets but argue that they do not solve problems associated with cross-border trade.

If national standards differ or are not mutually recognized, recyclers may face additional legal and administrative requirements when moving recycled rubber between Member States, reducing the advantages of the EU single market.

Europe collected around 3.9 million tonnes of ELTs in 2024

The joint paper states that approximately 3.9 million tonnes of end-of-life tires were collected and made available for treatment in Europe in 2024. Roughly half were recycled into materials including rubber, steel and textile fibers, while the other half was largely directed to co-incineration in the cement industry.

The document also estimates that up to one third of ELT treatment takes place outside Europe. Tyres Europe and Recycling Europe argue that stronger domestic markets for recycled tire materials could help retain more resources within the European economy.

Recycling rates remain relatively stable

Although ELT collection volumes have increased over time, the organizations say recycling rates have remained comparatively stable. They argue that stronger demand for recycled rubber is necessary if Europe is to accommodate future growth in end-of-life tire volumes without relying increasingly on exports or energy recovery.

Developing harmonized End-of-Waste criteria is presented as one way to improve market access and create greater confidence in recycled tire-derived materials.

Criteria could support tire-to-tire circularity

Tyres Europe said common End-of-Waste rules could help increase the use of recycled inputs in tire manufacturing and support objectives under the Ecodesign for Sustainable Products Regulation. Clear product status could make it easier for manufacturers to source secondary raw materials across Europe and integrate them into new tire and rubber products.

The approach could also support investment in higher-value tire recycling applications by creating more predictable market conditions for recovered rubber.

Proposal linked to EU industrial and circular economy policy

The joint paper connects End-of-Waste reform with the EU Clean Industrial Deal, which emphasizes circularity, resilience and reduced dependency on imported raw materials. It also points to the planned Circular Economy Act as an opportunity to strengthen demand for recycled materials and improve the internal market for waste-derived resources.

Tyres Europe and Recycling Europe argue that recycled tire rubber can contribute to these goals by reducing demand for virgin resources and keeping more secondary raw materials within European industrial supply chains.

Industry says technical basis is already available

The organizations maintain that the technical conditions necessary to determine when ELT-derived rubber can cease being waste are already well established. In 2021, Recycling Europe and Tyres Europe commissioned an assessment of Waste Framework Directive End-of-Waste criteria for end-of-life tire rubber.

They are now asking the European Commission to use this existing technical work as the basis for developing binding EU rules rather than delaying further studies or leaving Member States to develop separate approaches.

Harmonized rules could strengthen investment and market confidence

The joint position argues that a common framework would improve investor certainty, increase confidence among buyers of recycled rubber and encourage research and development into new applications for materials recovered from end-of-life tires.

Tyres Europe and Recycling Europe say the tire value chain is ready to support the Commission in developing practical and enforceable criteria. Their central argument is that tire recycling capacity alone is not sufficient: recycled materials also require a functioning European market in which their legal status, quality requirements and conditions of trade are clear and consistent.

Original joint position by Tyres Europe and Recycling Europe.