
The UK appears to have a waste-tyre contradiction. The Tyre Recovery Association says more than 150,000 tonnes a year of licensed recycling and remanufacturing capacity is idle, while around 1,000 tonnes of whole waste tyres leave the country each day. The figures are striking, but they do not yet explain why domestic capacity is underused or whether regulation alone can change the economics.
Tyre Recovery Association’s September Briefing Day has put a sharper number on an issue the UK recovery sector has raised for several years. According to the TRA, more than 150,000 tonnes a year of domestic recycling and remanufacturing capacity is unused, while around 1,000 tonnes of whole waste tyres are exported each day.
Annualised, the export figure would represent roughly 365,000 tonnes. Even on the TRA’s own numbers, therefore, bringing every tonne of claimed idle domestic capacity into use would not remove the export flow. The two figures establish a substantial mismatch, but not a simple one-for-one solution.
The 150,000-tonne estimate is not new. The TRA was citing at least that much idle capacity in January 2024, when it put annual UK end-of-life tyre exports at 250,000 to 300,000 tonnes. By March 2025 it was reporting exports above 350,000 tonnes while retaining broadly the same estimate for unused capacity.
That persistence strengthens the case for investigating the economics, but it also exposes the evidence still missing. TNM has not identified a current government dataset independently establishing how the 150,000 tonnes is distributed between plants, processes and regions, or how much is practically available at current commercial conditions.
Licensed capacity is not automatically the same as usable capacity. A plant may have regulatory headroom without having the right feedstock mix, customers for its outputs or economics that allow it to compete for material. The aggregate figure cannot tell the industry which of those factors is constraining utilisation.
This distinction matters because much of the public debate has centred on T8. TNM reported on 16 September that the timetable for withdrawing the exemption remains unset. Defra told Parliament on 7 September that drafting was being finalised and would be laid when parliamentary time allows.
T8 itself permits relatively small-scale mechanical treatment without a full environmental permit, with current limits of 40 tonnes over seven days for tyres other than truck tyres and 60 tonnes for truck tyres. The exemption can influence how tyres are collected, treated and moved through the market, but it is not the same thing as the licensed industrial capacity the TRA says is sitting idle.
Removing T8 may alter compliance costs and material flows. The published evidence does not, however, establish that withdrawal alone would redirect 150,000 tonnes into larger UK processors.
The export picture also needs qualification.
As of 3 August, the Environment Agency had received details of 10,822 waste tyre shipments under its enhanced checks. Of the 5,819 shipments that had reached the relevant evidence deadline, 3,837 were recorded as fully or partially compliant and 1,091 as non-compliant. The Agency also cautioned that substantial quantities of evidence were still awaiting assessment.
Separately, the Government told Parliament that the enhanced checks conducted between October 2025 and July 2026 had not identified evidence of widespread exports to batch-pyrolysis facilities. The EA subsequently moved towards a more targeted, risk-based approach. It had served 50 prohibition notices on waste tyre exporters from England and restricted exports to 31 destination facilities where satisfactory return-tracking evidence had not been provided.
Those findings do not remove concerns about individual shipments or destination standards. They do limit how far the economics of UK recycling can currently be explained by a narrative of widespread diversion into illegal overseas pyrolysis.
Digital Waste Tracking will improve another part of the data picture from 1 October, when licensed and permitted waste-receiving sites in England and Wales must begin reporting receipts through the new system. But phase one does not include operators working under waste exemptions, while Article 18 or green-list waste exports are planned for a future phase.
For waste tyres, that means the October change should not be confused with immediate end-to-end digital export tracking. The EA’s interim tyre-export compliance arrangements are intended to remain in place while wider digital controls are developed.
One revealing part of the TRA’s reform case is that it extends beyond export controls. Proposals presented at the Briefing Day included public procurement measures intended to increase demand for retreaded tyres and rubberised asphalt. Delegates were told that a 10% rubberised-asphalt target for public highway contracts could absorb currently unused crumb-rubber capacity.
That remains an industry proposition rather than proof of what is suppressing utilisation. But it points towards a second side of the equation. Domestic processors need both feedstock and viable markets for what they produce.
To explain the 150,000-tonne figure properly, the industry needs more granular evidence: actual plant utilisation, the price available to collectors supplying export markets compared with domestic processors, domestic gate fees, transport distances, processing costs and demand for outputs including crumb rubber, retreads, recovered materials and fuels.
Without those numbers, the UK has evidence of a capacity-and-export mismatch but not yet a complete diagnosis of its cause.
The TRA’s case is that domestic processors are losing material that could be treated in Britain. What remains unresolved is how much of that outcome is driven by regulation, export values, domestic processing economics or insufficient demand for recycled outputs.
That is the more important question now. T8 reform, tighter export controls and better tracking can change the rules around the market. Whether they are enough to fill existing UK plants will depend on the economics inside it.
Tags: UK tyre recycling, waste tyre exports, end-of-life tyres, T8 exemption, Digital Waste Tracking, tyre recovery, circular economy, retread tyres, rubberised asphalt, Environment Agency
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