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Tyre kickers needed?

We’re tired of the slow progress towards real, verifiable Tyre recycling and re-manufacturing. But your help will speed up progress with our lawmakers. We need you to ‘kick some tyres’. Here’s how to make a difference.

The Background

Remember the Minister for the Environment (and other things, such as Communications, & Climate Action ) Mr Denis Naughton planned to introduce a Producer Responsibility Initiative to attack the widespread illegal dumping of used tyres.  Well, things are moving along (slowly as usual but at least rolling along in the right direction). The Joint Oireachtas Committee (JOC) on Communications , Climate Action and Environment are currently scrutinising the Waste Management (Tyres and Waste Tyres) Regulations 2017 (SI 400 of 2017).

These regulations are finally delivering on recommendations stemming from a report in 2013 which looked specifically at how the tyre industry was operating producer responsibility schemes. The report revealed inadequacies  and found that:

  1. up to 50% of all used tyres were unaccounted for  – i.e. LOST
  2. there was a significant rate of non-compliance with the previous regulations and
  3. there was a lack of consistent and accurate data on tyres.

The scale of the problem with waste tyres is now so bad that the Minister has made €1m available this year to the 23 local authorities who have reported illegal stockpiles of tyres dumped within their jurisdictions.

What do the new regulations do?

The regulations signed by the Minister enable the establishment of a full compliance scheme for tyre producers, distributors and retailers, which is financed by a visible Environmental Management Cost (vEMC).   This new Tyre Tax will help plug the gaps and eliminate the 50% losses we currently experience, as tyres get illegally dumped or burned.

Similar compliance schemes have operated very successfully for other waste streams like packaging, waste electrical and electronic goods (WEE), batteries and farm plastics. The introduction of the vEMC charge will standardise and formalise a charge that tyre retailers already apply to purchases of new tyres by consumers. It will ensure that the fee they pay actually goes towards what it is supposed to support – the correct environmental treatment of waste tyres. Currently they charge consumers but do not deliver fully on the proper disposal of up to 50% of the used tyres. So the charges are pocketed by some unscrupulous operators as extra profits. We want this to end.

What Can you do to help?

The Dail Committee (JOC) are meeting again next Tues 24 October and they need to be aware of the level of concern we, the citizens who pay the costs, have about the scheme operating well.

It must eliminate the illegal dumping of tyres.   It would be of particular benefit to the Committee if they could be given evidence of the scale of the problem with dumped tyres and the benefit to us all of a system that traces the movement of all tyres on and off the road.

But we’re aware that the tyre industry is trying to persuade the Dail Committee to block this regulation! Yes, it’s hard to believe but they seem to be winning. So we all need to get in a submission to assert our support for the new regulation  ASAP.

How to submit your opinion.

So we want as many people as possible to contact their TD’s and those TDs and Senators on the Dail Committee (JOC).   We want you to send in submissions tomorrow, Sunday or Monday at latest.

It could be as simple as welcoming the Regulations and referencing the success of the earlier examples below or just a plea to end the curse of illegal dumping and mention any personal experience you had with illegally dumped tyres.

Maybe send a photo or two. We have a template to help you below. Just take it and copy what you want and add a personal note. Then email it to the chosen targets. You can also cite references from the other PRI schemes listed below.

There are reference material and articles that you might find useful to make extra points but a very simple one-pager is all that is needed to alert the Committee members to the mood of their electorate.

There is Zero cost to doing it. Just send an email (click on the name to get the email address). We really appreciate your time and effort.

Who should you contact with your submission?

Please send your submissions to any or all of the following people :

Chairman: Deputy Hildegarde Naughton hildegarde.naughton@oireachtas.ie

  1. Vice Chairman: 
    Deputy James Lawlessjames.lawless@oireachtas.ie
  2. Clerk to the Joint Committee on Communications, Climate Action and EnvironmentLeo Bollins – leo.bollins@oireachtas.ie
  3. Committee MemberParty / Group Deputies:
    Timmy Dooley Fianna Fáil
    James Lawless Fianna Fáil
    Michael Lowry Rural Independent Group
    Hildegarde Naughton Fine Gael
    Eamon Ryan Social Democrats – Green Party Group
    Bríd Smith Solidarity – People Before Profit
    Brian Stanley Sinn Féin
  4. Senators:
    Terry Leyden Fianna Fáil
    Tim Lombard Fine Gael
    Michael McDowell Independent Group
    Joe O’Reilly Fine Gael

Sample text on which to base your submission


Dear Mr/Ms /Deputy/Senator xxxxx,

REF: Waste Management (Tyres and Waste Tyres) Regulations 2017 (SI 400 of 2017).

I am alarmed and concerned to see that the rapid implementation of the Producer Responsibility Incentive (PRI) is not proceeding through the Oireachtas quickly. Similar schemes are now well established e.g. Repak Packaging Waste scheme was established on 10 June 1997, 20 years ago, WEE scheme exists since 5 July 2005. An effective recycling management scheme for used tyres is long overdue.

We have to make progress with used tyres as they offer new opportunities and jobs in recycling and remanufacturing activity e.g. crumb rubber makes playground surfaces, running track surfaces, road noise barriers and flexible concrete walls (http://www.ruconbar.com is a good example) 

The waste of these recycled tyres in illegal dumping and burning activity is a complete failure with respect to today’s strive for a Circular Economy and the Government’s stated EU commitment to reduce our Nation’s contribution to Greenhouse Gases.

The legacy of non-recycled tyres littering our countrysides, waterways and seas should not be contemplated. Nor should we allow used tyres to be used as fuel for cement kilns, as recent An Bord Pleanala applications have sought to do.

So I urge you to proceed with all haste to bring the SI 400 of 2017 into effect.

It must be implemented thoroughly, quickly and transparently and the recycling monies collected used for environmental projects exclusively.

Yours sincerely,

[Name &  address]


When done, why not post your submission on the Zero Waste Alliance Ireland Facebook Page, so we can all clap your effort. Thank you.

Useful references:

PRI Models used as basis for the new Tyres PRI

Farm Plastics:  The PRI scheme for the recovery and recycling of farm plastics was established by Minister Dempsey on 14 July 1997. [FF-PD Govt]

Packaging/Repak:  The PRI scheme to organise and finance the environmental management of packaging waste was established by Minister Howlin on 10 June 1997. [FG-Lab-DL Govt] The regulations were consolidated, in order to bring improved clarity, transparency and accessibility to the packaging PRI, by Minister Gormley on 7 December 2007 [FF-GP-PD Govt]

WEEE Ireland:  The PRI scheme to organise and finance the environmental management of household waste electrical and electronic equipment was established by Minister Roche on 5 July 2005. [FF-PD Govt]

Tyres: A scheme to track/collect data on tyres, but not fund or subsidise the collection and treatment of tyres, was approved by Minister Gormley on 27 September 2007. [FF-GP-PD Govt]

Batteries:  The PRI scheme for the collection, treatment and recycling of waste batteries was implemented by Minister Gormley on 16 July 2008. [FF-GP Govt]

Other info/articles you can use in your email:

  1. Plastic from tyres ‘major source’ of ocean pollution
  2. https://en.wikipedia.org/wiki/Tire_fire
  3. http://www.ruconbar.com

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