Fewer than one in four UK waste tyre export shipments are meeting the basic compliance requirements of the Environment Agency's enhanced verification regime, according to government data revealed through parliamentary questions and reported in February by the Tyre Recovery Association. The figures, which cover the period since the new checks came into force on 1 October 2025, have prompted the TRA to write directly to Mary Creagh MP, Minister for Waste and Recycling, calling for the UK to introduce a mandatory shred-only export policy modelled on Australia's approach.
The enhanced verification regime was introduced by the EA following a review prompted by evidence that UK waste tyres were being diverted from licensed recycling facilities to illegal pyrolysis operations in India, where tyre imports for pyrolysis were banned in July 2022. Under the new rules, exporters subject to an information notice must provide documentary evidence that their chosen Indian recovery facility meets environmentally sound management (ESM) standards broadly equivalent to those in the UK, as well as submitting Annex VII waste movement forms both before and after each shipment. Between 1 October and 15 December 2025, the EA served information notices on 42 exporters, approved 41 Indian recovery facilities and rejected 13, and received 1,093 Annex VII forms. For a tyre collector or recycler using an export contractor, this means the burden of demonstrating compliance now runs through every link of the chain, not just the point of collection.
Despite the new framework, the TRA reports that compliance rates remain below 25%, with Tyre and Rubber Recycling citing an unofficial industry figure of 77 non-compliant operators. The TRA has warned that legitimate processors in the UK continue to be undercut by exporters who are not meeting their documentation obligations, and that at least 150,000 tonnes of licensed domestic recycling capacity lies idle as a direct consequence. The EA has said it will consider prohibiting further shipments from exporters who have not provided required post-shipment documentation, but the industry is seeking confirmation that stop notices are actually being issued rather than threatened.
The TRA's response is a call for structural reform rather than further enforcement tweaks. In its letter to the minister, the association urged the UK to replicate Australia's Recycling and Waste Reduction Act 2020, under which whole and baled end-of-life tyre exports were banned from December 2021 and tyres must be processed into shred or crumb of no more than 150mm before export. According to the Australian Tyre Recycling Association's Executive Officer Rob Kelman, the policy delivered improved market confidence and investment in new recycling infrastructure. The TRA argues that introducing an equivalent mandate in the UK would unlock multi-million pound investment in shredding and crumbing capacity, support secondary industries including rubber crumb for sports surfaces and acoustic products, and end what Peter Taylor OBE, Secretary General of the TRA, described as the UK exporting its environmental responsibilities. Taylor stated: "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."
Not everyone in the sector accepts the shred-only argument without reservation. Critics of the proposal note that mandating shredding before export does not eliminate the risk of misuse at the Indian end of the chain, and at least one formerly active importer in India has confirmed to Tyre and Rubber Recycling that their business had not imported UK tyres in the past year, suggesting some market adjustment is already under way without a legislative mandate. The EA itself has signalled that a wider charging scheme for green list waste movements is planned for consultation in early 2026, and that digital waste tracking remains part of the long-term approach, though Defra has yet to confirm delivery timelines.
The EA has committed to publishing a further update on its enhanced verification findings in spring 2026, including analysis of the completed Annex VII post-shipment forms that became mandatory from 22 December 2025. That update will provide the clearest picture yet of how many operators are in persistent breach and whether prohibition notices are being used at scale. For the UK tyre recycling sector, it represents the next critical enforcement moment in a policy debate that has been running for years without resolution.
For tyre recycling businesses and tyre retailers with duty-of-care obligations, the sub-25% compliance rate is a direct operational warning. Any business using a third-party export contractor to handle end-of-life tyres should verify that contractor's compliance with the EA's enhanced verification requirements before the spring 2026 update is published, since the EA has indicated it will consider shipment prohibitions against persistently non-compliant exporters. Recyclers with domestic shredding or granulating capacity are better positioned than at any point in the past decade to compete on a level playing field, but only if enforcement follows through. The TRA's shred-only push, if adopted, would represent the most significant structural change to the UK ELT sector since the landfill ban of 2006, and businesses planning capital investment in processing equipment should be monitoring the ministerial response to the TRA's letter closely.
Tagged with:waste tyre exports, end-of-life tyres, Tyre Recovery Association, Environment Agency, shred-only export, ELT compliance, tyre recycling UK, Annex VII, Mary Creagh, circular economy tyres, domestic tyre recycling capacity, tyre export enforcement
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