Does Tyre Stewardship Australia (TSA) need to change to be more supportive of tyre processors? Is TSA delivering public benefit? Should the scheme be made mandatory?
It’s the answers to these questions, says Lina Goodman, TSA Chief Executive Officer, that could help shape the future direction of the stewardship scheme.
TSA is waiting on the findings of an independent review, mandated by the Australian Competition and Consumer Commission (ACCC) for all product stewardship schemes, to determine if the scheme is adding value.
Lina describes it as a “hard-core report card” which outlines the scheme’s success and its failings. But she says it’s not a report that slaps you over the wrist and publicly shames you. If used correctly it can pivot the scheme to do better.
“It’s important for schemes to do these reviews. If they don’t, they will rely on what they believe they should be doing, rather than what the sector needs them to do,” Lina says. “I see it as an opportunity to be better, grow differently and evaluate where we are. We don’t want to be a scheme that stays the same forever because the market is not going to stay the same.”
TSA was established in 2014 to create productive outcomes for end-of-life tyres. Since then, it has accredited 1700 participants through the scheme, supporting sustainable outcomes, and has attracted top name tyre importers and auto brands to financially contribute. TSA has also committed more than $8 million to market development initiatives to increase the use of local tyre-derived products.
An independent review is designed to ensure product stewardship schemes continue to benefit the public. The review includes upwards of 50 interviews with government bodies, recyclers, processors, consumers and anyone involved in a particular scheme.
Lina says one of the recommendations of an original review conducted in 2017-18 was that TSA needed to do more than just fund research projects, rather there was a need to allocate funds towards infrastructure grants, aimed at supporting the practical application of crumb rubber in projects.
“When we commenced our focus was largely on research projects, whilst important, they failed to demonstrate the benefit of crumb rubber in the real world,” she says. “This led to a change in the Scheme to expand the commitment towards infrastructure projects. This change, coupled with continued research, is when change really started to take shape.
“If acted upon, the independent review recommendations can have a sizeable impact.”
While careful not to pre-empt the latest review findings, Lina hopes it will show that TSA is delivering public benefit. She believes the scheme is supporting the sector with market development, accreditation compliance and engagement with the Environment Protection Authority.
She is also hopeful the review will recognise that TSA has been an advocacy body for the sector and providing support to them “when things fall over” such as recent policy changes by global shipping companies.
But she says, as a voluntary scheme it can only go so far and believes the review may indicate a change of direction is needed.
“It’s evident even in addressing free-riders. We only have 47 per cent of passenger truck and tyre manufacturers contributing to the scheme,” Lina says. “That’s only changed five per cent since we started.
“Tyres imported on vehicles contribute 25 per cent to the problem but only seven per cent of the market is participating in the scheme. That shows a failure with the voluntary scheme. It indicates to me that the review will likely tell us there needs to be more support, or for TSA to be successful, we need to move out of a voluntary arrangement.”
David Spear, TSA Chair, agrees that as a voluntary scheme, TSA is “pushing the envelope” in terms of what it can achieve.
“There are only so many ways we can bring the market together. A more regulatory environment is required,” he says.
“That’s my personal view as chair and director of TSA. It’s up to the independent review as to whether this is a theme that needs to be looked at further. We were a start-up seven years ago. We’ve come a long way.”
David says the board understands its duties from a governance perspective and believes the latest review will reflect TSA’s progression.
He encourages other product stewardship schemes to embrace the review process.
“Be open and transparent about the positives and negatives of your scheme and look to build on the base that you’ve managed to create.
“Performance is always about making strides forward, regardless of what sector you’re in. If it’s small performance issues you can build upon, so be it. If it’s large strategic issues it takes greater time and effort, but you still must have your eyes wide open to determine what the best pathway forward is.
“Reviewing performance is part of a business cycle. If you’re not reviewing performance you’re standing still.”
Rose Read, a Director of the Product Stewardship Centre of Excellence, agrees. She says the review is not about compliance, but best practice and learning how to improve this collective scheme.
“Are you being as effective as you can? Are you collecting the right data? Are you engaging with stakeholders? What are they saying and are you listening to them?” she says. “It’s a very positive process.”
The Centre was established to help accelerate the adoption of product stewardship by businesses and their supply chain, through education, mentoring, developing resources and undertaking research. It offers expertise in design, implementing and operating product stewardship initiatives against a range of product types.
Rose says more companies are reaching out individually or collectively as they consider how they can minimise the environmental and human health impacts of their products across their life cycles. There are also now 24 new collective schemes under development that received grants from the federal government’s National Product Stewardship Investment Fund.
She says part of the pathway to excellence is considering how a business can improve their practices. “Independent reviews are hearing from the people you need to hear from”.
Lina adds that while an independent review can be daunting, it’s important to remember that product stewardship schemes, like small businesses, aren’t instantly successful.
“There’s a real journey to get established,” she says. “It’s going to fall and it’s going to fail. It’s about failing safely and getting back up and understanding the areas you need to invest your time in. Most importantly, be brave.”
For more information, visit: www.tyrestewardship.org.au