Bundesverband Reifenhandel und Vulkaniseur-Handwerk e.V.
BRV
Der Bundesverband Reifenhandel und Vulkaniseur-Handwerk e.V.
ID: 156572939166-11
Lobbying Activity
Response to Sustainable Products Initiative
9 Oct 2020
The BRV Bundesverband Reifenhandel und Vulkaniseur-Handwerk e.V. (German Tyre Retail and Vulcanisation Trade Association) represents the interests of German retreaders and tire disposal companies in addition to the tire retail branch.
We welcome the fact that the scope of application of the Ecodesign Directive is to be extended within the framework of the "European Green Deal". The existing narrow framework of energy related products must indeed be extended to meet the Commission's Circular Economy Action Plan.
The extension of the scope should also include the tire product segment. With reference to the Commission's Circular Economy Action Plan, tires are a predestined product that falls within the classic Circular Economy.
In Germany, in 2019 approx. 571,000 tons of worn tires* are currently produced annually, and the trend is rising. The legal situation with regard to the recycling of worn tires is as follows: The landfilling with end of life tires has been prohibited in the EU states since 2003, so they are currently being primarily recycled thermally and materially. Tire Recycling is becoming increasingly difficult due to technological developments, e.g. the degrease use in the area of cement production as solid fuel, but also due to the declining acceptance of recycled products consisting of tire recycling materials.
At this point, the principle of waste avoidance by “re-use” before recycling should be applied. End of life tires could be reprocessed by “retreading” and re-enter a second or third life cycle, thus putting waste prevention in the foreground. Within the scope of retreading, only the worn tread of a tire is replaced, the complete remaining casing is re-used again. The retreading process is therefore a perfect example for improving the Circular Economy balance for tires.
The EY study "The socio-economic impact of truck tire retreading in Europe"** (as of October 2016) shows that a retreaded tire saves 70% of the depletion of natural resources such as oil and steel, 29% land use for the cultivation of rubber trees, 24% CO2 savings, 21% of air pollution and 19% of water consumption compared to a low end non-renewable new tire.
As BRV we therefore ask the European Commission to include tires in the scope of the Ecodesign Directive. Furthermore, the tire manufacturers should be encouraged to place retreadable tires on the market. Retreaded tires should be promoted as an environmental product and should be considered as a compensation option in emissions trading in regard to the CO2 savings from the use of retreaded tires.
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