ETRMA Feedback to the Inception Impact Assessment of the Revision of the End-Of-Life Vehicles Directive

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ETRMA Feedback to the inception impact assessment of the revision of the End-of-Life vehicles directive

Brussels, 17th November 2020

The European Tyre & Rubber Manufacturers’ Association (ETRMA) and its members count around 4.300 companies in the EU, employing directly 360.000 people. We have strong presence in the EU and candidate countries with 93 tyre-producing plants and 17 R&D centres. EU production is estimated in 5.1 million tons of Tyres and 2.3 million tons of General rubber goods.

Tyres are essential to the functioning of multiple elements within the mobility system – they have an important role in road safety, they can contribute to CO2 reduction from transport as well as to the optimisation of other performances (e.g. traffic noise), and through more recent technological developments around tyre’s digitalisation they can enable predictive maintenance and reduce traffic congestion, amongst other benefits.

For General rubber goods, the automotive sector accounts for 65% of the production including, wiper blades, seals, air and radiator hoses and seatbelts as their main components. Rubber is resistant to several chemicals used in a car and can withstand the heat and cold. Rubber is also used to make gaskets used in cars, which help create a seal so there is no leak when fluids are flowing through junction areas in a pipe or a hose.

The current ELV directive considers the vehicle frame. The scope rightly does not include tyres. The management of end of life tyres –once removed from the ELVs – is carried out through national EPR schemes since late 90’s. This approach has been successful so far in collecting and recycling tyres; two-thirds of end of life tyres arising under EPR regime. There are 23 European Producers Responsibility Schemes in Europe and the collection and treatment rate of Tyres have reached up to 92% on 20181. The future revision of the ELV directive shall avoid a change in the scope that hampers and affects the current End-of-Life Tyres, ELT, collection scheme and successful value chain.

We signal the need to integrate the ELV directive into the targets and goals of the EU Green Deal and the Circular Economy Actin Plan. In this sense, requirements to include recycled material in the automotive will be investigated in the revision ELV directive. We endorse the principle and endeavours towards recyclability/up-cyclability. However, when it comes to minimum recycled content in tyre production, technologies would still need substantial development and maturity to meet not only demands of the circular economy, but also essential technical performances of tyres.

The same applies for general rubber goods. The type of rubber used in each good adapts to the final application. Its function is what defines whether a recycling solution can be used. For instance, it is possible to use micronized rubber powder2 to substitute a percentage of butyl rubber and vulcanized rubber in some

1 Source: ETRMA 2018 2 MRP is typically made from vulcanized elastomeric material, most often from end-of-life tire material, but can also be produced from post-industrial nitrile rubber, ethylene propylene diene monomer (EPDM), butyl and natural rubber compounds.

ETRMA Aisbl European Tyre and Rubber Manufacturers’ Association www.etrma.org Avenue des Arts 2 Box 12 Tel. +32 2 218 49 40 BE-1210 Brussels - Belgium Transparency Register N° 6025320863-10

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applications. However, this is not a practice that can be extended to every rubber good for every performance. Therefore, the establishment of a recycled content for GRG goods is still premature and not possible as a general rule.

The ELV directive revision shall also address to the new trends in automotive, to mention the increase in electric vehicles and need to address digital data treatment. ETRMA is ready to contribute and help shape the new era of ELV. We offer our support and contribution in the coming stakeholders’ consultation and public consultations.

European Tyre and Rubber Manufacturers’ Association members (www.etrma.org). ETRMA represent 93 tyre manufacturing plants spread across EU28, Turkey and other candidate countries employing some 200.000 direct jobs in the tyre sector. ETRMA, represents more than 6.000 companies in EU28, employing 360.000 individuals and supports another 800.000 jobs in related sectors. The product range of its members is extensive from tyres to pharmaceutical, baby care, construction and automotive rubber goods and many more applications. ETRMA members’ turnover in 2016 is approximately € 73 billion, of which up to 5% continues to be invested in R&D, annually. ETRMA’s membership include the following tyre manufacturers: APOLLO VREDESTEIN, BRIDGESTONE EUROPE, BRISA, COOPER TYRES, CONTINENTAL, GOODYEAR DUNLOP TYRES EUROPE, HANKOOK, MARANGONI, MICHELIN, NOKIAN TYRES, PIRELLI, PROMETEON, SUMITOMO RUBBER INDUSTRIES AND TRELLEBORG WHEEL SYSTEMS. Furthermore, members include Associations in the following countries: Belgium, Finland, France, Germany, Hungary, Italy, the Netherlands, Poland, Spain and the UK.

ETRMA Aisbl European Tyre and Rubber Manufacturers’ Association www.etrma.org Avenue des Arts 2 Box 12 Tel. +32 2 218 49 40 BE-1210 Brussels - Belgium Transparency Register N° 6025320863-10