ETRMA, EuRIC call for ‘harmonised end-of-waste criteria’ for ELT-based rubber

Brussels – The European Tyre and Rubber Manufacturers’ Association (ETRMA) and the European Recycling Industries’ Confederation (EuRIC) have called on the European Commission to “urgently develop” EU-wide end-of-waste (EoW) criteria for rubber derived from end-of-life tires (ELTs).

In a joint position paper published 9 July, the European bodies warned that the absence of harmonised criteria is “a major and persistent barrier” for the tire recycling industry and its supply chain.

“The lack of harmonisation creates significant difficulties for the tire recycling industry and its supply chain,” the paper said.

The paper noted that the lack of harmonised criteria creates legal and administrative barriers across member states, undermining market confidence and limiting the uptake of recycled materials in manufacturing.

Despite being identified by the European Commission’s joint research centre in 2021 as a top candidate for EoW criteria, ETRMA said “progress has stalled.”

The position paper argued that defining harmonised EU rules would “clarify when ELT-derived rubber is no longer considered waste.”

This will ensure compliance with product legislation, improve quality assurance, and enable circular procurement at scale.

The EU-wide EoW criteria, the paper stated, will “ensure a level playing field for trade across Europe by establishing equal conditions and equivalent opportunities across borders.”

It will also reduce administrative burdens associated with the trade of recycled materials, and secure that materials meet safety and quality criteria.

Many regulations, the paper noted, such as ‘declarations of performance’ for construction products or the REACH restrictions on chemical substances, only apply once the material has ceased being waste.

“Technical conditions for ELT rubber to cease being waste are well defined. What’s missing is legal certainty,” explained Julia Ettinger, secretary general of EuRIC.

EU-wide EoW criteria, she said, are “essential to unlock intra-EU trade, investment, and circular use of recycled rubber.”

Adam McCarthy, secretary general of ETRMA, emphasised that standardised EoW criteria “will boost demand for high-quality secondary raw materials and reduce dependence on virgin resources.”

“These standards will support the uptake of recycled inputs in tire manufacturing, thus supporting the objectives of the ecodesign for sustainable products regulation (ESPR),” he added.

The two organisations said they were ready to support the Commission in defining “workable, enforceable EoW rules” to safeguard valuable resources and ensure the development of “a well-functioning internal market for recycled materials in the EU.”

The paper concluded that ELT-derived material is an “ideal candidate for EU-wide end-of-waste criteria,” with no conflicting interests within the tire production and recycling sectors that would delay adoption.

Read full joint letter here.