Lina Goodman

Tyre Stewardship Australia has released the most comprehensive analysis of the Australian end-of-life tyre market that provides a rigorous data set, insight into the impact of the ban and options to support a transitioning market.

Following the recent Council of Australian Governments (COAG) meeting in March, the export ban, which will commence on 1 December 2021, applies to all whole waste tyres, including baled tyres.

According to the COAG Waste Export Bans response strategy, bus, truck and aviation tyres which are legitimately exported for re-treading can continue to be exported and are not subject to the ban.

The COAG strategy points out that this is on the basis that re-treading represents a re-use. This is a higher order ‘waste hierarchy’ outcome through the resource efficiency outcomes associated with extending a tyre’s primary use, rather than reaching end-of-life and being processed into a secondary material such as a crumb or shred.

Additionally, crumb rubber, buffings, granules and tyre shred less than 80 millimetres will still be exportable as such materials are considered a ‘value-added product’ and not a waste and are therefore not subject to the ban.

As a result, the volume of waste tyres that are currently exported which are expected to be subject to the ban once it is enacted will equate to 61,282 tonnes of whole used tyres, including baled tyres, with around a third being generated in NSW and Victoria.

While the waste industry has long called for national standards and specifications for tyre-derived product in infrastructure, the COAG report’s call to action suggests the feds may finally heed this call.

Moreover, it points to “tyre research and innovation” through further support for commercialisation of new technologies, including crumb rubber in permeable pavements.

This is a product that Tyre Stewardship Australia (TSA) has supported from early stage research to its current stage of commercialisation. Likewise, improved tracking of tyre fates and looking at recovering off-the-road (OTR) tyres is another important next step.

These plans for targeted action are consistent with the work of TSA, which has been supporting progress in these areas since it initiated market development activities five years ago.

Now, TSA has released the most authoritative and up to date data set on end-of-life tyre arisings in Australia to date.

The report, Used tyres supply chain and fate analysis, is the most comprehensive and biggest piece of research conducted into the end-of-life tyre market since the 2017 National Market Development Strategy for Used Tyres.

It combines material flow analysis data with TSA participant reports to provide a complete picture on the fate of all tyres: passenger, truck and off-the-road.

One of the key gaps identified in the last study was that around 60 to 65 per cent of all waste tyres generated were disposed to landfill or other fates like dumping or illegal stockpiling, with little verifiable data to specifically quantify each fate.

This report addresses that, and according to TSA CEO Lina Goodman, supports TSA’s role as an information hub, thought leader and provider of rigorous, independent data for the resource recovery sector.

SMASHING THE TARGET

Lina says it’s positive to see recovery rates in passenger and truck tyres at 89 per cent, which exceeds the 2018 National Waste Policy target set at 80 per cent.

Unfortunately, a recovery rate closer to 10 per cent for OTR tyres (large mining and agricultural tyres) brings down the overall recovery rate for the sector.

“Of the 460,000 tonnes used tyre arisings that reach end-of-life each year, we are seeing that 69 per cent is being recovered in passenger, truck and OTR, whether its reuse, process of tyre-derived product or used whole in thermal processing,” Lina explains.

For example, she says that when looking at the often quoted 56 million equivalent passenger units (EPUs) tyre generation figure, which is now 57 million, 40 million of these EPUs were recovered.

Lina adds that market development is a strength in Australia, and an area TSA has worked tirelessly to develop. However, finding further end markets for waste tyre consumption is critical, particularly with the impending ban.

To that end, she says on-shore energy recovery is an area of untapped potential, with cement kilns in Australia a possible outlet.

“When I travelled overseas late last year to visit a number of sister schemes in Europe, one thing I noticed was that many schemes do an excellent job at collecting and processing waste tyres domestically, and part of that is to do with consistent onshore consumption via tyre derived fuels (TDF) in cement kilns,” Lina says.

As a proportion, Australia sends a similar amount of tyres to TDF end markets. However, Australian tyres are consumed offshore in Asia – not in the domestic markets as is the case in Europe and the US.

“With the ban in place, we need to focus on energy recovery as an outlet in Australia to insulate against fluctuations in foreign trade and commodity prices – such as those we are experiencing in the global trade now.”

Lina asserts that the waste ban, coupled with the disruption of global markets, will no doubt affect the cost of collection and this is an area that TSA is watching closely.

It comes as demand in India for foreign tyres constrains, with its National Green Tribunal directing the Central Pollution Control to regulate the import of waste tyres. Not to mention the impact of COVID19.

“With current upheavals in the global markets, we will see an increased risk of stockpiling as local processing capacity is limited in terms of national distribution, foreign outlets are constrained and sites reach storage limits,” Lina says.

She says that based on this, TSA will identify and engage with stakeholders to provide both a short and long-term plan to mitigate stockpiling before issues arise. Importantly, TSA will be keeping an eye on coordinated efforts by rogue operators.

“Our relationship with the consumer app Snap, Send, Solve is integral now more than ever. We’ll be asking consumers to keep an eye out and report cases of dumping. It means TSA gets live data on dumping throughout Australia and can jump on these issues right away,” she says.

KEY RECOMMENDATIONS

To that end, the key recommendations of the report are to increase the proportion of levied tyre sales.

With the TSA levy being paid on around 34 per cent (140,000 tonnes) of all imported passenger and truck tyres (26 per cent when including OTR) – there is significant opportunity to improve coverage of the Tyre Stewardship Scheme considering participants handled around 50 per cent of used tyre arisings (85 per cent of passenger tyres) in 2018-19.

Secondly, investigating export end markets and foreign policy plans to ensure offshore markets for shredded tyres are stable is another report recommendation.

Particularly as there will likely be a move from baling to shredding as the ban looms closer, creating an ever greater need to find foreign end market outlets for such materials.

Thirdly, in line with the research completed on OTR tyres, more work is required to stimulate OTR markets to bring the 10 per cent recovery rate in this sector more in line with that of passenger and truck tyres which is close to 90 per cent.

Finally, continuing to analyse the costs of tyre recovery will be crucial to enable TSA and other stakeholders to monitor market conditions and better understand existing and potential market risks.

“We need government intervention to help the Tyre Stewardship Scheme.

It can only go so far with the current voluntary model. Government needs to intervene so that all tyre importers play their part in contributing to better end of life tyre outcomes – not just the eight companies that currently voluntarily contribute the levy,” Lina says.

“Our market development is excellent, and it needs to remain the focus. We need to see more tyre-derived product being utilised in a wider range of applications. There is growth happening now and we believe it will escalate with the announcement of the ban – and ideally a greater financial contribution from the current ‘free riders’ should government intervene and make scheme participation compulsory for tyre importers.”

NEXT STEPS

With this in mind, building a consistent strategy around local consumption of tyre-derived product is going to play an increasing role for the next evolution of tyre resource recovery.

When it comes to the domestic fate, the data shows a number of markets are very much in their infancy.

This comprises civil engineering which makes up only one per cent of the market, or pyrolysis at less than one per cent. Around 32,900 tonnes of used tyres were recycled into crumb, granules and buffings in Australia (17 per cent) with the majority of material derived from truck tyres.

No TDF is used in Australia in cement kilns, industrial boilers or furnaces, with all TDF currently going offshore.

“In Australia, we still don’t consume enough of our own waste and we really need to focus on how we’re going to build those alternate markets to use that.”

“We’ve done some great work in market development, but we need to now work on how we’re going to commercialise it, whether it’s research and prototyping, and if so we need to dial it up in a big way. The market and environment are right, we just need to help drive outcomes.”

Passenger tyres, she says, are another priority area.

“I think the passenger tyre issue is really important because at the moment we are seeing that the major fate for passenger tyres is fuel consumption overseas.”

“Truck tyres are valuable because they’re easier to crumb than passenger tyres. We need to dispel the myth that passenger tyres can’t be used in crumb rubber applications – because they can, they just need to be processed a bit differently.”

Notably, the data reflects huge decline in stockpiling. Stockpiles now make up less than one per cent, or around 5600 tonnes of used tyres, which in the report are defined as more than 40 tonnes of untreated or unprocessed product with onsite storage for more than 12 months.

The report attributes this decrease in stockpiling to stronger EPA regulation and enforcement and increases in the volume of baled passenger tyres exported over the last few years.

However, Lina notes that with the implementation of the ban and constraints in the demand for Australian tyres from foreign markets such as India, more material may accumulate in Australia, creating stockpiling risks for responsible authorities and the community more broadly.

Also, as was noted by a recent announcement by the UK Tyre Recovery Association, with baling being removed from the market, gate fees may rise, incentivising less scrupulous operators to collect without legitimate outlets, thereby encouraging dumping.

Coordinated activity between TSA, processors, industry associations and government are needed to mitigate these risks.  

Lina adds that new participants in the market, including online retailers, will create a controlled ecosystem that helps squeeze rogue operators out of the market.   

“Auto brands are seeing a positive partnership in working with TSA and we hope to see more of that over the next 12 months,” Lina says.

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