Position papers
Over the last decades, the European recycling industries have drastically evolved by modernizing and constantly innovating to turn more waste streams into new resources. By doing so, the sector has contributed to the development of new technologies and automated equipment made in Europe and exported around the globe. The European regulatory framework has accompanied these changes thanks to ambitious targets and a meaningful waste hierarchy. However, the recycling sector continues to be subject to a complex and ever-growing EU regulatory framework, which affects its activities. To ensure a competitive European recycling sector, which is part of a global industry, EuRIC advocates clear, effective and smart European policies which:
- Incentivise recycling across the value chains;
- Minimise regulatory burdens on recyclers, in particular on SMEs;
- Guarantee an open and fair competition within Europe and with the world to foster a genuine internal recycling market.
EuRIC also advocates positive measures to ensure a consistent implementation of existing legislation across Europe.
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EURIC and ETRMA call for the development of EU-wide End of Waste criteria for the End of Life Tyre-derived Rubber Waste Stream
ETRMA and EuRIC are committed to support the European Commission in developing EU harmonized End of Waste (EoW) criteria.
The rubber supply chain is ready for the next step in the advancement and uptake of the recycling of ELT-derived Rubber.
This will secure that trade across European borders happens normally in equal conditions and with equivalent opportunities across borders, while reducing the administrative burdens associated with trading.
Since many regulations, like Declarations of Performance for construction products, or the REACH restriction of chemical substances only apply once the material has ceased to be waste, EU harmonized EoW criteria will also secure the material’s accountability for safety and quality criteria.
All this is of key importance to increase the uptake of ELT derived rubber in the manufacture of new rubber products for high-value end-use markets.
ETRMA and EURIC believe that securing a common starting point for end-of life tyres rubber to cease to be waste is essential to foster the circular economy in Europe. This can only be achieved with a European End-Of-Waste criteria, that is translated in a legal text, applicable in all Member States. This will add trust to the market, increase investors security and boost the research and development on innovative solutions of this valuable material.
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Revision of the ELV and 3R Type Approval Directives
The European Recycling Industries’ Confederation (EuRIC), welcomes the initiation of the Impact Assessment andrevision of both Directive 2000/53/EC on End-of-Life Vehicles (ELVs) and of the Directive 2005/64/EC on the type approval of motor vehicles with regard to their reusability, recyclability, and recoverability (3R type-approval).
EuRIC - via its various branches1 - represents Authorised Treatment Facilities (ATFs) and the vast majority of ELV recycling facilities (shredders and post-shredder installations) which recycle ELVs in Europe, and producers of plastics, rubber and metal recyclates incorporated into new automotive vehicles/parts. The Confederation therefore has a strong interest in the revision of the ELV and 3R Type-Approval Directives, and call upon the European Commission to ensure the highest level of environmental ambition is achieved as a result of this revision process. For the recycling industry, several key concerns must be addressed to build upon the success noted within the European Commission’s Evaluation report on the state of ELV treatment in the EU.2 These concerns include: missing vehicles, the eco-design of new vehicles to allow for future recyclability, recycled content, and free and fair compensation for the implementation of the Circular Economy.
This paper outlines EuRIC’s position in regard to the revision process ahead for both Directives, with a focus on key measures to be addressed.
1 European Shredder Group (ESG), European Plastics Recycling Branch (EPRB), Mechanical Tyre Recycling branch (MTR), European Shredder Group (ESG), European Plastics Recycling Branch (EPRB), Mechanical Tyre Recycling Branch (MTR), European Ferrous Recovery and Recycling Branch (EFR), European Non-Ferrous Metal Trade and Recycling Branch (EUROMETREC).
2 European Commission (2021) Evaluation of Directive (EC) 2000/53 of 18 September 2000 on end-of-life vehicles. -
EuRIC Press Release to Support Continued Use of Tyre-derived Granular Infill
EuRIC REAFFIRMS ITS COMMITMENT TO THE OBJECTIVES OF THE CIRCULAR ECONOMY AND CALLS UPON THE COMMISSION TO SUPPORT CONTINUED USE OF GRANULAR INFILL MADE FROM RECYCLED TYRES
- EuRIC warns about the questionable future of 527,000 tonnes of end-of-life tyres which may be annually incinerated, or worst stockpiled and illegally landfilled, if a ban on granular infill is adopted.
- EuRIC demands that tyre recycling into infill for artificial turfs is regarded as a strategic objective of the new Circular Economy Package considering the substantial environmental benefits of this application.
- EuRIC reiterates that preserving a circular economy for tyre recycling into artificial turf infill can and must go hand in hand with reducing microplastics’ releases through standardized risk management measures.
The European Recycling Industries’ Confederation (EuRIC) representing the collective interests of the European mechanical end-of-life tyre (ELT) recycling industry, calls upon the Commission to strengthen its commitment to the Circular Economy.
With the release of ECHA´s opinions on infill materials, now it is up to the Commission to take a decision on what measures to follow as regards this application.
EuRIC warns about the negative impacts that some of the options covered, including a complete ban, may have on the environment and on the objectives of speeding the transition towards a more circular economy.
EuRIC has raised concerns over the future of 527,000 tonnes of end-of-life tyres annually recycled into artificial turfs, warning on the risks of them being mismanaged and causing a huge environmental impact in the event of a proposal to ban infill materials.
EuRIC Mechanical Tyre Recycling Branch (EuRIC MTR) has expressed its support to the objectives of the European Commission, and it is confident that preventing a mismanagement of waste tyres will be at the focal point of their decision when taking into consideration the different options proposed by ECHA. Especially, knowing that there are no alternatives for an environmental sound management of the aproximatelly 50,000,000 tyres units annually recycled and turned into infill material.
Yet, preserving a circular economy for tyre recycling into artificial turf infill can and must go hand in hand with reducing microplastics’ releases through standardized risk management measures such as those described in the European Standards Committee (CEN) technical report CEN/TR 17519.
“State of the art mechanical tyre recycling entirely supports the European Green Deal and the new Circular Economy Action Plan” stressed Poul Steen Rasmussen, President of EuRIC MTR Branch and Group CEO Genan. “The processing of ELT tyres into rubber is not only the most resource-efficient option but also the most climate-efficient one because for each tonne of ELT recycled as infill for artificial turf pitches- the climate is spared 700 kg of CO2 when compared with co-incineration” he added.
EuRIC entirely supports the efforts of the European Commission to minimise the release of microplastics in the environment.
“We are sure that cutting down microplastics releases into environment and the circular economy goals can coexist and achieve the objective of minimising the environmental impact of microplastics, which is why we encourage the European Commission to introduce risk management measures to avoid unintended releases of microplastics into the environment, one of the options assessed by ECHA.”
EuRIC has expressed their support towards the sustainable recycling system of end-of-life-tyres which they define as “well-functioning and mature circular value chain which directly contributes to the recovery of thousands of tonnes of critical raw materials such as rubber, and also steel and textile fibres, saving substantial amounts of energy and water, and preventing greenhouse gas emissions. Together with millions of euros saved in imports of raw materials and generating thousands of jobs”.
Read more about tyre recycling: EuRIC’s brochure on mechanical tyre recycling
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EuRIC Brochure on Mechanical Tyre Recycling highlighting its contribution towards circular economy and climate neutrality
EuRIC Brochure presents key facts about end-of-life (ELT) mechanical tyre recycling, which is a major enabler of circularity and climate mitigation for the entire tyre value chain.
The Brochure describes the current state of play of ELT management with recommendations to overcome key challenges faced by the European mechanical tyre recycling industry be them embedded in legislation, market failures or eco-design. It features key numbers outlining the economic importance of the ELT recycling sector as well as its benefits for the environment and society.
State of the art mechanical tyre recycling entirely supports the European Green Deal and the new Circular Economy Action Plan stressed Poul Steen Rasmussen, President of EuRIC’s Mechanical Tyre recycling (MTR) Branch and Group CEO Genan. The processing of ELT tyres into rubber is not only the most resource-efficient option; it also the most climate-efficient one since for each tonne of ELT recycled -for example as infill for artificial turf pitches- the climate is spared 700 kg of CO2, he added.
Currently, out of the approx. 3 million tonnes (Mt) of tyres reaching end-of-life stage annually in Europe, there are more than 1 Mt of tyres down-cycled annually in energy recovery, while less than 50% (approx. 1.5 Mt) are mechanically recycled into rubber, steel and textile fibers. Increasing material recovery is essential as natural rubber is a critical raw material in Europe[1].
A landfill ban for ELT is far from sufficient to boost tyres circularity. The EU needs to consider further measures to closing the loop of the Circular Economy of tyres, in particular:
- Incentives rewarding ELT recycling benefits and recycled content targets to drive the demand for recycled materials from tyres, especially rubber, be it in new tyres, asphalts, moulded products and construction materials.
- EU-wide end-of-waste criteria for ELT which are essential to alleviate obstacles impacting circular uses of materials derived from ELT recycling into a variety of applications benefiting society, the environment and industrial symbiosis. While national end-of-waste criteria as the recently adopted by Italy[2] are strongly supported, harmonization at EU level is key for a well-functioning of internal market for secondary raw materials.
Sustainable design of tyres to boost their recyclability and minimum thresholds of recycled content to stimulate the demand. Product design requirements shall go hand in hand with a better enforcement at European borders of imported new tyres which must comply with European standards to level the playing and protect the environment.
[1] European Commission (2020). Critical Raw Materials Resilience: Charting a Path towards greater Security and Sustainability
[2] Regolamento recante disciplina della cessazione della qualifica di rifiuto della gomma vulcanizzata derivante da pneumatici fuori uso, ai sensi dell'articolo 184-ter del decreto legislativo 3 aprile 2006, n. 152. (20G00094) (GU Serie Generale n.182 del 21-07-20) -
EuRIC Factsheet - LCA Tyre Recycling Environmental Benefits
LCA study demonstrates positive climate and environmental benefits of the recycling of end-of-life tyres for artificial turf pitches.
Read more about EuRIC’s position by following the link below. -
Press Release - Environmental Benefits - Tyre Recycling - Infill Artificial Turf
Tyres are complex products subject to strict standards to fulfill mobility and safety requirements. Proper treatment of end-of-life tyres (ELTs) is essential to recover valuable materials of which tyres are made, namely rubber, steel and textiles. A new peer-reviewed study, based on Life Cycle Assessment (LCA) meeting ISO 14040 and ISO 14044 standards, made by the Danish FORCE Technology Institute and the German ifeu – Institut für Energie- und Umweltforschung Heidelberg GmbH1 demonstrates that mechanical recycling of ELTs into infill for artificial pitches is, by far, the most sound treatment option in terms of circularity and climate benefits. The LCA study shows that the mechanical recycling of an average of 400,000 tonnes of ELTs processed into infill for artificial turf - when compared with energy recovery - spares the environment 280,000 tonnes of CO2 emissions annually in the EU. To give an order of magnitude, ELT recycling as infill into artificial turfs offsets greenhouse gases emissions (GHS) comparable to the amount of GHS absorbed by 140,000 hectares (approx. 250 million trees) of forest land in the EU2.Tyres are complex products subject to strict standards to fulfill mobility and safety requirements. Proper treatment of end-of-life tyres (ELTs) is essential to recover valuable materials of which tyres are made, namely rubber, steel and textiles. A new peer-reviewed study, based on Life Cycle Assessment (LCA) meeting ISO 14040 and ISO 14044 standards, made by the Danish FORCE Technology Institute and the German ifeu – Institut für Energie- und Umweltforschung Heidelberg GmbH1 demonstrates that mechanical recycling of ELTs into infill for artificial pitches is, by far, the most sound treatment option in terms of circularity and climate benefits. The LCA study shows that the mechanical recycling of an average of 400,000 tonnes of ELTs processed into infill for artificial turf - when compared with energy recovery - spares the environment 280,000 tonnes of CO2 emissions annually in the EU. To give an order of magnitude, ELT recycling as infill into artificial turfs offsets greenhouse gases emissions (GHS) comparable to the amount of GHS absorbed by 140,000 hectares (approx. 250 million trees) of forest land in the EU2.
Continue reading the full press release by clicking on the link below.
1 Life cycle assessment of waste tyre treatments: Material recycling vs. coincineration in cement kilns, Force Technology with contribution by ifeu – Institut für Energie- und Umweltforschung Heidelberg GmbH, for GENAN Holding A/S, May 2020.
2 European Parliament News. Climate change: using EU forests to offset carbon emissions (Eurostat), April, 2018. -
EuRIC Comment on Tyre Ecodesign to Boost Circular Economy
Tyres are becoming more and more sophisticated. Yet, they are still perishable and have to be recycled when reaching end of life stage.
Read more on the subject by downloading the file below.
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EuRIC call for Recycled Plastic Content in Cars
By turning waste into valuable resources and hence saving massive amounts of GHG and energy, plastics recycling is at the core of the circular economy. Automotive plastics’ recyclers have developed during the last decades state-of-art post-treatment technologies to efficiently separate and then recycle plastics from end-of-life vehicles (ELV); recycled plastics that once compounded again in new vehicles, meet similar performance standards as those compounds from virgin polymers
In this substantiated call for recycled content of plastics in new cars, EuRIC outlines the state of play of plastics in the automotive sector and highlights the need for an increase content of recycled plastics thanks to targets to be set in the ELV Directive currently under revision.
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Implementation of Best Practices in Synthetic Turfs
It is a report on ‘Implementation of Best Practices in synthetic turfs to avoid the release of microplastics from rubber granulate into the environment’. The report describes the most conventional best practices that have been implemented in synthetic turfs across Europe and their associated costs, and also highlights the importance of implementing those kind of measures to avoid the emissions of microplastics from rubber granulate into the environment, that could be reduced to negligible limits when those best practices are implemented in synthetic fields.
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Q&A Document on the Presence of PAH in Synthetic Turfs
The document is divided into seven questions that develop on explaining what are PAHs, why are they present in synthetic turfs, and how safe it is to use those turfs regarding the low rate of exposure of PAHs for users, its environmental benefits, and what can be further improved to establish realistic restrictions to the use of ELT for the production of synthetic turfs.
