Environment Agency announces enhanced verification for waste tyre exports to India

The Environment Agency (EA) will implement enhanced verification checks for all waste pneumatic tyre exports to India from 1 October 2025, following an internal review that identified significant compliance gaps in the sector.

The measures will require all exporters of waste pneumatic tyres to India to demonstrate environmentally sound management throughout the shipment period, using powers under Articles 49 and 50 of the UK Waste Shipment Regulations and the Transfrontier Shipment of Waste Regulations 2007. Shipments lacking adequate evidence will be prohibited.

In addition to enhanced checks, the EA says it will implement improved staff training, better horizon scanning for international legislative changes, and strengthened partnerships with Indian environmental authorities to address regulatory gaps identified in the review.

The UK exports between 210,465 and 432,566 tonnes of waste rubber annually, with 89 per cent destined for India according to customs data analysed by the EA, estimated to be around 50 million waste tyres annually.

"We believe now that it is highly likely that a proportion of UK waste pneumatic tyres are being diverted for illegal pyrolysis on arrival into India," the Environment Agency stated in its internal review published on 31 July 2025.

India banned imports of waste tyres for pyrolysis in July 2022, but despite this exports have increased. The EA admits it was unaware of this ban for six months after it came into force, highlighting systemic regulatory failures.

The agency committed to reviewing this policy in April following the threat of legal action by campaign group Fighting Dirty and the release of BBC's File on 4 'Tyre Scandal'.

A BBC investigation reports that there are up to 2,000 pyrolysis plants in India, around half of which are unlicensed and therefore illegal, despite the country prohibiting such imports for pyrolysis operations since July 2022.

A significant proportion of the UK’s waste tyres were being systematically diverted from their declared and legitimate recycling destinations in India. This industry operates with little to no environmental controls, causing severe local air and water pollution, creating significant public health risks for vulnerable communities, and undermining India's own environmental regulations.

T8 exemption concerns and removal

The review confirms that the UK's regulatory system facilitated large-scale international trade through the T8 waste exemption, which created a low-cost entry point for operators.

The EA's review identified 1,014 T8 exemptions registered in England as of April 2025, with many operators allegedly exceeding the 40-tonne weekly limit for car tyres. These allow mechanical treatment of waste tyres without full environmental permits.

Baling and exporting whole tyres proved far cheaper than legitimate domestic recycling, exacerbated by weak international shipment controls under the Article 18 Green List system.

The UK Government reaffirmed its commitment to removing the T8 exemption in July 2025, and will strengthen regulatory control by introducing operator competence standards, management systems and mandatory waste reporting.

The EA supports the removal of the T8 exemption and says it is helping businesses prepare by publishing standard rules permits for tyre storage and treatment. These offer a quicker, more cost-effective transition for current T8 operators compared to bespoke permits.

The changes aim to address intelligence that completed Annex VII forms are being falsified, with industry-placed tracking devices revealing tyres failed to reach intended destinations in several documented cases.

Economic challenges facing domestic recycling

Data from a key industry body, the Tyre Recovery Association (TRA), reveals the cost issues relating to the management of waste tyres. The TRA has warned that the UK possesses at least 150,000 tonnes of idle domestic shredding capacity, which cannot be brought online because it is economically uncompetitive against the cheap export route.

The capital investment required for machinery to bale whole tyres for export is minimal, estimated at less than £50,000. In contrast, the industrial shredders and granulators required for legitimate domestic recycling and the production of high-value secondary materials can cost upwards of £2.5 million.

Peter Taylor OBE, Secretary General of the Tyre Recovery Association said: “This is a true step forward after several years of inaction. It includes welcome initiatives on tracing and tracking UK export of waste tyres, the TRA will work with DEFRA and EA to deliver on these.

“It is important, however, that the policy creators and enforcers [DEFRA and the EA] recognise this is just a staging post on the road to the full reforms needed. We will continue to work with the Government to achieve a zero-waste circular economy and sustain the UK’s capability to process end of life tyres.”

The TRA will shortly publish 'The Road to Reform', a recommendation paper outlining necessary actions to deliver the steps recognised in the Environment Agency's review. This includes strengthening the Annex VII process for enhanced verification, increasing responsibility on shipping lines carrying waste exports, and introducing geo-tagging with active EA management of paperwork processes.