Introduction: I am Chairperson of ATRS which represents Independent Tyre Retailers. I would like to thank the Chairperson for the invitation to the

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Jasmine Barnett
6 years ago
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1 Introduction: I am Chairperson of ATRS which represents Independent Tyre Retailers. I would like to thank the Chairperson for the invitation to the meeting of Joint Committee on Communications, Climate Action and Environment, Re; Scrutiny of S.1 No 400 of 2017 Waste Management Regulations I am joined by Kevin Farrell and Brendan Byrne, we are all former ITIA Council members. We established ATRS along with Daren Darker, Sean Mc Cullough and Cormac Farrell to give retailers a voice and a platform to build and promote best practise among compliant tyre operators. We have engaged with DCCAE, Tyre Working Group, Road Safety Authority and Repak ELT to date. Currently we have a mailing list of 500 retailers who receive our newsletters and our web site is We are tyre operators with outlets across the Country with many years in business. We strive to have consistently high standards for safety and service. We all have ATA Accredited tyre fitters. The founding Retailers who formed ATRS felt that as both other tyre representative organisations represented more than one sector, each sector could not be effectively represented and set up ATRS as a Retail only organisation to fully represent the Retail sector. Retailers have long been looking for regulation in our industry as the compliant operators must battle daily against the black economy traders who have popped up in our industry without any requirement for them to be trained or competent to fit and repair the most important and often overlooked safety component of a vehicle. This along with the dumping of tyres nationwide means that Regulation in our industry has long been needed and is something Retailers have been calling for. We see the introduction of the Waste Management (Tyres and Waste Tyres) Regulations 2017 as a good foundation for the establishment of new standards for our industry which we would like to see established as a trade with enforceable standards for fitting, repairs and the safety of the products going onto the national fleet. We welcome that some tyre categories have not had a vemc imposed on them just yet and we will continue to engage in the further examination of how best to manage these tyres. We are sure that an agreement can be reached with a fit for purpose outcome through the Tyre Working Groups next meeting. Some key industry facts

2 A culture of compliance is building The number of tyre operators in Ireland is estimated at just over 3,000. There is a culture of compliance building in the Tyre industry with over 2000 members now joined with the Repak ELT tyre scheme in the first two weeks of the new regulations. As the first piece of regulation to specifically deal with the tyre industry the swift uptake of compliance shows how needed and welcomed the Regulations are to tyre operators. The complaint operators now need to be supported with targeted enforcement to deal with the non-compliant free riders on the periphery. Tyre disposal is not free in Northern Ireland As was the case in here before the 1 st of October there is a cost connected to the collection and disposal of tyres and consumers are being charged a disposal fee when getting their tyres changed. Northern tyre suppliers have already joined the scheme. Waste Management (Tyres and Waste Tyres) Regulations 2017 What is working well The stipulation that all operators must join the compliance scheme has been a catalyst to have a new culture of compliance building in our industry and the fact that it will be public knowledge who is signed up to the scheme and who has remained non-compliant, should make identifying free riders in the system very simple. What needs more work Enforcement is weak Enforcement is something that the entire industry has always agree on yet it only has a brief paragraph in the Regulations. This urgently needs to be expanded. The need for enforcement to weed out free riders is paramount to the proper establishment and operation of the scheme. There simply must be consequences to non-compliance. Fixed penalty notices had been promised to come in with the new regulations and from our meetings with Waste enforcement officers and fellow tyre industry colleagues, they are badly needed to make enforcement of the 2017 Regulations effective. There has been a commitment to multi agency operations on enforcement and this needs to be structured and have a feedback mechanism. Enforcement checks must start with non-compliant operators and visible enforcement operations would be the best deterrent to illegal noncomplaint activities. Producer Definition The definition of Producer in the Regulation has resulted in some of the main manufacturers who sell directly into Ireland, not joining the scheme thus placing the onus of reporting and paying the vemc, back onto the Retailer. This is completely unacceptable and needs to be

3 rectified. Retailers do not want to be Producers especially not for tyres from suppliers who have been Producers under previous Regulations, and who are Producers in the other tyre schemes throughout Europe. Data reconciliation Retailer data will under the new Regulations be checked for accuracy by the scheme. The PRL does not receive or adjudicate the data submissions received from Producers, which go straight to a third party black box. Data from all sectors should be scrutinised and cross checked in the same manner and the Regulations need to provide for this. ATRS have always stated our objections to a second black box as it does not fulfil any additional function to the black box that was operated for all sectors in phase one of the tyre scheme. Dual Reporting The onus, especially on small owner operator Retailers to join Repak ELT and the Producer Register is unnecessary. As smaller operators who spend most of our time fitting tyres the burden of dual reporting is already being felt. In registering as a Producer, my reporting to the PRL was zero for the previous 12 months. My outlet is fairly typical of the independent tyre operators who will make up the largest group of members of the tyre scheme. I have only had to join the PRL as some of the main manufacturers have not joined the scheme. For us tyre Retailers the bulk of our reporting will be to the scheme. Instead of an opt in from the PRL, it would serve the majority of the scheme members better to have an opt in from Repak ELT to the PRL. Part Worn tyres in ATFS Previous drafts of the Regulations placed restrictions on ATF s prohibiting the resell of a tyre which has been discarded. The final Regulations have left this area too vague and this needs to be addressed. Recommendations ATRS recommend the following actions to ensure the successful implementation of the new Regulations The second black box does not fulfil any unique role and only seems to serve the requests of the wholesale sector. In the motor industry all sales figures are published on a monthly basis and market share is published. While we are not calling for industry to publish tyre sales, at a basic minimum we must insist that data from all sectors is held to the same level of traceability. Retailers should be able to do all reporting through Repak ELT. An opt in to the PRL for any Producer tyres would reduce the administrative burden on Retailers and make it easier to trace all their data submissions. It makes sense that the reporting takes place with the option to opt in from where the bulk of their submissions are made. Targeted and visible enforcement has been promised. This needs to be delivered in the first quarter of the schemes operation to build confidence

4 among the compliant tyre operators and further boost the growing culture of compliance. Fixed penalty notices must be brought in to support the new Regulations. Multi agency operations should be enacted and published to encourage the free riders Cross border co-operation with the DOE and Customs would help to allay concerns in the industry and ensure that both sides of the border are fully aware of the trading channels and better able to ensure that cross border trade is managed so as not to pose a risk to the scheme. Tyre suppliers from Northern Ireland and the EU have already joined the scheme and this should be highlighted to the authorities in these jurisdictions as well as to all non - domestic suppliers as a valuable service to their customers. Part worn tyres pose both a safety and environmental risk. Some are reused from crashed cars without any assessment for internal damage. This means they are a serious safety lottery. Tyres are your only contact with the road and need to be in good condition to keep you safe. Part worn tyres shipped in from Europe do not follow established sales chains which could leave them open to under and non-reporting. Containers of part worn tyres could have up to 30% of unusable tyres in a consignment. The unusable tyres come straight onto the waste stream in Ireland and the ones that do get fitted to vehicles come onto the waste stream 3 times quicker than new tyres. They also will have poorer performance due to their wear and condition resulting in higher fuel consumption compared to fitting new tyres. Therefor part worn tyres place a heavy burden on environment and should be subject to a vemc that reflects this imbalance. The scheduled 6 month review of the tyre scheme operation needs to have some measurable parameters added to its scope and a date should be set for the review to take place to make sure it is timely and to give all parties time to prepare. ATRS work with all stakeholders in the tyre industry and will continue to engage with the local authority enforcement officers, the EPA, WERLA, the Road Safety Authority and the DCCAE to make sure that in carrying out our business activities we continue to protect the environment. The new Regulations for tyres are most welcomed by ATRS and we will do all we can to ensure they are implemented successfully. With robust enforcement the Regulations could be a positive for all compliant operators and could be a starting point for other standards to be introduced in our industry. THOM FOX

5 Chairperson ATRS

TYRES AND WASTE TYRES Questions and Answers September 2017

TYRES AND WASTE TYRES Questions and Answers September 2017 What s the Minister introducing? A Producer Responsibility Initiative (PRI) review report on waste tyres, published in November 2013, contained