The Tyre Recovery Association (TRA) has issued a stark warning that the UK's new enhanced verification system for waste tyre exports is failing to deliver meaningful compliance and the data now backs them up.
In a letter to Mary Creagh MP, Minister for Waste and Recycling, the TRA praised the minister for the action she took last year after evidence emerged that enforcement of end-of-life tyre (ELT) export regulations was seriously deficient. Waste tyres illegally imported from Britain had been identified as a primary feedstock for highly polluting batch pyrolysis plants in India.
New figures, revealed through parliamentary questions tabled by Tessa Munt MP, paint a troubling picture. According to a written ministerial response dated 12 February, 3,281 Annex VII documents have been authorised for tyre exports since October 2025. Of the 1,891 consignments that have passed their eight-week reporting deadline, 1,370 have returned no post-shipment information whatsoever. Of those that did respond, only 458 met the required standards.
In plain terms: more than three quarters of recent whole ELT exports remain entirely undocumented, an outcome that is difficult to reconcile with a system introduced to sharpen environmental oversight.
Beyond the headline figures, the TRA has identified further failings in the enforcement landscape. There is no evidence that the Environment Agency has removed non-compliant receiving sites from its approved list. It also remains unclear whether brokers who have failed to provide the required post-shipment documentation are being issued with stop notices, a basic compliance tool that ought to be deployed as a matter of course.
The TRA says the current approach amounts to a system in name only: rules exist on paper, but without consistent enforcement action, importers and brokers face little meaningful consequence for non-compliance.
The TRA is urging the UK Government to follow Australia's lead. In December 2021, Australia banned the export of whole and baled ELTs outright. Under the Australian model, tyres must be processed into shred or crumb of no more than 150mm before they can be exported. The TRA argues that introducing equivalent legislation in the UK would provide the regulatory certainty needed to unlock significant private investment in domestic ELT processing, investment that is currently being withheld due to ongoing enforcement uncertainty.
The scale of the opportunity is considerable. The TRA estimates there are at least 150,000 tonnes of idle domestic recycling capacity sitting unused in the UK capacity that remains dormant precisely because weak enforcement allows cheaper, unregulated export routes to persist. A shred-only mandate would change that calculus overnight, making domestic processing the only viable option and driving expansion across the secondary tyre industry.
Alongside the call for a shred-only export policy, the TRA is pressing the government to end the T8 waste tyre exemption immediately. Originally conceived as a low-burden route for operators handling small volumes of tyres, the T8 exemption has, the TRA says, been widely abused by irresponsible operators exploiting its light-touch requirements at minimal cost. The result is an uneven playing field that penalises legitimate UK recyclers while subsidising fly-by-night operators.
Peter Taylor OBE, Secretary General of the TRA, was unambiguous in his assessment of the situation:
“A new system with a 75% failure rate is not a solution. Despite the Government’s best intentions to sharpen the Environment Agency’s teeth, the new enhanced verification measures are being ignored by brokers and operators who continue to fuel unregulated pollution overseas.
“The only way to secure the integrity of our waste stream and protect the environment is to move beyond paperwork and mandate a ‘shred-only’ export policy. A model with proven success in Australia. We now know that recent efforts to improve enforcement of existing rules still have a long road to travel before there are signs of success. Legitimate operators in the UK continue to be disadvantaged and significant domestic capacity lies idle.”
“2026 must be the year that the UK stops exporting its environmental responsibilities - bring in the Australian model and build a robust, truly circular UK economy for tyres.”
The TRA's intervention comes as pressure mounts on the government to demonstrate that environmental commitments on waste export translate into real-world outcomes. With over three quarters of ELT export consignments undocumented and 150,000 tonnes of domestic processing capacity sitting idle, the association argues the case for structural reform has never been stronger.
Tagged with: waste tyre exports, end-of-life tyres, Annex VII, Environment Agency, enhanced verification, shred-only exports, tyre recycling capacity, T8 exemption, geotagged evidence, circular economy, ELT compliance
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