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After long and numerous attempts by trade associations to urge the Institutions to tackle the serious problem of few ELTs collections in Italy, an important and concrete signal finally arrived in December with a directive of the Ministry of the Environment, signed by the head of the new Directorate General for the Circular Economy, Laura D'Aprile. This measure, considering that "it is clear that a higher number of ELTs than those declared as having been placed on the market, must be collected", establishes that "all stakeholders linked with the management of ELTs and individual management systems with inputs exceeding 200 tons, shall collect and manage additional quantities of ELTs to be measured as 15% above their targets".
A change of pace
The decision is related to a report that Federpneus and CNA had addressed to the Ministry in October, reporting the seriousness of the situation and requesting urgent measures to deal with the issues. According to some estimates, at the end of 2020 there were at least 30,000 tons of ELTs lying on the ground at tire stores.
The effects of this measure will only be seen in the course of a few months, and at the beginning of 2021 reports of negligence, including some of a serious nature, from tire dealers have still not ceased to circulate throughout the supply chain. However, this is an unprecedented decision, and besides the measure itself, it is perhaps appropriate to emphasize the importance that this directive will have in relation to the reasons given. In fact, the text reads: "In fulfilment of the supervisory activities, this Directorate has found serious anomalies in the management system of end-of-life tires due, in part, to the mode of withdrawal requests adopted by some forms of authorized management in their computer systems that have contributed to the formation of irregular stocks of ELTs at tire shops. In particular, repeated reports received from individual tire dealers and associations have highlighted problems in accepting requests for collection, often justified, erroneously in our opinion, by targets arbitrarily set by the authorized collection bodies themselves. In this regard, we would like to point out that these forms of ELT management, pursuing a public interest such as the management of waste for environmental protection, cannot organize the collection of ELTs in a way that restricts the efficiency of the system, limiting the quantities on the basis of objectives other than those established in Ministerial Decree 182/19, or favouring the withdrawal of ELTs on the basis of purchases made by tire dealers, a practice that violates the principle of fairness and transparency to which they are held".
For the first time, therefore, it is the Ministry of the Environment itself that clearly admits the existence of a series of critical elements that can be traced back to the current regulatory system, in addition to illegal practices that have long been the subject of reports from several players in the supply chain. "A careful examination of this phenomenon has shown that, at least partially, that it can be attributed to problems with the regulations, but equally evident is the number of tires being placed in the domestic market illegally and fake exports of tires that no longer fall within the collection targets, but remain in Italy and in some cases become the object of environmental contribution reimbursements."
The 15% increase in mandatory collection by consortia and individual systems that manage more than 200 tons of ELTs per year, with a possible recalculation of the environmental contribution, has been established with the specific aim of ensuring that collection takes place evenly throughout the country and without interruptions due to unrealistic arbitrarily self-imposed limits, replaced by management targets set by law. Furthermore, the directive specifies that this collection and management percentage may be further increased to a maximum of 20% if it is found necessary.
What will the future hold?
Waiting to see the concrete effects of the measure, Federpneus expresses its satisfaction, and the president Giancarlo Veronesi comments: "It is important that we have finally reached a full recognition of the problem and its scope, and that concrete action have been taken. The measure with which the Ministry establishes an increase in the collection obligations is certainly of great importance from a practical point of view, and we hope that the positive effects will soon be seen throughout the country, with fewer illegal stocks of ELTs. However, this is also a highly significant step, which comes after many years of reports and requests; we hope this marks the beginning of a constructive dialogue with the Ministry in order to promote further measures of a more structural nature to address the causes of the problem, starting with the unfair competition from those who sell tires avoiding taxes and environmental contributions".
This seems to be the intention of the Ministry, since the directive itself concludes by referring to "regulatory initiatives under evaluation aimed at curbing the phenomenon of the irregular dumping of tires".
Now the hope of the whole supply chain is that the recent change of the government will not affect this change of direction. It is clear, in fact, that there will be considerable reorganization in the activities and competences of the Ministry of the Environment, which has taken on the new name of Ministry for Ecological Transition with the Draghi government, defining a change of focus that, in theory, should not interfere negatively with what was being planned in recent months – but only time will tell.