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.

Introduction

The UK Environment Agency (EA) has recently published a detailed internal review on the export of end-of-life tires (ELTs). The report highlights significant regulatory shortcomings, raising questions about the environmental and legal soundness of current practices. Since India receives the majority of UK tire exports, the review carries substantial implications for trade flows, compliance requirements, and the structure of the ELT recovery market.

Key Findings of the Review

Documentation and Oversight Failures

Exports of ELTs from the UK to India are currently governed under Article 18 “green list” controls, which require an Annex VII form to accompany shipments. These forms are intended to document the movement of waste, including its origin, transit, and final recovery destination. However, the EA found credible evidence of falsification. Shipments have, in multiple cases, been diverted from the designated recovery facilities to unregulated operations. The regulator concluded that it cannot assume that exported tires are managed in line with the principles of environmentally sound management.

Illegal Practices

A particular area of concern is the diversion of ELTs into pyrolysis operations. While pyrolysis can be a legitimate recovery method if conducted under controlled conditions, in India, unlicensed facilities have been linked to unsafe practices and environmental harm. Since July 2022, India has prohibited the import of ELTs for pyrolysis. Nevertheless, evidence suggests that tires continue to be diverted at ports to these facilities, undermining both Indian regulations and the intent of the UK’s waste shipment framework.

Indian Regulatory Capacity

The Ministry of Environment, Forest, and Climate Change (MoEFCC) is responsible for authorizing tire imports in India, while the State Pollution Control Boards (SPCBs) regulate facilities. However, SPCBs reportedly lack sufficient enforcement powers against illegal operators. This structural weakness has led to inconsistent oversight, particularly in relation to pyrolysis plants. At the same time, India’s domestic recycling capacity, estimated at 2.5 million tons annually, exceeds the combined volume of domestic and imported ELTs. This high capacity continues to create strong market demand for imported tires, despite restrictions.

Planned Regulatory Actions in the UK

The EA has announced a phased set of reforms to address the shortcomings identified:

  1. Enhanced Export Verification (effective October 2025): Exporters of ELTs to India will be required to provide robust evidence that shipments are delivered to approved facilities and processed in accordance with environmental standards. The EA intends to issue information notices and block shipments where compliance cannot be demonstrated.
  2. Mandatory Submission of Annex VII Forms: Currently, Annex VII forms accompany shipments but are not routinely submitted to the EA. Under the new framework, pre-shipment submission will become compulsory. This will allow greater scrutiny and introduce a fee structure to support compliance activities.
  3. Removal of the T8 Exemption: The government has committed to ending the T8 exemption, which allowed certain operators to manage tires without holding full permits. This exemption has been widely abused, with operators handling volumes far beyond authorized thresholds. Its removal will require all operators to hold permits that include competence standards, fire prevention measures, and mandatory reporting.
  4. International Cooperation: Recognizing the transnational nature of the issue, the EA intends to expand collaboration with the MoEFCC, SPCBs, and international partners. A visit to India is planned for autumn 2025 to meet with regulators and industry stakeholders, as well as to inspect facilities and ports. Additionally, the EA will enhance its collaboration with the British High Commission, INTERPOL, and Europol.

Implications for the ELT Market

Constraints on Exports

The introduction of enhanced verification and mandatory Annex VII submissions will increase administrative requirements for exporters. Compliance costs are expected to rise, and some shipments may be prohibited if evidence of environmentally sound management cannot be demonstrated. The cumulative effect is likely to reduce the volume of ELTs exported from the UK to India.

Pressure on Domestic Recycling Capacity

Reduced access to Indian markets will increase pressure on UK recyclers to handle a larger share of ELTs domestically. The UK currently lacks sufficient infrastructure to absorb these volumes. However, the reforms may create incentives for investment in new capacity, potentially strengthening the domestic recycling industry in the medium to long term.

Market Rebalancing in India

For Indian recyclers, imported ELTs continue to be a valuable resource. However, stricter verification requirements on the UK side and India’s prohibition of imports for pyrolysis will likely lead to a rebalancing. Other exporting countries may fill the gaps left by declining UK volumes.

Risks for UK Exporters

Smaller operators, especially those that previously relied on the T8 exemption, may face challenges adapting to the new requirements. Non-compliance may result in financial penalties, reputational harm, or the loss of export permissions. The reforms, therefore, raise the threshold for participation in the ELT export trade.

Broader Context

The UK reforms align with international trends. Australia and the European Union have all introduced restrictions on tire exports in recent years, aiming to reinforce domestic recycling capacity and reduce reliance on environmentally unsound recovery abroad. The UK’s measures represent a step towards harmonization with these global developments, despite its regulatory autonomy post-Brexit.

Conclusion

The EA’s review identifies fundamental weaknesses in the current system governing UK tire exports to India. With evidence of falsified documentation, diversion into prohibited pyrolysis operations, and inadequate oversight, the Agency has concluded that stronger measures are necessary. The reforms outlined—enhanced verification, mandatory submissions, removal of exemptions, and international cooperation—are designed to improve transparency and compliance.

For the ELT market, the implications are significant. Export volumes to India are likely to decline, compliance costs will increase, and pressure will mount on domestic recyclers to expand capacity. While the reforms may create short-term disruption, they also present an opportunity to develop a more robust and sustainable tire recovery sector within the UK.

If you would like to gain deeper insights into this topic, please don't hesitate to contact the author, claus@weibold.com.