Associazione Italiana Ricostruttori Pneumatici
AIRP
AIRP è un'associazione indipendente che rappresenta sul piano unitario, nazionale ed internazionale, la categoria dei Ricostruttori italiani di pneumatici.
ID: 128256439890-87
Lobbying Activity
Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)
1 May 2025
AIRP - Associazione Italiana Ricostruttori Pneumatici (Italian Tyre Retreaders Association) represents the independent Italian tyre retreading industry. Our association reports that already at the time of publication of Regulation (EU) 2023/1115, a strong concern had emerged in all companies in the retreading sector regarding the possible obligation to issue a due diligence statement relating to the carcasses to be retreaded. In the opinion of our association, in fact, it is virtually impossible for a retreader to recover the data of a used tyre that is delivered to him for retreading, furthermore this would also be superfluous, since in almost all cases it is a tyre that has evidently already been introduced on the European Union market. To our satisfaction, we learned from reading the FAQs Version 4.0 that the Commission intends to exclude casings from the due diligence statement requirement, as point 2.8.1 states that In a draft Delegated Act put forward by the Commission, it is proposed that used tyre casings and carcasses (generally used for retreading tyres) are out of the scope of the Regulation, whereas retreaded tyres are in the scope only for the new natural rubber parts, such as the tread, applied to the carcasses and casings. However, reading the public draft of the Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation) we are concerned that the proposed wording in point (m) is not sufficiently clear with respect to the purpose of excluding carcasses and casings from the scope of the Regulation. Therefore, in order to avoid any possible ambiguity of interpretation, AIRP requests that in the wording of the amendment referred to in point (m) the carcasses and casings be explicitly and clearly mentioned (together with used tyres) as goods that are excluded from the list of relevant commodities and relevant products to which Regulation (EU) 2023/1115 applies.
Read full responseResponse to Sustainable Products Initiative
30 Oct 2020
Founded in 1963, AIRP represents the tyre retreading industry in Italy. Among its objectives, it aims to foster and follow activities in defence of industry and members, to sponsor activities supporting and increasing the importance of the tyre retreading industry socially, technically and economically, to defend and represent legitimate business interests with authorities, boards, public and private institutions, national and international associations.
Tyre retreading offers several economic and environmental benefits: it saves around 70% on oil and raw materials such as natural and synthetic rubber, carbon black, textile fibers, steel and copper; besides, it reduces waste tyre disposal significantly, while it lowers CO2 emissions up to 30%.
In just over ten years, the volume of sales of retreaded tyres in Italy has halved, with the closure of numerous companies. This downfall, which found a dam only a couple of years ago thanks to the high anti-dumping duties by the European Union against Chinese tyres for trucks and buses, has had multiple implications. At first, the immediate effect was to put retreaded tyres out of the market, since their cost advantage over the new premium tyre was canceled out by the low-cost products from Asia. Secondly, the main structures, ie quality tyre casings, has been lacking on the retreading market. Finally, many new tyre manufacturers have reacted to the invasion of low cost products by chasing new competitors in the field of price, putting at risk the very conditions of a system based on the recovery and reuse of the product.
This is why it is important to encourage a market competition that is also linked to environmental sustainability: with a different incentive system, attentive to environmental impacts and in particular to the circular economy, these repercussions would have been avoided. This is why it is also important for the future to implement policies that can nip in the bud commercial strategies based on throwaways.
Just as the European legislation has come to express precise indications that prohibit the so-called planned obsolescence, with the same logic it would be right to put a preventive barrier against everything that is designed in order to offer low prices and more frequent replacements.
In this regard, our association is now watching with great interest at the Sustainable Product Initiative” of the European Commission. As we read in the “COM(2020) 98 - A new Circular Economy Action Plan for a cleaner and more competitive Europe” document: ““The core of this legislative initiative will be to widen the Ecodesign Directive beyond energy-related products so as to make the Ecodesign framework applicable to the broadest possible range of products and make it deliver on circularity- […] Priority will be given to addressing product groups identified in the context of the value chains featuring in this Action Plan, such as electronics, ICT and textiles but also furniture and high impact intermediary products such as steel, cement and chemicals. Further product groups will be identified based on their environmental impact and circularity potential.”
As for the circularity potential, the tyre retreading industry has been a perfect example of circularity for 80 years.
For these reasons, AIRP hopes that tyres can be included in the scope of the European directive on eco-design, so as to stimulate manufacturers to put on the market only tyres that are effectively retreadable, and to enhance and promote the role of retreading as an ecological practice.
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