Export controls, traceability and plant plans address different parts of the same commercial chain. The test is whether processors can secure repeat buyers for qualified recovered materials at prices that support operations.
Europe’s used-tyre debate stretches from export safeguards to new recycling plants. Better tracking could improve visibility, while dependable feedstock agreements could help processors plan production. Neither, by itself, establishes a functioning market for the materials recovered.
The European Commission’s proposed export list, Germany’s latest tyre-flow figures and plans for two French recycling plants illustrate these different challenges. Australia’s reform debate adds a further question: how can policy support demand alongside collection and processing?
The available evidence establishes activity across that chain. It does not yet establish whether those developments are progressing together.
Published sources identify gaps in recorded tyre flows, proposed feedstock arrangements and established applications for recovered materials. What remains missing from this investigation is evidence connecting those developments at plant level.
That means actual throughput, saleable output, qualification results, repeat orders and operating costs. Without those measures, announced capacity and examples of material use provide only part of the commercial picture.
The European Commission published its draft list of non-OECD countries that could receive specified non-hazardous waste on 18 September. Consultation closed on 16 October, ahead of the relevant export restrictions applying from 21 May 2027. The first authorised-country list is expected by the end of 2026.
As previously reported by Tyre News Media, the Tyre Recovery Association has called for mechanical processing before waste tyres are shipped to India. The intervention, reported by Tyre & Rubber Recycling, questions whether the proposed arrangements would adequately protect against unsuitable treatment.
Demonstrating appropriate treatment overseas and retaining recovered material within Europe are separate outcomes.
As previously reported by Tyre News Media, TSA has called for action following Australia’s parliamentary tyre inquiry.
Australian export guidance illustrates the distinction. Whole baled tyres cannot be exported, but licence applications are permitted for specified processed tyres destined for fuel or other uses, alongside retreading and reuse.
Processing before shipment can therefore coexist with material leaving the domestic economy. The European question extends beyond the condition of tyres at departure to their receiving facility, treatment and subsequent use.
WDK’s latest figures record 84,000 tonnes of tyres with unclear destinations in 2025.
That is a gap in the recorded balance. It is not a measured volume of illegal exports or an established equivalent shortage of commercially suitable feedstock for German recyclers.
WDK’s underlying table records 522,000 tonnes available for further use or recovery, including imports and tyres from vehicle recovery. Of that total, 210,000 tonnes went into granules and rubber powder, compared with 78,000 tonnes used by the cement industry.
The figures show the substantial role of mechanical recycling while identifying material whose destination remains unclear. WDK wants systematic recording of quantities and recovery routes.
The commercial test for improved tracking is whether it changes decisions. Can collectors identify additional recoverable tyres? Can processors forecast suitable deliveries more reliably? Can investors distinguish accessible feedstock from an estimated quantity?
Answering those questions requires more than assigning a destination to the statistical gap.
In France, Aliapur and Infiniteria signed an MoU to work towards long-term tyre supply for two planned recycling plants. Shortlisted sites remain under assessment and environmental impact studies continue.
The announcement establishes a framework for negotiating supply. Binding deliveries and operating plants remain separate milestones.
A commercial assessment needs proposed volumes, feedstock specifications, delivery responsibilities and pricing arrangements, alongside permits, financing and commissioning progress. Those details would help establish whether each plant could obtain suitable material consistently and at a workable delivered cost.
Offtake needs the same scrutiny. Processing capacity alone cannot establish how much saleable material a plant will produce, what customers will accept or whether sales will support operating costs.
There is published evidence of recovered tyre materials reaching commercial applications.
In a March 2025 investor statement, Enviro reported that AnVa had received commercial deliveries of its recovered carbon black since 2016 for automotive rubber components.
That supplier account identifies an established application. It does not establish current purchasing volumes, contract terms or the economics of expanding supply.
The recovered carbon black guidelines announced by Michelin and Bridgestone in 2023 identify proposed grades, specifications and quality and performance requirements.
The relevant commercial evidence goes beyond whether a buyer has used recovered carbon black. It is whether a processor can supply material qualified for a defined application, maintain the specification across batches and secure repeat orders at a delivered price compatible with plant economics.
For buyers, that makes material performance and supply consistency central to the investigation, alongside price and environmental benefits.
Rubber granules and powder, recovered carbon black and pyrolysis oil cannot be treated as a single commodity.
Each output needs its own assessment of intended applications, customer requirements, further processing and purchasing commitments. Evidence of demand for recovered carbon black does not establish a market for another plant’s granules or oil.
Reporting should therefore distinguish total material recovered from material sold into a defined application. It should also separate customer interest, qualification trials, signed purchase commitments and completed repeat deliveries.
Those stages provide different levels of evidence about demand.
TSA’s response to Australia’s parliamentary inquiry identifies stronger domestic markets, harmonised rules and consideration of mandatory stewardship among the committee’s recommendations.
These are proposals rather than new requirements. Their relevance to Europe is a question to investigate, particularly whether purchasing arrangements and product approvals can support repeat demand alongside improved collection and processing.
A fuller assessment needs evidence from both ends of an operating transaction: a recycler’s throughput, costs and saleable output, and a buyer’s qualification requirements, accepted volumes and purchasing decisions.
Those measures would help establish whether better tracking and feedstock arrangements are translating into recovered materials that customers can use and processors can sell commercially.
Tags: tyre recycling, used tyres, recovered tyre materials, waste tyre exports, tyre traceability, recovered carbon black, rubber granules, tyre pyrolysis, recycling demand, circular economy
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