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Summary
of responses to DTI discussion paper of March 2002 on a possible
producer responsibility model for used tyres
On 27 March 2002, DTI issued a discussion paper (URN: 02/1104)
setting out a possible statutory producer model for used tyres
in light of the requirements of Directive 1999/31/EC on the landfill
of waste. This Directive bans the disposal of whole tyres to landfill
from July 2003 and shredded tyres from July 2006. The paper also
invited views on ways of strengthening the present voluntary approach
to the recovery of used tyres. This approach, the preferred option
of both the tyre industry and the Government, has historically
yielded a used tyre recovery rate of around 70%. Comments were
sought from interested parties.
48 responses
were received. The views expressed have been summarised in the
attached document (
71KB ), assembled in broad sector and subject related areas; the
summary has not been ordered by the list of questions raised in
the consultation paper since the majority of respondents did not
follow this form.
There was a widespread view that a statutory scheme would need
to be applied to the disposal of used tyres, although no clear
view on the form such a scheme should take. Both the tyre industry,
through their joint tyre trade association industry response and
the motor industry, through the Society of Motor Manufacturers
and Traders, advocated alternative approaches to that set out
in the paper. However, the majority of respondents supported the
discussion paper's 'single point' producer responsibility approach,
the concept of which was also accepted by the tyre industry in
their response.
In terms of the structure of a statutory producer responsibility
scheme, there was some concern that the model set out in the paper
was unduly complex. There was also concern about the application
of minimum obligation thresholds, with views expressed that no,
or only very low, thresholds should be applied. A number of respondents
considered that obligations should apply to all used tyres, rather
than the 95% suggested in the discussion paper.
The fly-tipping of tyres was widely recognised as an issue that
needed to be tackled, and was a particular concern of local authorities.
The discussion paper invited views on the membership of the Used
Tyre Working Group. A number of responses indicated that membership
of the Group should be widened. One response suggested that a
smaller group, with an executive focus, should be established
aside from the UTWG to progress producer responsibility matters.
All the views expressed are being taken into account by the Government
and the devolved administrations as part of their consideration
of providing an effective framework for the re-use, recycling
and recovery of used tyres so that the UK is well placed to meet
the 2006 tyre landfill ban. The Government intends to set out
its views on next steps by the end of this year.
Copies of individual responses to the consultation paper can be
seen by appointment only at the DTI Library (Tel: 020 7215 5006).
Contact:
Paul Hallett
Sustainable Development
151 Buckingham Palace Road
London
SW1W 9SS
Tel: 020 7215 1860
Email: paul.hallett@dti.gsi.gov.uk
November 2002
Responses to DTI used tyre discussion paper
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Automobile
Association
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Bandvulc
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Biffa
Waste Services
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Biffpack
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British
Cement Association
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British
Metals Recycling Association
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British
Rubber Manufacturers’ Association (joint response)
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British
Vehicle Salvage Federation
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Bush
Tyres
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C.A.T.
III Co.
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Carbon
Processing
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Charles
Trent
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Cheshire
Fire Service
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Coalite
Tyre Services
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Derek
Campbell Exhaust & Tyre Centre
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East
Ayrshire Council
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Environment
Agency
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European
Metals Recycling
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Fife
Council
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Freight
Transport Association
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Imported
Tyre Manufacturers’ Association (joint response)
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J
Frewen-Lord
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J
Li
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Lafarge
Cement
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Local
Authority Recycling Advisory Committee
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Local
Government Association
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Motor
Vehicle Dismantlers’ Association of Great Britain
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National
Association of Local Councils
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National
Tyre Distributors Association (joint response)
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New
Forest District Council
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North
Eastern Tyre & Exhausts
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North
West Regional Assembly
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Northamptonshire
County Council
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Retread
Manufacturers Association (joint & individual response)
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Ribble
Valley Borough Council
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RMC
Group Services
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Road
Haulage Association
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Sapphire
Energy Recovery
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Society
of Motor Manufacturers and Traders
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South
Oxfordshire District Council
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Stapletons
Tyres
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Suffolk
County Council
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Tyron
Remoulds
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Valpak
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Waste
Tyre Solutions
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Wastepack
UK
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Watford
Borough Council
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West
Sussex County Council
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WS
Atkins Environment
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