Scottish Government

COUNCIL DIRECTIVE 1999/31/EC ON THE LANDFILL OF WASTE

1. STRUCTURE OF THE INDUSTRY

2. In considering how a statutory producer responsibility scheme might be framed, it is essential to look at the structure of the industry, its players and the various relationships between them. The diagrammatic below shows the routes tyres typically take between their first use and ultimate final reuse, recovery or export.

3. 

4. As illustrated, tyres take a number of routes between manufacture and first use. In essence, there are two main approaches to statutory producer responsibility:

• a shared approach, as with the packaging regulations, encompassing all actors in the supply chain; and
• a targeted approach.

1. The tyre supply chain is a complex one, which includes manufacturers and importers of new tyres, manufacturers and importers of new vehicles, importers of retreaded tyres and used casings and new tyre retailers and wholesalers. If UK arisings of second generation tyres are also considered, then the above list expands to include manufacturers of retreaded tyres and part-worn retailers. It is necessary to consider each of these sectors in turn.

2. UK new tyre manufacturers

3. A small number of household name companies currently manufacture new tyres in the UK namely Cooper-Avon, Dunlop, Goodyear, Michelin and Pirelli. None of these are ultimately UK owned.

4. UK new tyre importers

5. The 1999 UTWG background report indicated that there were around 40 companies importing new tyres into the UK. These range from foreign manufacturer affiliates to wholesalers and retailers importing across the brand range of overseas manufacturers.

6. UK retreaded tyre importers

7. Imports of retreaded tyres are limited at around 3,000 tonnes, around 1% of UK replacement tyre sales. It is likely, therefore, that relatively few companies import retreaded tyres; some may also import new tyres.

8. UK used casing importers

9. Used casings are generally used in retread manufacture or for the part-worn market. There is no definitive list of used casing importers but the number seems likely to be less than the 40 or so companies manufacturing retreaded tyres in the UK. Additionally, there are probably only a handful of companies specialising in the import of used casings for the part worn market.

10. UK vehicle manufacturers

11. The Society of Motor Manufacturers and Traders UK Motor Industry Facts indicates that there are 40 or so UK manufacturers of cars, vans, trucks and buses in the UK.

12. UK vehicle importers

13. In 1999 there were new car registrations from around 30 overseas car manufacturers (over 70 if imports from ostensibly the same manufacturer, but operating in a number of countries, are counted separately). On the commercial vehicle side, there were imports from some 35 overseas manufacturers (over 70 if counting related manufacturers, but from different countries). Of course, the specific entity of interest is not the overseas manufacturer itself but the importing agent, although in many cases the two will be closely related. Currently, the number of importing agents is unknown.

14. Tyre Retailers/Wholesalers

15. It is difficult to say how many tyre retail outlets exist. Both tyre and vehicle manufacturers ultimately own around 70% of the 5,500 or so high-street fast-fit tyre outlets. There are, however, many thousands of smaller operators also selling tyres.
16. The National Tyre Distributors Association Tyre Wholesalers Group has around 30 members and includes all the major tyre wholesalers operating in the UK. It is likely that a number of smaller wholesalers also operate outside membership of this particular Group.

17. UK Retreaders

18. As mentioned in paragraph 20, about 40 companies manufacture retreaded tyres in the UK, with about 10 of these retreading passenger car tyres and 30 retreading truck tyres; a few companies do both.

19. Part-Worn Retailers

20. It is extremely difficult to accurately assess the number of part-worn tyre retailers. However, there are some 2000 authorised vehicle dismantlers, and a significant proportion of these seek to recover value from tyres removed from end of life vehicles. The numbers of dismantlers, and therefore the numbers that continue to deal with tyres, may well be affected by the End of Life Vehicle Directive. This will require those dismantlers who continue to handle elvs to become authorised treatment facilities and introduces higher standards for the dismantling of vehicles. A number of other smaller operators, such as some individual garages, also retail part-worn tyres.

21. Sector Summary

    	Approximate numbers
    Tyre manufacturers	5
    Tyre importers	40
    Retread importers	< 50
    Used casing importers	< 50
    Vehicle manufacturers	40+
    Vehicle importers	not known
    Tyre retailers/wholesalers	20,000+
    UK retreaders	40
    Part-worn retailers	potentially 2000+

    Used tyre reuse and recovery infrastructure

22. The UK's used tyre reuse and recovery infrastructure, while diverse, is relatively small. It includes retreaders and part-worn retailers as well as those reusing tyres for other purposes (eg for landfill engineering), exporters of used casings, materials recovery companies (eg for sports and safety surfaces) and energy recovery companies (cement kilns). The 1999 UTWG background report provides additional detail.

23. Q1. Views and further information are invited on the structure of the industry.